Coolbet - Football LiveScore App Privacy Notice

What is a Privacy Notice?

Our mission is to give our users of this Application (“App”) a unique experience through top-class product, innovation, transparency and customer care. Please read this Privacy Notice carefully so that you understand what information we collect and retain about you, how it is being used and for what purpose, with whom it may be shared, and how you may exercise your rights and choices with respect to our processing of your Personal Data. This Privacy Notice also describes the measures we take to safeguard your Personal Data and how you may contact us if you have any questions about our privacy practices. 

“Personal Data” means any information about you that identifies you or makes you identifiable directly or indirectly through means that can reasonably be used.

“Process” or “Processing” of your Personal Data includes any operation or set of operations which is performed regarding your Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of your Personal Data.

“Cookies” are small pieces of files that are placed on your mobile device or tablet (all referred to as the “Device”) which you use to access our mobile app. They help us to facilitate and make your interaction faster and easier, as well as provide analytics and reporting information. Similar to cookies, we also use other tracking technologies, like web beacons, tracking pixels, digital fingerprints, which in many instances are reliant on cookies to function properly, and so declining cookies will impair their functioning 

Who Collects and Manages Your Personal Data?

E-2 Communications Malta Ltd. with registered office at 10, Lapsi Street, Level 1, San Giljan, STJ 1261, Malta (referred to as “the Controller”, “we”, “ours”) is the Controller of your Personal Data provided to, collected by or for, or Processed in connection with this App. This means that we decide why and how your Personal Data is used when you use our App, determine the purposes for using your data, such as improving our App, and the methods by which we process it, always ensuring your privacy and data protection rights are respected.

How to Contact us?

If you have any questions about this Privacy Notice or concerns about how we manage your Personal Data, please contact us by email at dataprotection@e2-malta.com. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. 

4. How and Why Will we Process your Personal Data?

Our App provides you with free of charge information on live and upcoming football events. 

For Users of our App the collection, use and sharing of your Personal Data are subject to this Privacy Notice, including its respective updates. If you disagree with how we handle Personal Data as described in this Privacy Notice, please refrain from downloading and using our App.

We highly value our customers’ trust and adhere to the principles of transparency, fairness, and lawfulness. We only process your Personal Data when we have a legal basis for it and to the extent that is necessary for a particular purpose. If you want to get acquainted yourself with all the terms, definitions and legislative requirements concerning your privacy and the Processing of your Personal Data, you can consult the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data of the European Parliament and of the Council of 27 April 2016  (“GDPR”) and all other applicable and relevant data protection laws, as amended, superseded or replaced from time to time.

Our goal is to deliver the best user experience to you. We may process your Personal Data, with the help of automated systems where necessary, to personalise and improve your experience using our App, and to maintain and offer exciting features. 

5.  What Are the Legal Bases and Purposes of Your Personal Data Processing?

In compliance with the GDPR and other applicable data protection laws, we process your Personal Data only when there is a legal basis to do so. 

5.1. Provision of App (Article 6(1)(b) of the GDPR)

We need to Process your Personal Data to be able to provide you our App for use and to implement safety procedures.

5.2. Legitimate interest (Article 6(1)(f) of the GDPR)

We may use your Personal Data for our legitimate interests or those of a third party, provided these interests do not infringe on your rights, freedoms, or interests. This means we carefully consider and balance any potential impact on you against our interests before Processing your Personal Data. For example, we may Process your Personal Data for the purposes of analytics, research and App development to provide You and others with a better, more intuitive and personalized experience, to drive growth and engagement with our App. 

You have the right to object to processing based on our legitimate interest, and you can do this by contacting us by email at dataprotection@e2-malta.com. However, there are instances where our legitimate reasons for processing your Personal Data may override your rights, in which case we will continue with the processing as necessary. 

5.3.Your consent (Article 6(1)(a) of the GDPR)

You can voluntarily give (opt-in) and withdraw (opt-out) your consent through your privacy settings at any time by managing your cookie preferences. Please note that you cannot opt-out from strictly necessary cookies.

6. What Personal Data do We Process and How Do We Collect It? 

We Process Personal Data related to your App usage, which includes, but is not limited to:

6.1. Logs, your Device and Location. Our servers automatically log usage data when you interact with our App. This includes actions like viewing content, clicking on various app elements and links, installing or updating our apps. We process information such as the UserId, your Internet Protocol (IP) address, timestamps, details about your Device (including type and operating system), sessions, App interactions, crash reports and your location. This data helps us to understand and improve user interactions with our services, to make sure that our App works securely and properly. 

6.2. Cookies and Other Technologies, which include:

• “Strictly Necessary Cookies” are required for technical reasons in order for the App to operate and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services. 
• “Analytics Cookies”, including but not limited to Cookies served by Google Analytics and/or Google Firebase, which help to collect limited data to enable us to better understand your use of the App, helping us customise our App for you and bug reporting. Further information on how Google collects and uses this data is available on Google's website at: https://www.google.com/policies/privacy/partners/. You can opt-out of all Google supported analytics within the Services by visiting https://tools.google.com/dlpage/gaoptout.

7. With Whom May We Share Your Personal Data?

We may share your Personal Data with the following recipients:

7.1. Internally with authorised employees, contractors, consultants, agents, affiliates, and subsidiary companies within our business group or linked to our parent company for professional purposes. Access is strictly limited to those who need it to perform their duties.

