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ESC Rest of the World Voting

The following information is intended to provide You, as a Voter in the Eurovision Song Contest (ESC) via the paid online voting platform available at (the “Voting Platform”) with an overview of the personal data we collect and process about you when you vote online in the ESC 2023 from a country outside the ESC participating countries (the “ESC Rest of the World Voting”)and about your rights under data protection law.

As joint data controllers, We
The European Broadcasting Union, L’Ancienne-Route 17A, 1218 Le Grand-Saconnex, Genève, Switzerland (the “EBU”)

digame GmbH, Schanzenstrasse 38 D-51063 Cologne Germany (the “ESC Voting operator”)

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 than the ones set below.

The EBU and the ESC Voting operator have executed specific and separate joint controllers’ arrangement pursuant to Article 26 of GDPR for the purposes of the ESC Rest of the World Voting, the key content of which is available on demand at the premises of either the EBU or the ESC Voting operator.

What categories of personal data are being processed?

We will process only the personal data which the ESC Voting operator receives when You cast your vote online via the Voting Platform as part of the ESC Rest of the World Voting.
When doing so, the ESC Voting operator will – depending on your country of origin - gather or have access to the following categories of data from you if applicable

  • IP-address

  • IP geolocation

  • User Agent

  • Voting metadata

    • Which songs you voted for

    • Timestamp

  • Payment data

    • Payment card details

      • Card number

      • Card expiry date

      • Card type

      • Card issuer bank

      • 3D Secure authentication details

    • Payment amount

    • Unique ID of payment method

    • Fingerprint (identifies returning customers, potentially links payments of different payment cards)

    • Country of issuing Bank

    • Date and time of transaction

    • The payment method and origin that has been chosen

    • Email address

    • Name.

Please note that the ESC Voting operator does not store your banking details or payment card details which are solely processed by the appointed payment providers as sole controller. However, payment providers may provide the ESC Voting operator access to your payment data (as listed above) to enable us to detect fraudulent or non-eligible votes or verify any refund request.

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

We collect your personal data on the basis of the performance of a contract (Art. 6 Para. 1 (b) GDPR) and our legitimate interest (Art. 6 Para. 1 (f) GDPR) for the Purposes of

  • calculating and generating valid and official results of the Eurovision Song Contest on the basis of the votes cast by the audience (including yours) to determine valid results and ranking of the songs entered in the Eurovision Song Contest and the winner thereof;

  • assessing votes’ eligibility and detecting fraudulent or non-eligible votes and/or verifying any refund request;

  • generating aggregated statistics on the voting in the ESC;

  • publishing aggregated and anonymized results.

Who will have access to your personal data?

We will share your personal data with the following service providers acting as processors on our behalf with whom the ESC Voting operator has entered into a data processing agreement (DPA) in accordance with Article 28 GDPR and which will process your data for different purposes such as hosting, content delivery etc.

  • External Hosting provider acting as processor

The Voting Platform is hosted by an external service provider (host). Personal data collected on the Voting Platform are stored on the servers of the host.
Our provider will only process your data to the extent necessary to fulfil the performance of its obligations and to follow our instructions with respect to such data.


  • Content Delivery Network providers acting as processors

The information transfer between your browser and the Voting Platform is technically routed via the Content Delivery Network. This enables us to boost the global availability and performance capabilities of the Voting Platform.


  • Payment services providers acting as separate controllers

We integrate payment services of third-party companies on the Voting Platform. When You proceed with payment for Your votes, your payment data (as listed above) are processed by the payment service providers as sole data controllers for the purpose of payment processing. For these transactions, you acknowledge that your personal data will be processed in accordance with those service providers own respective legal ground and privacy notice for which we have no responsibility. You acknowledge that payment providers will provide the ESC Voting operator access to your payment data (as listed above) to enable us to detect fraudulent or non-eligible votes or verify any refund request.


  • Inside the ESC Voting operator

Your personal data is accessible to various staff members acting under the ESC Voting operator’s authority and in accordance with our instructions. Whilst the EBU is joint controller with the ESC Voting operator with regard to the ESC Rest of the World Voting, the ESC Voting operator will not transfer your personal data to it, and the EBU will receive from the ESC Voting operator only anonymized 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?

Please note that whenever your personal data is transferred to processors or third parties located in countries outside the European Economic Area which are not considered by the European Commission to guarantee an adequate level of protection for personal data, we will ensure that appropriate measures are implemented according to the applicable national and European legislation relating to data protection. We will in particular use Standard Contractual Clauses approved by the European Commission to ensure adequate protection. For further information, including a copy of the documents used to protect your personal data, please contact the ESC Voting operator at

How long will my personal data be kept by us?

The ESC Voting operator 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 including:

  • fulfilment of commercial- and tax-law related storage obligations;

  • compliance with 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.

Use of cookies

The Voting Platform uses cookies to function. Cookies are small text files placed in the browser of your computer (or other digital device used) by websites that you visit. They are employed by us to detect and protect against fraudulent payments. These cookies do not require consent, and cannot be refused if you wish to visit the Voting Platform, as they are strictly necessary for proper functioning of our services.

Please refer to the table below for all relevant information about these cookies.


Cookies Requiring Consent
In addition, the Voting Platform uses other cookies that are not qualified as necessary and require your consent. Please refer to the table below for all relevant information on these cookies used by the Voting Platform.

Sharing on social networks

We may offer content sharing functionality to third party platforms. When redirecting to these platforms, cookies may be set on your device when visiting their websites or apps. Please refer to the respective privacy policies of these platforms to learn more.

What are your rights?

You have the right to review 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

If you believe that the processing of your personal data constitutes a violation of the data protection law(s), you have the right to file 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 ESC Voting operator’s Data Protection Officer at

Effective date and Changes

This Privacy Notice is effective from 20 April 2023.

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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