Information About Your Personal Data

This Privacy Policy relates to data about you, your devices, and your interaction with our Products.

"Personal Data" is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your name, email address, phone number, precise location, certain cookie and network identifiers.

Footsapp Limited collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the services provided and our business; for advertising and marketing; co-ordination with third-party suppliers and partners; and to provide you with innovative sport coaching and management services, as further described in this Privacy Policy.

How We Collect and Use Personal Data

We collect your Personal Data in a number of ways and for various purposes, including:

1. When you register for an account or interact with our services.

We collect Personal Data when you use or interact with our services, including when you register with us. During registration, Footsapp, asks for your email address. The more Personal Data that you provide (and the more accurate it is), the better we are able to customise your experience. This registration Personal Data includes (but is not necessary limited to): name, country, phone number, username and password, email address, date of birth, payment information, a photo, position and Location Data.

"Location Data" means either approximate location or, with your consent, precise location. We use this data to enable your activity within our services, and to provide the services generally, including to develop, enhance, and improve our services and your experience. We may also use this data for internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.

2. When you give us permission to collect Location Data.

We may collect precise Location Data as part of the functionality of our services, such as to provide location of sporting venue, location map for navigation, weather information, and to conduct analytics to improve the services. We may collect precise Location Data in several ways, such as through your wireless carrier, based on WiFi access point location, via Bluetooth beacons, through a connected device, or directly from the device on which you use the services. If you are accessing the services through one of our mobile applications, the way we collect precise Location Data will differ depending on your mobile device's operating system. In all events, we do not collect precise Location Data, unless you have consented to its collection. If you decline to allow Location Data collection in the app, we will not collect your precise Location Data unless you manually enter it in. Location data is collected but not stored and you will always be prompted before your location is used.

3. When you communicate with us or sign up for promotional materials.

We collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages - including email address, mobile number etc.

We may use your Personal Data and other information to communicate with you about the Footsapp Limited products or services you have purchased or used; provide you with promotional messages and personalised advertising; to notify you of other products; to notify you of other promotions ("Promotions"); to notify you of services we think may be of interest to you; and, for other marketing purposes. You can manage your Footsapp communication preferences by logging into your account or contacting info@footsapp.com.

We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests. We may also use your Personal Data to address your requests, enquiries, and complaints.

4. When you engage with our online communities or advertising.

We may collect your Personal Data when you engage with our online communities. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums affiliated with Footsapp Limited. Please note that our community forums are public, so we recommend that you exercise care in deciding what information and content you wish to disclose.

5. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies.

We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalisation, performance/analytics, and advertising.

6. When we link you to fellow coaches and players across platforms.

Some of our services consist of social sharing and communication with others. We use your Personal Data to enable sharing of content.

7. When we provide you geographically relevant services, offers, or advertising.

Where you have provided consent to process your precise Location Data, we may use such data to provide you with services, offers or advertising that are relevant to your location.

8. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes, we do this under the legal framework of the GDPR.

We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of Third-Parties, to enforce our Terms of Service, this Privacy Policy, or agreements with third parties and/or for crime-prevention purposes.

9. When you access Third-Party Products and services.

We may allow you to register for Third-Party products and services or otherwise interact with another website, mobile application, or Internet location (collectively "Third Party Sites") through our services, using your Personal Data as part of that registration.

10. When you give us permission to collect device data.

We may provide features that rely on the use of additional information on your mobile device or require access to certain services on your mobile device that will enhance your Footsapp experience but are not required to use the service, such as contacts, photos, camera, or media files. Before we access this information or these features on your mobile device, we will ask for your permission for such access. You have the right to withdraw your consent at any time by going to your device-based settings or emailing info@footsapp.com.

How We Disclose Personal Data

We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy and in the following ways:

1. To other Users/Footsapp Limited Registered Users.

With other users in the context of specific services that are social in nature. In these cases, we disclose social data, team data and certain personal data by default because the service being provided is one of social interaction. Additionally, any information you post or disclose in our community forums (for example, Facebook) is public.

2. For Advertising and Marketing.

With your consent, we may share your precise Location Data with Third-Parties for on and off platform personalisation and curated marketing and advertising purposes.

3. For Certain Analytics and Improvement.

With Google Analytics for analytics and improvement of the services.

4. For Legal Compliance, Law Enforcement and Public Safety Purposes.

With law enforcement, government or regulatory bodies, lawful authorities, or other authorised Third-Parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of Third-Parties, to enforce our Terms of Service, this Privacy Policy, or agreements with Third-Parties, or for crime-prevention purposes.

Legal Basis for Processing

This section addresses the legal basis for processing your data. Some processing is addressed in multiple sections because more than one legal basis may apply depending on the circumstances or service.

For the purposes of applicable data protection laws, Footsapp Limited is the controller of the Personal Data you provide to us ("Data Controller"). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy, please contact the Data Processing Manager on info@footsapp.com

We collect and process your Personal Data for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including, but not limited to:

1. For Legal Compliance, Law Enforcement, and Public Safety Purposes.

To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.

2. For Legitimate Interests

To operate our business and provide the services, other than in performing our contractual obligations to you for Footsapp Limited's "legitimate interests" for the purposes of applicable law - except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.

For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:

Communication: To communicate with you regarding the services, address your requests, enquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other Footsapp Limited's emails or communications. These types of communications do not require consent.
Respond to Your Requests: To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.
Compliance with Law and Public Safety: To assist in the investigation of suspected illegal or wrongful activity, including in-store tracking and sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of Third-Parties.
Improvement and Development: To develop, provide, enhance, and improve our services and your experience, including to enable you to use the full range of our services (e.g. processing of non-sensitive Personal Data; when we collect, use, or otherwise leverage cookies, device IDs, Location Data, data from the environment, and other tracking technologies; when you connect with us through social media; when we collect data from Third-Parties or publicly-available sources; when we aggregate and centralise data; and when we share Personal Data with companies or ventures that are owned or controlled by Footsapp Limited and with our service providers and vendors). For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, and administrative purposes.
Enforcing Terms and Notice: To enforce our Terms of Service, give effect to or this Privacy Policy, or comply with agreements with Third-Parties.

