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Televoting data protection notes

The following information is intended to provide you as a participant in the Eurovision Song Contest televoting (Televoting) with an overview of the personal data we collect and process about you when you vote by call and about your rights under data protection law.

As joint data controllers, We, The European Broadcasting Union jointly with the Participating Broadcasters and the Host Broadcaster

L’Ancienne-Route 17A

1218 Le Grand-Saconnex, Genève, Switzerland

(the EBU)


digame GmbH

Schanzenstrasse 38

D-51063 Cologne


(the Company)

are committed to protect your personal data and respect your privacy in compliance with applicable data protection laws notably the EU General Data Protection Regulation 2016/679 (GDPR) and the German Federal Data Protection Act (BDSG). We will not process your personal data for any other Purposes that the ones set below.

The EBU and the Company have executed specific and separate joint controllers’ arrangement pursuant to Article 26 of GDPR, the key content of which is available on demand at the premises of either the EBU or the Company.

What categories of personal data are being processed

We will process only the personal data which we receive when you cast your vote either by call or by texting SMS message (whether sent directly or via the ESC App) using connections provided by your landline or mobile network provider.

When doing so, we will – depending on your country of origin - gather the following categories of data from you if applicable

  • Your mobile telephone number (MSISDN – Mobile Station Integrated Services Digital Network Number)

  • The date and time at which you participated in Televoting

  • The song number you voted for

  • The name of your landline or mobile network provider

  • The type network provider contract which you have (prepaid, contract).

What are the Purposes of processing and what is the legal basis for this?

We collect your personal data on the basis of our legitimate interest (Art. 6 Para. 1 (f) GDPR) to generate the official results determining the ranking of the songs entered in the ESC and the winner thereof.

Your participation is voluntary and by taking part in the Televoting, you consent that we process your personal data (listed above) for the Purposes of:

  • calculating and generating valid and official results of the ESC on the basis of the votes casted by the audience (including yours)

  • generating aggregated statistics on the voting in the ESC

  • publishing aggregated and anonymized results

Who will have access to your personal data?

To participate in the Televoting, you are using a telecommunication service facilitated by your national telecommunication carrier and/or aggregator who may forwards part or all of your personal data to the Company to enable the calculation of a valid audience result.

Inside the Company your personal data will be made accessible to the departments which need it to fulfil the Company’s contractual and legal obligations. Service providers and vicarious agents working for the Company may also receive personal data for such purposes provided that they undertake to maintain, in particular, confidentiality and integrity. Such recipients could, for example, be IT service or telecommunications providers.

There will be no transfer of personal data to recipients outside the Company. Whilst the EBU is joint controller with the Company with regard to the Televoting, the Company will not transfer your personal data to the EBU which will receive from the Company only anonymised results for the purposes listed above. Only the aggregated and anonymized results will be published.

Will personal data be transferred to a third country or an international organization?

Votes cast outside of Germany will be transferred to the Company in Germany in order to process them and no further transfer will be operated. The Company will not transfer personal data to third countries outside the European Economic Area.

How long will my personal data be kept by us?

The Company will process and store your personal data for as long as required to fulfil our contractual and legal obligations.

Once the personal data is no longer required to fulfil contractual or legal obligations, it will regularly be erased unless its further processing – for a fixed period of time – is required for the following purposes:

  • Fulfilment of commercial- and tax-law related storage obligations,

  • The German Commercial Code (HGB), Tax Code (AO), Money Laundering Act (GwG). These laws generally specify storage periods for archiving and documentation purposes ranging from two to ten years.

What are your rights?

You have the right to access your personal data, and to request that they are corrected in the event of inaccuracy or deleted in the event that they are no longer necessary in relation to the purposes for which they were collected and processed.

In some cases, you have the right to ask for a restriction of processing, for data portability or to object to processing. Any consent you give to the processing of your personal data by us may be withdrawn at any time. Please note that the withdrawal of consent will only apply for the future. Processing which took place before the withdrawal of consent will not be affected by it.

You may exercise your rights by sending your request by mail at [email protected].

If you consider that the processing of your personal data constitutes a violation of the data protection law(s), you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union of your usual place of residence, your place of work or the place where the violation occurred.

How can you contact our Data Protection Officers?

If you have any questions or concerns about this Privacy Notice you may contact:

The Company’s Data Protection Officer at [email protected]

EBU’s Data Protection Officer at [email protected]

Effective date and Changes

This Privacy Notice is effective from 11 February 2021

We reserve the right, at our complete discretion, to change, modify, add, or remove portions of this Privacy Notice at any time.





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