7.2. In the event of a change in control or sale, merger, joint venture, or preparation for these events, any acquiring entity or partner will have the right to continue processing your Personal Data as outlined in this Privacy Notice. 

7.3. Authorities and other public and private entities where necessary to comply with our legal obligations. 

7.4. Third-party providers, as necessary to deliver, manage, and improve our App. We carefully select these providers to ensure they comply with applicable laws, protect your data, implement necessary security measures, and delete your data from their servers upon our request. Specifically, we may transfer your Personal Data to the following third-party providers:

• Google Analytics, Google Firebase and other providers for analytics. Upon your consent given via Cookie preferences we use your Personal Data for analytics and surveys by generating aggregated data. All insights are derived in a way that maintains your anonymity. For deeper insights and analytics, we may engage third-party service providers, always ensuring your privacy is protected. For example, we use tools like Google Analytics to understand user interactions on our App, always prioritising the security of your Personal Data. Please, visit Google's Business Data Responsibility site and read Google’s Privacy Policy to get more information about how Google processes personal information.
• Other Service Providers. In certain cases we may use other service providers to help us provide our Services and adhere to our legal obligations (e.g., maintenance, analytics and development). Such Service Providers will have access to your Personal Data as reasonably necessary to perform these tasks on our behalf and are obliged not to disclose or use your Personal Data for other purposes. 

7.5. Our Business Partners, with whom we have a contractual relationship on affiliate marketing. The scope of data shared is limited to those strictly required for the provision of our services and obligations. 

8.  International Data Transfers

We never sell your Personal Data, nor do we publish it publicly on the Internet or elsewhere.

As our partners and providers operate globally, it may be necessary to transfer and store your Personal Data outside the country from which you access our App, including outside the EU/EEA. For example, your Personal Data may be Processed and stored by companies operating outside the EU/EEA who are our affiliates or provide us with certain services, like cloud storage, or computer servers. We take all reasonable measures to ensure that your Personal Data remains safe when transferred and stored.

We will only transfer your Personal Data if: 

• the country to which the Personal Data will be transferred has been granted a European Commission adequacy decision, confirming that such third country provides adequate protection for your Personal Data; or
• upon your explicit consent; or 
• transfer under legal justifications, supported by strong safeguards like EU standard contractual clauses or binding corporate rules approved by an EU authority;

9. What Security Measures Do We Take to Safeguard Your Personal Data?

While no data transmission or storage can be guaranteed to be absolutely secure, we have taken appropriate technical and organizational security measures to help protect your Personal Data and to prevent it from being accidentally lost, used, altered, disclosed, destroyed, or accessed without authorisation. These measures include policies, confidentiality agreements with third parties, secure development practices, due diligence of service providers, and products and services that may be used. 

We have implemented security standards to safeguard and protect your Personal Data and we regularly monitor our systems for possible vulnerabilities and attacks, including penetration testing, educating our employees by trained professionals and using all proportionate security measures for our network and infrastructure. Also, we have put in place procedures to deal with any suspected Personal Data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so. We use cryptography to ensure the confidentiality, authenticity and/or integrity of your Personal Data at rest and data in motion.

Please take into account that we cannot guarantee the absolute security of your Personal Data and there is no guarantee that it may not be accessed, disclosed, altered or destroyed by breach of any of our physical, technical or managerial safeguards.

10.  How Long Do We Keep Your Personal Data?

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for. Once your consent is withdrawn, we will promptly delete your data from our records, unless we are legally required to retain it for a longer period.

11. Persons Who Are Not of Legal Age

Our App is intended for use by persons 18 years (or the legal age in their country of residence) or older. Therefore we do not knowingly collect any Personal Data from minors. If you are the parent or guardian of a minor and believe that such person has provided us with Personal Data, please contact us at dataprotection@e2-malta.com. If we learn that we have unknowingly collected or received Personal Data from a minor, we will make reasonable efforts to delete such information from our records.

12. What Rights Do You Have Regarding Your Personal Data?

You have the right to access your Personal Data, the right to correct, update or request the deletion of your Personal Data, the right to restrict the processing of your Personal Data, the right to object to the processing of Personal Data, the right to data portability and the right not to be subject to automated decision-making (with no human intervention), including profiling.

Moreover, you have the right to file a complaint to the Maltese Office of the Information and Data Protection Commissioner: idpc.info@idpc.org.mt , phone +356 2328 7100.

To exercise your rights, submit a request with your ID or digital signature, specifying the right, date, and contact information We will consider your request in accordance with Applicable Laws. Please contact us at dataprotection@e2-malta.com for help. 

Exercising one right does not affect your ability to exercise others. We shall respond free of charge within 30 days.

12. Updates to this Privacy Notice

We may regularly update this notice and these updates take effect immediately. Check your App for the latest version. For major changes affecting how we handle your Personal Data, we will provide notice through our App to allow you to review the changes before they become effective. 

You acknowledge that your continued use of our App after we publish or send a notice about our revised Privacy Notice means that you accept such change and that the collection, use and sharing of your Personal Data is subject to the updated Privacy Notice.

Version 1 dated 21.07.2025