Surveys: To send you surveys in connection with our services.

Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our services (ii) registering or creating an account with us. We may request your consent for a number of activities including:

1. Footsapp Ltd Marketing and Communication.

By agreeing to our Terms of Service you consent to contact you by email about other offers, products, Promotions, or services that we think may be of interest to you and for other marketing purposes. You can manage your Footsapp communication preferences by logging into your account or contacting info@footsapp.com.

2. Collecting and Sharing Location Data.

We will request your consent prior to collecting and using your precise Location Data. Our services may require this data to provide certain services (such as weather information relating to a game). If you choose not to provide this information, certain services or features like this may be unavailable or not function properly.

3. Automated Processing.

We may use some automated processing to provide our services and to make recommendations in the context of specific services. This processing is strictly necessary for providing certain services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, meaning that consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, we will first seek your consent.

4. To Enable Social Sharing.

Some of our services consist of social sharing and communication with others. If you sign up for these services, we may ask for your consent to use your information to enable sharing as described in the service.

Interest-Based Advertising

Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. Our advertising practices also include the creation and use of "audience segments." You have the option to and to opt-out of receiving interest-based communications. Additional information on Audience Segments and our choices for interest- based advertising is found below.

1. Audience Segments.

We disclose various types of information for purposes of interest-based advertising, including for Third-Party, interest-based advertising. This processing includes the use of Personal Data to create audience segments. The audience segments are based on sport interest, membership, app usage data, website usage data, interaction with Footsapp Limited emails and similar types of information.

2. Interest-Based Advertising Opt Outs, Choices, and Control.

For all of the interest-based advertising described above, you have the choice to not have your data used to target and serve you interest-based advertising (including Third-Party advertising) regardless of where such ads might be served. You can manage your Footsapp communication preferences by logging into your account or contacting info@footsapp.com.

Managing Preferences and Withdrawing Consent

You may at any time withdraw your consent (in relation to the data (and for where consent is the basis for processing) with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Product, collection and use items of Personal Data may be required for the services to work.

We provide you several ways to manage your preferences:

1. Cookie Use and Controls.

Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. You have choices regarding cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject all cookies, certain functionality on our websites will not work.

One way to think about cookies is based on their function. The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data for cookie-based, interest-based advertising.

[ IN ] Required Cookies: These strictly necessary cookies are used for core functionality, and recognise when you are signed in, remember things such as shopping carts and text entered, are necessary for security, and enforce your privacy preferences. Without these cookies, some functionality on our websites will fail. You can block these cookies in your browser preferences.
[ IN / OUT ] Functional Cookies: These cookies help to improve the sites by allowing us to understand how the site is used and how the site performs. These cookies include analytics and measurement.
[ IN / OUT ] Advertising Cookies: These cookies help us and other parties personalise ads that are shown to you on our sites and services, as well as on other sites. If enabled, these cookies will allow Third-Parties engaged in interest-based advertising on our site to recognise your browser software on other sites too.

2. IP Address Use.

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include "public" IP addresses, such as the IP address for a home router that is visible to the Internet, as well as "local" IP addresses, which are IP addresses assigned to computers and mobile devices "behind" a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency. You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for "Advertising Cookies," and "Performance/Analytics," above.

3. Web Pixels or Beacons Use.

Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party's cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.

4. HTML5 Local Storage.

HTML5 Local Storage in the browser is different from cookies, but can be used for the same purpose (to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 Local Storage is used by using the cookie controls outlined above.

5. Flash Cookie Use.

Flash cookies are "local shared objects" used by Flash player to store data, similar to cookies. If you have Flash installed, and wish to delete, block, or manage Flash cookies, please use the Flash settings panel made available by Adobe.

6. Manage Your Location services.

You can also turn off the transmission of precise Location Data by turning off those services using your mobile device's built-in settings. Turning off location may cause some of our services not to work.

7. Change Consent Settings for Communication Preferences.

Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any email we send.

If you use more than one Product, then unsubscribing from the emails relating to that Product will not stop you from receiving emails from other Products. Please note that if you unsubscribe from "all emails" this means that you will still receive email communications from us if they are necessary to provide the Footsapp Limited service or to confirm or validate a transaction, recover accounts, etc.

Mobile Push Notifications: As an organiser/captain, you can manage the type of push notifications you receive from Footsapp by modifying the settings within Footsapp.

You may also set your mobile device settings to not allow push notifications from all Footsapp Limited products.

Data Retention

For these purposes, an "active account" means interaction with our Products (websites or applications), emails or ongoing payments for Footsapp Limited services. We will retain your Personal Data for as long as you maintain an active account, and then on a limited basis, as is as necessary to comply with our legal obligations, resolve disputes, enforce our rights/agreements and basic necessary administrative purposes.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy Footsapp will delete your Personal Data from our systems. This will be no later than after an account is inactive for a period of7 years after the last activity.

Where permissible and to the extent it is not needed to comply with our legal obligations, resolve disputes, enforce our rights/agreements and basic necessary administrative purposes, we will also delete your Personal Data upon your request. If you would like to make a deletion request, or have any questions about our data retention practices, please contact info@footsapp.com.

Security

We implement appropriate technical and organisational safeguards to protect against unauthorised or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

Links to Other Websites: Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our services may provide a link or otherwise provide access to Third-Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites, and any data you provide to Third-Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third-Party Sites with that you interact with.

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