Cookies & Privacy Policies

Privacy Policy

Introduction

MoveUp Media SAS (“we”, “our”, or “us”) operates ToffeeWeb, a digital media platform focused on Everton FC news, commentary, and fan engagement. Our company is headquartered in France but primarily serves supporters of Everton Football Club in the United Kingdom.

This Privacy Policy explains how we collect, use, and protect personal data from users (“you”, “your”) who interact with our services.

Data Controller Registration:

Important Notice: Registration is entirely optional. You can access and read all content on ToffeeWeb without creating an account. Registration is only required if you wish to comment on articles.

By using our website or registering to comment on our content, you accept the terms of this policy, including the use of cookies. If you do not agree, please discontinue your use of our services.

2. What Data We Collect

We collect two types of information:

2.1 Information You Provide to Us

Comments and Live Chat on ToffeeWeb are provided by Arena, an independent third-party provider. If you create an Arena account, your details are collected and processed by Arena under its own terms and privacy policy. When you visit a page where Arena is enabled, technical data (such as your IP address and device information) may be transmitted to Arena so the service can load.

Former ToffeeWeb accounts: accounts created on our previous commenting system, and the data associated with them, will be permanently deleted on 31 October 2026.

Important:

We do not store payment information
You can delete your account at any time, and your personal data will be erased accordingly

2.2 Information We Collect Automatically

We collect data from all visitors, including:

IP address
Browser type and version
Device type and screen resolution
Operating system
Referral source (which website you came from)
Pages visited and time spent on site
Geographic location (country/region level only)

This information is gathered through cookies, analytics tools (e.g., Google Analytics), and standard server logs.

Newsletter and email communications

If you choose to subscribe, we collect your email address (and name, if you provide it) to send you ToffeeWeb communications in the categories you select at sign-up: newsletter and content, offers and promotions, and events. Offers from selected partners are only sent if you give separate consent.

• Legal basis: your consent. We confirm each subscription by double opt-in (a confirmation email), and you can withdraw at any time via the unsubscribe link in every message or by contacting contact@moveup.media.

• Engagement tracking: our emails measure opens and clicks so we can improve our content; you can turn this off in your preferences or by reading messages in plain text.

• Email service provider: we send the newsletter through a third-party email provider acting as our processor under a data processing agreement; this may involve international transfers protected by Standard Contractual Clauses.

• Retention: we keep your subscription data until you unsubscribe or withdraw consent.

We never sell your data. Unsubscribed contacts are suppressed and not contacted again without new consent.

3. How We Use Your Data

3.1 Legal Basis for Processing

We process your personal data based on the following legal grounds:

Data Type	Purpose	Legal Basis
Former ToffeeWeb account data (name, email)	Account management until deletion of former accounts	Performance of contract
Website analytics data	Monitor performance and improve platform	Legitimate interest (website improvement)
Security logs	Detect fraud or security breaches	Legitimate interest (security protection)
Marketing cookies	Deliver relevant advertising	Your consent
Essential cookies	Website functionality	Legitimate interest (service provision)
Newsletter subscription (email, name)	Send the ToffeeWeb communications you signed up for and measure engagement	Your consent
Service communications	Account notices, changes to our services	Legitimate interest

3.2 How We Use Your Information

We use your information to:

Enable commenting functionality for registered members
Personalize the website based on your preferences
Monitor performance and improve our platform
Detect fraud or security breaches
Fulfill legal obligations or respond to regulatory authorities
Deliver relevant advertising through our affiliate partnerships

We do not sell or rent your data to any third party.

We share data with an email service provider (processor) to deliver our newsletter, under a data processing agreement and appropriate safeguards for any international transfer.

4. Cookies

4.1 What Are Cookies?

Cookies are small text files stored on your browser to enhance your experience on our website. They allow us to remember your preferences and login status, and to analyze how users interact with our content.

4.2 Types of Cookies We Use

Type	Purpose	Legal Basis	Duration
Strictly Necessary	Enables essential functions such as commenting and login	Legitimate interest	Session/1 year
Functional	Remembers preferences like font size, dark mode, display settings	Legitimate interest	1 year
Performance/Analytics	Analyzes website usage to improve layout, speed, and user flow	Legitimate interest	24 months
Marketing/Affiliates	Tracks affiliate links and delivers relevant ads (e.g., Google AdSense)	Your consent	13 months

Arena.im – Cookies and Third-Party Services

ToffeeWeb uses Arena.im to provide our website’s comments and Live Chat features. Arena uses session cookies to keep you logged in when you comment or use Live Chat.

