GDPR and Journalism

Last updated: 2026-06-02

This notice explains why and how Almanacstats LLC ("Almanacstats", "we", "us") publishes information about sportspersons, coaches, referees, officials, clubs, federations and other persons in their public sporting role, and the rights that apply to that publication under the European data-protection framework. It is the document referred to in Article 12(1) of Regulation (EU) 2016/679 ("GDPR") for the purposes of journalistic processing carried out on the Platform.

If you are a visitor or registered user of the Platform looking for information about how we handle your account, browsing and device data, please read the Privacy Policy instead.

1. Who we are and what we do

Almanacstats is an editorial media product covering competitive sport worldwide. We publish:

• factual data — schedules, results, line-ups, statistics, injuries, transfers, career histories, awards;
• analytical content — ratings, heat maps, expected-goals values, momentum charts, team form indicators;
• editorial content — match previews, post-match reports, opinion pieces, interviews, season retrospectives;
• visual content — third-party logos, photographs and broadcast clips used in our editorial capacity under the journalism exemption.

The Platform addresses the general public and aims at the systematic dissemination of information of public interest about sport. It is published by Almanacstats LLC, a company registered in the Republic of Croatia, registration number Registration pending, registered seat Registered office to be confirmed upon incorporation.

2. The legal basis we rely on

Our editorial processing of personal data is carried out on the basis of:

• Article 85 GDPR — "Processing and freedom of expression and information", which requires Member States to reconcile data protection with journalism, academic, artistic and literary expression;
• the Croatian Implementing Act of the GDPR (Zakon o provedbi Opće uredbe o zaštiti podataka, NN 42/2018), in particular Article 38, which sets the journalistic-purposes exemption in Croatian law;
• the Croatian Media Act (Zakon o medijima, NN 59/04 with subsequent amendments, consolidated text NN 81/13), which defines media activity and editorial responsibility;
• the Croatian Electronic Media Act (Zakon o elektroničkim medijima, NN 111/2021), which applies to electronic publishers including websites and applications;
• Article 11 of the Charter of Fundamental Rights of the European Union — freedom of expression and information;
• Article 10 of the European Convention on Human Rights — freedom of expression — as interpreted by the Court of Justice of the European Union in Tietosuojavaltuutettu v. Satakunnan Markkinapörssi (C-73/07) and Buivids v. Datu valsts inspekcija (C-345/17).

The cumulative effect of these instruments is that we may process personal data of sportspersons and other public figures for journalistic purposes without their individual consent, that several rights granted by Articles 15–22 GDPR are subject to limits described below, and that the special-category restrictions of Article 9 are not blanket prohibitions when the publication serves a matter of public interest.

We restrict ourselves to the editorial purpose. We do not use editorial profiles for behavioural advertising, credit-scoring, employment decisions or any other purpose unrelated to journalism.

3. What public-figure data we publish, and why

We do not publish, in our editorial capacity:

• private addresses, private phone numbers or private email addresses;
• bank-account information or other financial detail beyond what is disclosed by the wider sporting press;
• information about a sportsperson's family members where those family members are not themselves public figures;
• information about a sportsperson's political opinions, religious beliefs, sex life or sexual orientation, except where the person has actively brought those topics into the public sphere themselves;
• content depicting minors except where the minor has an established public sporting role and the depiction is in their sporting context.

4. Sources

We obtain editorial data from:

• official league and federation feeds, club press offices and press conferences;
• our licensed sports-data partners (statistical providers and image agencies — see Section 12 below);
• public statements made by athletes, clubs and officials on their official channels;
• our editorial staff and contributors who attend events, conduct interviews and produce original analysis.

Where a particular piece of content is licensed from a third party (a wire-service photograph, a broadcaster clip, an infographic), we mark it as such or carry a visible credit in line with the licence and applicable national copyright rules.

5. Limitation of subject rights

Article 85 GDPR and Article 38 of the Croatian Implementing Act allow Member States to derogate from a series of GDPR provisions for processing carried out for journalistic purposes. The following rights are restricted on the Platform to the extent that giving full effect to them would be incompatible with our editorial mission:

These restrictions are not blanket. Each request is assessed individually under the standard of necessity and proportionality.

