Privacy Notice on the Processing of Personal Data — BetwixtPro

1. Data Controller

The Data Controller for processing activities directly attributable to the BetwixtPro platform is:

Antonio Lo Re

viale San Teodoro 25 - Catania - Italy

For requests concerning this privacy notice or the exercise of privacy rights, the email address above may be used.

2. Scope of this Privacy Notice

This privacy notice describes the processing of personal data carried out through the BetwixtPro website and services, including Consumer and MY authentication systems, application modules, support features, payment services and the technical integrations used by the platform.

The Cookie Policy and the management of non-essential tracking technologies are addressed separately.

3. Privacy roles in modules used by facilities

For data processed directly by BetwixtPro for the management of the platform, accounts, authentication, security, support and billing, Antonio Lo Re acts as Data Controller.

When a facility uses BetwixtPro modules to manage its own customers, players, collaborators, bookings, availability or other operational information relating to its activities, the facility may determine the purposes and content of those processing activities. In this scenario, the facility acts as Data Controller for the data of its own data subjects, while BetwixtPro processes such data on behalf of the facility as part of the technical provision of the service, in accordance with the applicable agreements.

4. Categories of data processed

Depending on the features used, BetwixtPro may process:

identification and contact data, such as first name, last name, email address, telephone number and address;
account and organisation data, including username, company/facility, role, permissions, VAT number where provided and internal identifiers;
authentication and security data, including session identifiers, token hashes, challenges, timestamps, access information and authentication-provider identifiers;
Google data used for Sign in with Google: the stable Google identifier (sub), email address, email_verified status, first name, last name and profile picture where returned by Google;
operational module data, including players/customers, collaborators, instructors, bookings, availability, notifications, notes, tags, memberships, levels and data relating to managed activities;
data contained in requests submitted through public forms or support channels, including free-text content entered by the user;
payment and billing data: BetwixtPro processes Stripe identifiers, billing email address and customer/payment method/subscription/invoice references; full card details are entered through Stripe Elements and, in the audited backend paths, are not handled by BetwixtPro as raw card numbers;
images and files uploaded by the user; such content may include personal data where it depicts individuals or contains identifying information;
technical and usage data necessary for the operation and security of the service, including IP address in flows where this is provided for, session information, application logs and preferences stored in the browser.

5. Purposes and legal bases

5.1 Account creation and management and access to services

Data is processed to create and manage accounts, authenticate users, maintain sessions, link an account to authorised modules and make the requested features available.

Legal basis: performance of a contract or steps taken at the request of the data subject prior to entering into a contract; for measures strictly necessary for security, the legitimate interests of the Data Controller in protecting the service and user accounts.

5.2 Email access / magic login

For Consumer magic login, the email address is used and challenge and technical verification data are generated. The challenge has a technical validity of 15 minutes; the system applies a 60-second throttle and a maximum number of attempts in accordance with the technical rules of the service.

Legal basis: performance of the requested service and legitimate interests in the security of the authentication process.

5.3 Sign in with Google

If the user chooses "Sign in with Google", BetwixtPro receives and verifies server-side the credential provided by Google Identity Services. The system uses the stable Google identifier (sub) to recognise the linked identity and may receive the email address, email_verified status, first name, last name and profile picture.

For the first linking or creation of a Consumer account, the current code requires a verified Google email address. For subsequent sign-ins by an identity that is already linked, the identity is primarily resolved through the stable Google subject (sub).

The Google credential is not used as a persistent BetwixtPro application session: once authentication is completed, BetwixtPro issues its own Consumer session.

Google data is used exclusively to provide authentication, correctly link the user's identity and maintain the profile data necessary to provide the service. BetwixtPro does not sell data obtained from Google and does not use it for behavioural advertising, credit scoring or the training of general-purpose artificial intelligence models.

Legal basis: performance of the service requested by the user through the chosen authentication method; legitimate interests in the security and integrity of the account.

5.4 MY accounts and business data

For business/administrative accounts, identification, contact and business data, credentials and roles/permissions may be processed to create, activate and manage the account and allow use of the subscribed services.

Legal basis: performance of a contract and pre-contractual measures; compliance with legal obligations where applicable to administrative and accounting management.

5.5 Contact, support and availability requests

Data entered in contact or availability forms is used to respond to the request, forward it to the relevant facility where necessary and prevent abuse through security tools such as reCAPTCHA.

Legal basis: pre-contractual measures or performance of the data subject's request; legitimate interests in preventing spam and abuse.

5.6 Management of players/customers, bookings, staff and facility activities

Sport Hub modules may process data relating to players/customers, linked identities, collaborators, instructors, bookings, availability, notifications and operational history in order to allow the facility to manage its activities through BetwixtPro.

Legal basis: for processing carried out by the facility as Data Controller, the legal bases determined by the facility apply; BetwixtPro processes the data on behalf of the facility as part of the technical provision of the service, in accordance with the applicable agreements.