These technologies may collect information about your device, browser and interactions with Arena’s services. Arena.im and certain third-party service providers may also use cookies or similar technologies in connection with these features.

For more information about how Arena.im uses cookies, the types of information collected and how to manage cookie settings, please read Arena’s Cookie Policy and Privacy Policy.

You can also manage cookies through your browser settings. Please note that blocking certain cookies may affect the operation of Arena’s comments or Live Chat features.

4.3 Managing Your Cookie Preferences

Essential Cookies: Cannot be disabled as they are necessary for website functionality.

Arena: (comments and Live Chat provider): session cookies used to keep you logged in to your Arena account when commenting or using Live Chat. Duration: session.

Non-Essential Cookies: You can accept, refuse or change your cookie preferences at any time via [Cookie settings].

Third-Party Advertising: We work with third-party ad networks (e.g., Google AdSense, Stanza) that may use cookies to show you relevant ads. You can opt out via:

Google: https://www.google.com/privacy_ads.html
Industry opt-out: http://www.youronlinechoices.eu/

Withdrawing Consent: You can withdraw consent for non-essential cookies at any time without affecting the lawfulness of processing based on consent before withdrawal.

For more information, please visit our Cookie Policy section

5. Affiliate Marketing Disclosure

ToffeeWeb participates in affiliate marketing programs. This means we may earn a commission when you click affiliate links and complete a qualifying action (such as signing up or placing a bet) on third-party websites.

How This Works:

Affiliate links may use cookies to track referrals
We have no control over, nor access to, the data collected by affiliate partners
Each affiliate partner has their own privacy policy
Commissions help us keep ToffeeWeb free for all users

Age Restriction: Any content related to betting or gambling is strictly for users 18 years and older.

6. Data Security

We implement industry-standard security measures (technical and organizational) to protect your data from unauthorized access, misuse, loss, or disclosure.

Our Security Measures Include:

Encryption of sensitive data (passwords, personal information)
Regular security assessments and updates
Access controls and staff training
Secure hosting with reputable providers

Your Responsibility: No online system is 100% secure. We encourage you to use strong, unique passwords and update them regularly.

7. International Data Transfers

7.1 EU-UK Data Flows

As a French company processing UK residents’ data, transfers between our French headquarters and UK-focused operations are governed by the EU-UK adequacy arrangement.

7.2 Other International Transfers

Your data may be processed outside the EU/UK by:

Cloud service providers (e.g., hosting, analytics)
Third-party services (e.g., Google Analytics, advertising networks)

When this occurs, we ensure appropriate safeguards including:

Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions where available
Certification schemes where applicable

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

8.1 Core Rights

Access: Request a copy of your personal data
Rectification: Correct inaccurate or incomplete information
Erasure: Request deletion of your data (“right to be forgotten”)
Restriction: Limit how we process your data
Portability: Receive your data in a structured, machine-readable format
Objection: Object to processing based on legitimate interests
Withdraw Consent: For processing based on consent (e.g., marketing cookies)

8.2 How to Exercise Your Rights

8.3 Right to Complain

You have the right to lodge a complaint with the UK Information Commissioner’s Office (ico.org.uk) or with the French data protection authority, the CNIL (cnil.fr).

9. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

Data Type	Retention Period	Reason
Former ToffeeWeb Accounts	31st October 2026	Migration to Arena, then permanent deletion
Google Analytics data	24 months	Website improvement analysis
Security logs	12 months	Fraud prevention and security
Cookie preferences	12 months	Respect your choices
Newsletter subscription data	Until you unsubscribe or withdraw consent	Deliver the communications you signed up for

Account Deletion: You can delete your account at any time through your profile settings or by contacting us. Upon deletion, your personal data will be permanently erased within 30 days.

10. Children’s Privacy

10.1 Content

ToffeeWeb is intended for users aged 18 and over. Content relating to gambling and betting is strictly intended for users over 18 and must not be accessed by minors under any circumstances.

11. Changes to This Policy

We may update this Privacy & Cookie Policy from time to time to reflect:

Changes in our services
Updates to applicable laws
Improvements to our privacy practices

Notification: Changes will be posted on this page with an updated effective date. Please check back regularly to stay informed about how we protect your privacy.