PRIVACY POLICY

This Promotion Privacy Notice supplements the Delta Privacy Policy and applies to personal data processed in connection with the Fantasy Investment League – RSCA Edition (the “Competition”) organised by Opus Labs NV, having its registered office at Predikherenlei 1 - bus 5, 9000 Ghent (“Delta”, “we”, “us”).

If there is any conflict between this notice and the Delta Privacy Policy regarding the Competition, this notice prevails.

1. Data controller

The data controller is:

Delta (Opus Labs NV)
Predikherenlei 1 - bus 5
9000 Ghent
Belgium
Email: support@delta.app

2. Personal data we process

In connection with the Competition, we may process the following categories of personal data:

• Identification and contact data (e.g. name, email address, country of residence).
  
• Competition data (e.g. registration date and time, XI composition, portfolio performance, ranking, quiz participation and scores).
  
• Communication data (e.g. emails sent to and from participants, support requests).
  
• Technical data related to the use of the Competition website (e.g. IP address, device and browser data, cookies and analytics, in accordance with our Cookie Policy).
  

If you win a prize, we may also process further information necessary to verify your eligibility and arrange the prize (e.g. proof of age or residence, preferred dates, delivery address).

3. Purposes and legal bases

We process personal data for the following purposes and on the following legal bases:

• Operating the Competition
  
  • registering participants, managing entries, operating the leaderboard and daily quizzes, and selecting winners;
    
  • Legal basis: performance of a contract (acceptance of the Official Rules) and/or our legitimate interests in organising and promoting the Competition.
    
    
• Communicating with participants
  
  • sending Competition-related communications (e.g. confirmations, updates, winner notifications);
    
  • Legal basis: performance of a contract and/or our legitimate interests.
    
• Awarding and administering prizes
  
  • verifying eligibility, arranging prize delivery, handling logistics with partners;
    
  • Legal basis: performance of a contract and compliance with legal obligations (e.g. accounting, tax).
    
• Fraud prevention and security
  
  • detecting and preventing abuse, multiple accounts, or manipulation of results;
    
  • Legal basis: our legitimate interests in ensuring the integrity of the Competition and protecting our services.
    
    
• Marketing communications (optional)
  
  • where you choose to receive marketing communications (for example by ticking a checkbox on the landing page), we use your data to send you product updates, news and offers from the Delta application;
    
  • Legal basis: your consent, which you can withdraw at any time via unsubscribe links or by contacting us.
    
    
• Analytics and performance measurement
  
  • using aggregated and/or pseudonymised data to analyse the performance of the Competition and improve our products and campaigns;
    
  • Legal basis: our legitimate interests in improving our services and marketing activities.
    
    

4. Recipients and international transfers

We may share personal data with:

• other entities within the eToro Group, where relevant for support, analytics or compliance;
  
• service providers such as:
  
  • website hosting and landing page providers (e.g. Webflow),
    
  • customer engagement and messaging platforms (e.g. Braze),
    
  • analytics tools (e.g. Google Analytics),
    
  • prize partners and logistics providers (e.g. RSC Anderlecht, hospitality providers, voucher issuers).
    

Some of these recipients may be located outside the European Economic Area (EEA). Where this is the case, we implement appropriate safeguards, such as standard contractual clauses approved by the European Commission, as described in the Delta Privacy Policy.

5. Retention

We keep personal data related to the Competition for as long as necessary to:

• run the Competition and handle any complaints or disputes;
  
• comply with legal obligations (for example in accounting or tax); and
  
• maintain appropriate records of our marketing campaigns.
  

In general, Competition-specific data is kept for up to 12 months after the Competition ends, unless a longer retention period is required by law or justified by ongoing legal proceedings. Data used for marketing purposes may be kept longer, in line with our Delta Privacy Policy and until you unsubscribe or object.

6. Your rights

Under applicable data protection laws (including the GDPR), you have rights in relation to your personal data, such as:

• the right of access, rectification and erasure;
  
• the right to restrict or object to processing;
  
• the right to data portability; and
  
• where processing is based on consent, the right to withdraw consent at any time.
  

You can exercise these rights by contacting us at support@delta.app. You also have the right to lodge a complaint with your local data protection authority.

Further details about your rights and how we process personal data are available in the Delta Privacy Policy.