- At ELEVEN, we know your privacy is a serious matter. We strive to ensure that our use of your personal data
is lawful and reasonable, with the ultimate goal of improving our services and your viewing experience.
any of our websites, applications (including the ELEVEN App), products, platforms and services to browse,
create or access content, including when you are not registered or signed in to our service. Here we also
provide some ways for you to exercise control over your personal data, and to contact us if you have
- Empower Sports AG operates subject to laws of Switzerland. We are located at c/o Controva AG, Hoeschgasse
25, 8008 Zürich, Switzerland.
- Empower Sports AG is the controller of personal data the processing of which is described in this Privacy
Policy. Empower Sports AG is hereinafter referred to as “ELEVEN”. The designated EU Representative is: Eleven
Sports Italia S.r.l. via Pietro Giannone 9, 20154 Milan (Italy),
- We encourage you to read this policy completely so that you understand how we rely on personal data to
create the best possible experience for you. We also use this policy to call your attention to the information
about Cookies that help power our offerings from a technical perspective.
- Should you have any questions regarding the processing of personal data by ELEVEN, you can contact email@example.com.
Personal Information We Collect
- Overview: We may receive and collect personal data about you in several ways, including when you download
the ELEVEN App on your device; you sign up to use ELEVEN; you broadcast, stream, upload, download, access or
make use of any ELEVEN Service or Content, you participate in an event streamed or broadcast on ELEVEN, you
give us payment details, you contact our support centre, you participate in a marketing or promotion activity
or you submit your personal data to us for any other reason. We may also receive personal data from third
parties that have obtained it from you and that are permitted to share it with us.
- Categories of personal data when you are logged in to ELEVEN Service: The categories of personal data of
logged in users that we collect include:
- Basic Account and Contact Information: You must provide an email address and password to create an
ELEVEN Account. ELEVEN may also receive basic account information from third party sites, such as when you
choose to sign in via a social network account;
- Payment Methods: In relation to your payments for access to the ELEVEN Service, we collect details of
methods of payment, including but not limited to certain information about credit and debit cards, loyalty
points, vouchers, mobile phone number for payments with telecommunications operators’ bills or use of an
- Preferences, profiles, and other information: We also collect and process certain information on your
activity on the ELEVEN Service, ELEVEN Website and ELEVEN App, such as content selections, viewing
history, and information about your ELEVEN Account, settings data and certain data inferred on their
- Activities: When you take certain actions on the ELEVEN Service that are public or intended to be public
in nature, such as when you broadcast content, participate in a chat, post profile information, follow a
team, or subscribe to a channel. Given the social nature of some of the ELEVEN Service, that information
may be collected, used, or disclosed by others who are part of that social interaction.
- Events: We collect certain information about your activities observed when you are accessing and using
the ELEVEN Website, ELEVEN App or when you react to our marketing communications, including details of
how, when and for how long you have accessed, viewed or used any of our platforms as well as details
regarding site traffic and usage information (for example search queries, navigation behaviour and viewing
time and duration), and, if enabled, voice commands processed through the ELEVEN App;
- Support services information: We collect certain details of your interactions with the ELEVEN support
centre (in case we can attribute the conversation to you), such as the date, time and reason for
contacting ELEVEN, transcripts of chat, email or other conversations;
advertising IDs and other technologies, including ad data. For more information on cookies please refer to
- Device and Browser Information: When you access the ELEVEN Website or the ELEVEN App, we may also
collect information about the device or browser accessing the ELEVEN Services, such as unique device
identifiers, IP address, type, model, settings, operating system, system activity and crash reports.your
device and browser, such as unique device identifiers, IP addresses, the type of device used to access
ELEVEN Service, ELEVEN Website and ELEVEN Account, hardware model and settings, operating system, browser
type, language, system activity, and crash reports;
- Location Information: When you access the ELEVEN Website or the ELEVEN App, based on your IP address, we
may determine the geographical location of a device used to access ELEVEN Service based on your IP
address, however, such information determined does not beyond the level of municipality.
- Information necessary to verify your country of residence in connection with the cross-border content
portability (if applicable in your region): ELEVEN may ask you to provide two means of verification,
including ID card, driving license, passport, utility bill or declaration confirming address, to verify
your country of residence in accordance with the Regulation of the European Parliament and of the Council
2017/1128 on cross-border portability of online content services in the internal market. The information
which ELEVEN collects from you for the sole purpose of verifying your country of residence will be deleted
on completion of verification.
- User Research Information: We collect certain details of your interactions with a ELEVEN User Research
Surveys (in case you decide to contribute, which is completely voluntary), such as your evaluation of
various aspects of ELEVEN Service, your preferences regarding ELEVEN Service properties and your opinion
on certain ELEVEN Service related questions.
- Categories of data when you are not signed in to ELEVEN Service: The categories of personal data of that we
may collect when you are browsing the ELEVEN Website or the ELEVEN App without signing in include data
referred to in the following sections: on Events (2.2.5), Cookies (2.2.7), Device and Browser Information
(2.2.8) and Location Information (2.2.9).