6. How to contact us as a subject of editorial content

If you are a sportsperson, coach, referee, official or other person whose data appears on the Platform and you wish to:

• request correction of a factual mistake;
• supplement a fact with new information;
• request take-down of a specific photograph or quote;
• raise any other concern about how you are covered;

please write to [email protected] from an email address that allows us to verify your identity or representation, or use postal contact: Almanacstats LLC, Registered office to be confirmed upon incorporation.

We will reply within thirty (30) days, with a reasoned written decision. Where a take-down is granted in part only — for instance, replacement of one photograph but retention of the surrounding text — we will explain the editorial reasons.

If you disagree with our decision, you have the right to lodge a complaint with the Croatian Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, AZOP), Selska cesta 136, Zagreb, azop.hr, and to seek judicial review under the Croatian Administrative Procedure Act.

7. International dimension

Our editorial activity is global by nature — we cover sport in every continent. We rely on the journalism exemption of GDPR and Croatian law within the European Economic Area, and on the corresponding journalism / public-interest exemptions of:

• the UK GDPR and the UK Data Protection Act 2018, Schedule 2 Part 5;
• the California Consumer Privacy Act (CCPA / CPRA) §§ 1798.145(k) and 1798.145(l);
• the Brazilian General Data Protection Law (LGPD) Article 4(II)(a);
• the Russian Federal Law 152-FZ Article 6(1)(11) — journalistic activity exception;
• the Indian Digital Personal Data Protection Act 2023 Section 17(2)(b) — research, archiving, statistical purposes;
• the Japanese Act on the Protection of Personal Information (APPI) Article 57 — press organisations exemption;
• the Australian Privacy Act 1988 Section 7B(4) — acts of media organisations;
• the Canadian PIPEDA Section 4(2)(c) — journalistic, artistic, literary purposes;
• the South African POPIA Section 7 — exemption for journalistic processing in the public interest;
• equivalent doctrines in MENA, ASEAN and other jurisdictions, applied with respect for local law.

We monitor these regimes and adapt our practice when a country requires additional notice, registration or take-down workflow.

8. Retention

Editorial content is retained for as long as it remains a matter of public record. Articles, results, match data and historical statistics may be retained indefinitely as an editorial archive, in line with Recital 153 of the GDPR (archiving for journalism in the public interest).

Where a correction or partial take-down has been agreed, the corrected version replaces the original and the original is retained only in our internal editorial log for accountability.

9. Editorial standards

Our internal editorial standards include:

• separation of editorial decisions from advertising and partnership functions;
• a documented correction and right-of-reply procedure;
• a named editor responsible for the Platform under the Croatian Media Act;
• staff training on EU data-protection law and journalism ethics;
• a documented notice-and-action procedure for the EU Digital Services Act.

A summary of our standards can be requested from [email protected].

10. Children

We cover persons who appear in their public sporting capacity. Where that person is a minor, we follow the best-interests-of-the-child principle of Article 24 of the EU Charter and Croatian child-protection law:

• we do not publish private information about minors;
• we limit visual content to the sporting context;
• we respond promptly to representations from guardians or clubs about a specific minor.

11. Image and visual content

Many of the visual elements on the Platform — club crests, league logos, athlete photographs — are third-party content. We use such material in our editorial capacity in reliance on:

• the journalism exemption to Article 9 GDPR processing where personal data is involved;
• the news-reporting and quotation exceptions of the Croatian Copyright and Related Rights Act (NN 111/2021);
• the corresponding exceptions of the EU Digital Single Market Directive (2019/790);
• the nominative-fair-use doctrine of trademark law, which permits the use of a third-party mark for the descriptive purpose of identifying the entity referred to;
• licences obtained from our visual partners, where applicable.

Third-party rightsholders retain their rights. A rightsholder may notify us at [email protected] of a specific item they consider to fall outside the editorial scope, and we will assess the notice without undue delay.

12. Data partners

Almanacstats obtains structured sports data from licensed providers and editorial content from accredited contributors and wire services. The identities of our current data and visual partners can be requested from [email protected] for legitimate purposes such as journalistic verification or rightsholder correspondence.

13. Changes

We will update this notice when our editorial practice changes materially or when the applicable law evolves. The "Last updated" date reflects the most recent revision.

14. Contact

Editorial corrections and rightsholder correspondence — [email protected]. Postal — Almanacstats LLC, Registered office to be confirmed upon incorporation. Supervisory authority — AZOP, Selska cesta 136, Zagreb, azop.hr.