5.7 Payments and subscriptions

Data necessary for payments and subscriptions is processed to manage purchases, renewals, billing, payment and termination of the service. Card details are entered through Stripe.

Legal basis: performance of a contract; compliance with legal, tax and accounting obligations for data whose retention is required by law.

5.8 Security, logging and prevention of abuse

BetwixtPro processes technical data and logs to protect the application, accounts and infrastructure, diagnose malfunctions, prevent unauthorised access and document relevant technical events. The audit identified that some application logs may contain identifiers and, in specific legacy flows, technical activation data.

Legal basis: the legitimate interests of the Data Controller in the security, reliability and defence of the service and its rights.

6. Data stored in the browser

BetwixtPro uses browser storage necessary for the operation of the requested features. Technical data identified by the audit includes Consumer session tokens, temporary claim and return-target data, MY access/refresh tokens and application preferences.

The server-side Consumer session has a technical duration of 30 days. Certain temporary handoff data has a validity of 15 minutes. MY tokens are issued with a technical expiry of 10 hours. Data may remain in the browser for a different period where the individual key does not implement its own TTL and is removed through logout, consumption, logical expiry or another action provided by the service.

Cookies, trackers and third-party technologies are described in the separate Cookie Policy.

7. Recipients and service providers

Personal data may be disclosed or made accessible, only to the extent necessary, to the following categories of recipients:

infrastructure, hosting, database, storage and technical-service providers;
email/SMTP providers used for authentication, activation, support and notification messages;
Google, for Sign in with Google, reCAPTCHA, Google Tag Manager and Google Maps in their respective features;
Stripe, for payments and subscriptions;
Meta/Facebook, when the user uses Facebook publishing or linking features;
facilities/organisations using BetwixtPro, where the data relates to requests or activities managed by the facility;
advisers and authorised persons where necessary to comply with legal obligations, ensure security or protect rights.

8. Transfers to countries outside the EEA

Some technology providers may process data outside the European Economic Area. Where an international transfer applies, it must take place in accordance with Chapter V of the GDPR, on the basis of an adequacy decision by the European Commission or, where necessary, appropriate safeguards such as the Standard Contractual Clauses and any additional measures that may be applicable.

9. Data retention

BetwixtPro retains personal data for as long as necessary to achieve the purposes for which it was collected and, subsequently, for any period required to comply with legal obligations, manage disputes or protect rights.

Where the code provides for a technical expiry, the relevant rules apply, including:

Consumer magic challenge: 15 minutes;
magic-login throttle: 60 seconds;
server-side Consumer session: 30 days;
MY access and refresh tokens: 10 hours;
Consumer authentication return target: 15 minutes.

For accounts, linked identities, requests, players/customers, bookings, notifications, images, payment/billing data and logs without a technical TTL, the retention period is determined on the basis of the duration of the relationship, operational necessity, applicable legal obligations and the periods necessary for the establishment, exercise or defence of legal claims.

Once the relevant purposes and applicable retention periods have ended, the data is deleted or rendered no longer identifiable, unless further retention is required by law.

10. Security

BetwixtPro adopts technical and organisational measures aimed at protecting data against unauthorised access, loss, alteration or improper disclosure. The technical mechanisms identified include expiring application tokens, server-side storage of Consumer token hashes, session revocation and server-side verification of Google credentials.

No security measure can completely eliminate all risks associated with the transmission or storage of data.

11. Provision of data

Data identified as necessary within individual flows is required in order to provide the relevant feature. Failure to provide such data may prevent account creation, authentication, a response to a request, a booking or use of the relevant service.

Use of Sign in with Google is optional where an alternative sign-in method is available within the service.

12. Sources of personal data

Personal data is collected:

directly from the data subject;
from the data subject's Google account when Sign in with Google is used;
from the facility/organisation using BetwixtPro to manage its users, customers or collaborators;
automatically by technical systems to the extent necessary for sessions, security and operation of the service.

13. Automated decision-making

Within the technical scope audited, no solely automated decision-making processes were identified that produce legal effects concerning the data subject or similarly significantly affect the data subject within the meaning of Article 22 GDPR.

14. Rights of the data subject

Where provided for by the GDPR, the data subject may request:

access to their personal data;
rectification of inaccurate data;
erasure;
restriction of processing;
data portability, where applicable;
objection to processing based on legitimate interests;
withdrawal of consent, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

Requests may be sent to info@commonjoin.com.

The data subject also has the right to lodge a complaint with the competent supervisory authority, which in Italy is the Garante per la protezione dei dati personali.

15. Changes to this Privacy Notice

This privacy notice may be updated when features, processing activities, service providers or legal requirements change. The updated version will be made available on the BetwixtPro Privacy Policy page.

For Google data, BetwixtPro keeps this privacy notice up to date with the ways in which the application accesses, uses, stores or shares data originating from the user's Google account.