- Childrens’ data: You must be at least 16 years of age or older to create an ELEVEN Account. While
individuals under the age of 16 may use the ELEVEN Service, they may do so only under the supervision of a
parent or a guardian.
- Voluntary provision of data: The provision of your personal data is voluntary but necessary to use some of
the services offered by ELEVEN. Refusal to provide some of your personal data will make it impossible to use
the ELEVEN Service or some of their functionalities, for example its websites, applications, products,
platforms and services to browse or to access content, and will prevent ELEVEN from offering and performing
Purposes for Processing Personal Information
- Overview: We use the information we receive and collect generally for the purpose of providing, promoting,
maintaining, personalizing and improving our services, to develop new services, and to protect ELEVEN, our
platforms, content partners and our users from fraudulent or illegal activity.
- Purposes: Specific purposes for which we process your data include:
- processing personal data necessary for the purposes of conclusion and performance of the agreement with
- to establish, personalize and maintain your ELEVEN Account, and to authenticate your identity when
accessing your ELEVEN account, to provide you with content and to settle payments;
- to provide you with recommendations resulting from automated analysis of your content choices and
other actions made by you while using the ELEVEN Service;
- to provide customer support services and to communicate with you, including to inform you about any
changes to ELEVEN products and services; and
- if applicable - to provide you with the ELEVEN App, including its voice search function available in
some versions of the ELEVEN App.
- Processing personal data to enrich event information - users who are participants in events, may have
their personal and participation information shared with other users or partners for the purpose of
enriching event information, which is our legitimate interest for processing personal data;
- to provide cross-border portability of ELEVEN online content, including verification of the country of
residence in accordance with and based on the Regulation of the European Parliament and of the Council
2017/1128 on cross-border portability of online content services in the internal market;
- processing of personal data in order to fulfil obligations resulting from provisions of applicable laws;
- to fulfil any contractual obligations with our business partners for the purpose of offering ELEVEN
services and for the purposes of financial settlements connected there to, which is our legitimate
interest for processing personal data;
- processing of personal data for marketing of the ELEVEN services,
- For all users except Italy, San Marino and Vatican including through advertising tailored for individual
or group needs and preferences, for example online advertising, which is our legitimate interest
for processing personal data;
- For users in Italy, San Marino and Vatican,
- only through e-mail communications concerning product and/or services similar to the ones you have already purchased,
based on our legitimate interest and in absence of specific consent (known as soft-spam as defined
in art. 130, co. 4 of d.lgs. 196/2003)
- even through targeted advertising based on individual or group needs and interests, like online advertising,
based on our legitimate interest concerning processing of personal data
- processing for the purposes of research, analytics, development, improvement (including user experience
improvement), administration, maintenance, technical support and security of the ELEVEN Service, ELEVEN
Website and ELEVEN App, which is our legitimate interest for processing personal data;
- processing for the purposes of establishment, exercise and defence of legal claims, enforcing or
activities, protecting rights, property or safety of ELEVEN, our customers, employees and other third
parties, which is our legitimate interest for processing personal data; and
- processing for the purposes of reorganization of the ELEVEN group, including changes in ownership or
control of assets, shares or management of ELEVEN, or that of our affiliates, which is our legitimate
interest for processing personal data.
Disclosure of Personal Information
- Your personal data may be disclosed to the following categories of recipients:
- ELEVEN affiliates, which includes our holding companies, subsidiaries and entities that control or are
under common control with ELEVEN, in particular when necessary for the ongoing maintenance and continued
provision of the services to you;
- trusted service providers retained by us to enhance or provide services to you, acting at our
instruction, including hosting services providers, platform development, support and security services
providers, analytics tools and services providers, customer support services providers, payment and
reconciliation services providers;
- marketing services providers supporting us in promoting the ELEVEN Service, including marketing
agencies, email distribution and other marketing tools providers, social media marketing services
providers including Facebook and Google, as well as analytics services providers;
- partners who may offer access to the ELEVEN Service on our behalf and/or partners with whom ELEVEN
co-operates with respect to placing the ELEVEN App on their platforms;
- third parties, including governmental bodies, courts or bodies of similar nature, when it is required in
or any other contract between you and us, to protect our rights, property or safety or that of our
customers, employees, and other third parties; and/or
- third party in relation to reorganization of the ELEVEN group, in particular a third party that acquires
(or proposes to acquire) ownership or control of our assets, shares or management, or that of our
affiliates by any means, or a third party from whom we acquire, ownership or control of assets, shares or
- Please note that ELEVEN offers services in jurisdictions located outside the European Economic Area and some
of the data recipients referred to in clause 4.1 may be located outside the European Economic Area, in
countries with respect to which the European Commission has not issued an adequacy decision (“Third Country”).
- Where personal data is transferred to a Third Country, ELEVEN takes legally required steps consistent with
applicable European data protection legislation to ensure that the personal data is adequately protected in
each such jurisdiction in particular by basing agreements with the relevant data recipients on the standard
data protection clauses adopted by the European Commission or adopted by a supervisory authority and approved
by the European Commission. Should you wish to obtain a copy of them, please contact us at firstname.lastname@example.org.
