Privacy Policy

SPORTING MINDS LIMITED APP PRIVACY POLICY 

You and the Player 

We wish to make you, as the parent or guardian (you) of a child who is a member of the football team or club (the “Player”) who wishes to use the XLinSport football mobile application software (the App), aware of our privacy policy. We are making you aware of this privacy policy so that you and the Player (who is under 18) understand how we obtain and use personal data regarding the use of the App. 

Where in these terms we refer to “you” that includes the parent or guardian and the Player. 

Consent to installation of the App 

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in this policy and it is important that you read that information.  

Before installation of this App, please indicate your consent to our processing of your and the Player’s personal data (including your name, contact details and financial information and the Player’s name and contact details and device information) as described in this policy.  

YES I consent to the installation of the App for the purposes of football coaching. 

NO I do not consent to the installation of the App.  

How you can withdraw consent 

Once you provide consent by selecting “YES”, you may change your mind and withdraw consent at any time by contacting us [CONTACT DETAILS] but that will not affect the lawfulness of any processing carried out before you withdraw your consent.  

 Sporting Minds Limited (trading as XLinSport) (Co. No. 11457874), having its registered office address at 64 Baker Street, London, W1U 7GB (we) are committed to protecting your personal data and respecting your privacy. 

Introduction  

This policy (together with our end-user licence agreement as set out at [WEB ADDRESS OF EULA] (EULA) and any additional terms of use incorporated by reference into the EULA, together our Terms of Use) applies to your Player’s use of: 

• The XLinSport football mobile application software (App) hosted on [WEB ADDRESS] (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device). 
• Any of the services accessible through the App (Services) that are available on the App Site. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App does collect personal data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. 

This policy is provided in a layered format so you can click through to the specific areas set out below. [Alternatively, you can download a pdf version of the policy here: [LINK].]  

[IMPORTANT INFORMATION AND WHO WE ARE] 

[THE DATA WE COLLECT ABOUT YOU] 

[HOW IS YOUR PERSONAL DATA COLLECTED?] 

[HOW WE USE YOUR PERSONAL DATA] 

[DISCLOSURES OF YOUR PERSONAL DATA] 

[INTERNATIONAL TRANSFERS] 

[DATA SECURITY] 

[DATA RETENTION] 

[YOUR LEGAL RIGHTS] 

[GLOSSARY] 

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA] 

Important information and who we are 

Sporting Minds Limited is the controller and is responsible for your personal data (collectively referred to as Company, we, us or our in this policy). 

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.  

Contact details 

Our full details are: 

• Full name of legal entity: Sporting Minds Limited 
• Name or title of data privacy manager: Jason Edmonds 
• Email address: jasonedmonds@xlinsport.com 
• Postal address: 64 Baker Street, London, W1U 7GB 
• Telephone number:07930320863 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues, but we would prefer to raise the issue with us first.  

Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review.  

This version was last updated on the date set out at its end. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by SMS or when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.  

Third party links 

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services. 

The data we collect about you 

We may collect, use, store and transfer different kinds of personal data about you as follows: 

• Identity Data. 
• Contact Data. 
• Financial Data. 
• Transaction Data. 
• Device Data. 
• Content Data. 
• Profile Data. 
• Usage Data. 
• Marketing and Communications Data. 
• Location Data  

We explain these categories of data here [LINK TO DESCRIPTION OF CATEGORIES OF PERSONAL DATA BELOW]. 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

How is your personal data collected? 

We will collect and process the following data about you: 

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.  
• Information we collect about you and your device. Each time you visit one of Our Sites or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy [LINK] for further details. 
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: 
• Device Data from the following parties: 

analytics providers such as Google based outside the UK and 

search information providers such as Google based outside the UK. 

• Contact, Financial and Transaction Data from Coaches, providers of technical, payment and delivery services such as Stripe Payments Limited based in the UK; 
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK 
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us. 

Cookies 

We use cookies and/or other tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy [LINK]. 

How we use your personal data 

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:  

• Where you have consented before the processing. 
• Where we need to perform a contract we are about to enter or have entered with you. 
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. 
• Where we need to comply with a legal or regulatory obligation.  

Click here [LINK TO GLOSSARY: LAWFUL BASIS] to find out more about the types of lawful basis that we will rely on to process your personal data.  

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.  

Purposes for which we will use your personal data 

Disclosures of your personal data 

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]: 

• Internal Third Parties as set out in the [Glossary]. 
• External Third Parties as set out in the [Glossary]. 
• Specific third parties [listed in the table [Purposes for which we will use your personal data] above . 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

International transfers 

We do not transfer your personal data outside the UK. 

Data security 

By using our Website and/or our Service you consent to our third party service partners having access to your personal data, including those outside the European Economic Area (EEA). We always ensure that your data is only transferred in full accordance with UK data protection laws and/or applicable EU data protection law. In particular, this means that your data will only be transferred to a country that provides an adequate level of protection (for example, because the European Commission has determined that a country provides an adequate level of protection) or the recipient is bound by standard contractual clause according to conditions provided by the European Commission (“EU Model Clauses”). You are responsible for checking the privacy policy of any third party websites we link to. It may also be processed by staff operating outside the EEA who work for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your payment details and the storage of your personal data. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. You agree to keep confidential and not to disclose to any other individual or individuals for all time the user name and password related to your XLinSport account. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. 

The security of your data is of the utmost importance to us which is why we use the safest and most reliable platform available to us. 

We use Amazon Web Services (AWS) servers to store your data at various locations within Europe. 

Amazon Web Services provide state of the art physical and environmental security, so you can rest assured that your data is in the safest place possible. More information about AWS security can be found here. 

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology (have the same level of security used by online banking systems). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 

Data retention 

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. 

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

In the event that you do not use the App for a period of [three months] then we will treat the account as expired and your personal data may be deleted. 

Your legal rights 

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.  

Please click on the links below to find out more about these rights:  

• [Request access to your personal data.] 
• [Request correction of your personal data.] 
• [Request erasure of your personal data.]  
• [Object to processing of your personal data.] 
• [Request restriction of processing your personal data.]  
• [Request transfer or your personal data.]  
• [Right to withdraw consent.]  

You also have the right to ask us not to continue to process your personal data for marketing purposes.  

You can exercise any of these rights at any time by contacting us at our above address or by email to support@xlinsport.com. 

Glossary 

Lawful basis 

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 

Third parties 

External third parties 

Coaches, being individuals or clubs providing football training 

Service providers acting as processors based in United Kingdom and the Republic of Ireland who provide IT and system administration services. 

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. 

HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances. 

Your legal rights 

You have the right to: 

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

1. if you want us to establish the data’s accuracy; 

1. where our use of the data is unlawful but you do not want us to erase it; 

1. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or 

1. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

Description of categories of personal data 

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender. 

• Contact Data: billing address, delivery address, email address and telephone numbers. 
• Financial Data: bank account and payment card details. 
• Transaction Data: includes [details about payments to and from you and details of in-App purchases.  
• Device Data: includes the type of mobile device you use, a unique device identifier [(for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, [the type of mobile browser you use, time zone setting. 
• Content Data: includes information stored on your Device, including[login information, photos, videos or other digital content, check-ins. 
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences and feedback. 
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data [and other communication data],] whether this is required for our own billing purposes or otherwise [and the resources that you access. 
• Marketing and Communications Data: includes [your preferences in receiving marketing from us and our third parties and your communication preferences.