Data Subject Rights
- Your data subject rights. You have the following rights with respect to your personal data processed by
- Access: You have the right to access your personal data;
- Rectification: You can ask us to have inaccurate personal data amended. You can use the My Account
section on the ELEVEN Website or the ELEVEN App to change basic information about you;
- Erasure: You can ask us to erase personal data. Note that we will keep only personal data that are
necessary for us to comply with financial and tax regulations and for the establishment, exercise or
defense of legal claims;
- Object to marketing: You can object to processing your personal data for marketing purposes;
- Object to other processing: You can object to processing of your personal data based on the legitimate
interest of ELEVEN unless we have a valid ground to continue processing the data;
- Portability: You can ask us to receive your personal data that you provided to ELEVEN in
machine-readable format or have such data transmitted to a third party; and
- Restriction: We may be required to have your data restricted for processing in certain circumstances as
defined in article 18 of the GDPR.
- Exercise your rights: To review, update, delete, or otherwise limit ELEVEN’s use of information that you
have provided directly to ELEVEN, use the Setting section on the ELEVEN website or ELEVEN app. Alternatively
you may contact ELEVEN via email.
- Exercise of your objection to marketing: You may unsubscribe using the link included in every direct email
marketing communication or using the sms code indicated in direct sms marketing communication, it may take a
few days for this request to be processed. You cannot unsubscribe from service administration related emails
and sms messages.
- Withdrawal of consent. In some situations when we may seek your consent for processing. In such a case, you
will have the right to withdraw consent at any time, without affecting the lawfulness of processing based on
consent before its withdrawal.
- Complaints: You can raise a complaint about our processing with the data protection regulator in your
jurisdiction. If you find it difficult to contact the data protection regulator, we will help you.
- ELEVEN maintains data related to your usage of ELEVEN for as long as it is required in order to fulfill the
and accounting purposes, or as otherwise communicated to you. Once you have asked us to close your account and
delete your profile information, we will delete all information that we are not required or permitted to
retain by law.
- Where appropriate we will encrypt, pseudonymize, anonymize and/or segregate information so that we may make
use of it in a manner that avoids unnecessary identification, in the interest of protecting your privacy and
enhancing security practices.
- Maintaining the security and integrity of your personal data is a high priority and we endeavour to maintain
appropriate technical and organisational measures to secure the integrity of information, using accepted
technological standards to prevent unauthorized access to or disclosure of your personal data and to protect
them from misuse, loss, alteration or destruction.
- In order to ensure that the ELEVEN Website, ELEVEN App and ELEVEN Service work properly, to provide you with
a personalised experience, we and certain of our third party service providers may set cookies or similar
technologies (such as in particular web beacons, pixels and advertising identifiers) on your device, subject
to your consent where relevant. A cookie is a small text file that a website saves on your computer or mobile
device when you visit the website. It enables the website to remember your actions and preferences (such as
session status, language, font size and other display preferences) over a period of time, so you don’t have to
keep re-entering them whenever you come back to the site or browse from one page to another.
- The ELEVEN Website uses two basic cookie types: session cookies and persistent cookies. Session cookies are
temporary files stored on the user’s end device until the user logs out, leaves the website or closes the
software (web browser). Persistent cookies are stored on the user’s end device for the time specified in the
parameters of the cookies or until deleted by the user.
- In many cases, the default settings of the web browsing software (web browser) enable cookie storage on the
user’s end device. You can delete or block cookies from being set in your web browser settings or relevant
software. Cookies set by ELEVEN will likely be labelled as first party cookies, and those set by our partners
will be labelled third party cookies. Certain parts of the ELEVEN Website, the ELEVEN Service or the ELEVEN
App may not work properly if first party cookies are blocked or deleted.
- The types of cookies and the purposes for which they are used on the ELEVEN Website and the ELEVEN App
- strictly necessary cookies, which enable use of the services available on the ELEVEN Website and ELEVEN
App, for example cookies used for authentication of users and cookies that ensure security;
- performance cookies, which help us collect information about how the ELEVEN Website, the ELEVEN Service
and the ELEVEN App are used, so that we can perform analytics and improve their performance;
- functionality cookies, which remember choices made by the user and personalise the interface and allow
enhanced functionality and personalisation of the ELEVEN Website, the ELEVEN Service and the ELEVEN App;
- targeting cookies and advertising IDs for delivering adverts more relevant to users and their interests,
as well as ad conversion tracking; these cookies are mainly set by our advertising partners.
- Third parties that engage in online behavioural advertising, or that provide such services to us as
service providers, may offer additional control over this practice via a self-regulatory body called the
European Interactive Digital Advertising Alliance. For further details regarding the collection of
information by third-party advertising companies or to exercise choices over online behavioural
advertising practices, visit https://youronlinechoices.eu/.
Changes to This Policy
and will inform users of such amendments and of their effective date.