PRIVACY NOTICE

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PlayerData Limited and PlayerData Inc (“PlayerData”, “we”, “our” and “us”) take the issue of security and data protection seriously. This Privacy Notice (this “Notice”) describes how we process Personal Data (as defined below) we gather through our website at www.playerdata.com, as well as Personal Data we gather through the PlayerData App and related devices (together the “Services”). It also tells you about your rights and choices with respect to your Personal Data, and how you can contact us if you have any queries or concerns. 

If you have been provided with our details or directed to the PlayerData App by a coach, sports team organizer or educational professional (a “Client”), we process your Personal Data on their behalf when they use our services. We may process such Personal Data as a data processor of such Clients, which are the data controllers responsible for the data processing. To understand how your coach, sports team organizer or educational professional processes your Personal Data, please refer to them in the first instance. We are not responsible for their privacy or data security practices, which may differ from those explained in this Notice.

Any questions relating to this Notice and our privacy practices should be sent to dataprotection@playerdata.com.

It is important that you read this Notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your information. This Notice supplements the other notices and is not intended to override them.

HOW WE COLLECT PERSONAL DATA FROM YOU AND WHAT WE COLLECT

In this notice, “Personal Data” means any information relating to an identified or identifiable natural person. We may collect and process Personal Data about you in the ways outlined below. Where applicable, we indicate whether and why you must provide us with your Personal Data, as well as the consequences of failing to do so. If you do not provide Personal Data when requested, you may not be able to benefit from our services if that information is necessary to provide you with them, or if we are legally required to collect it. 

Information provided by you

• When you order from us. If you order a device or accessories from us, we will collect information from you including your email address, name, address and postal/zip code, and credit card information. If you are ordering a device or accessories from us on behalf of a team or other organization, or managing the account of such an organization, we will collect your name and details of the organization you work for.
• When you create an account on the PlayerData App. If you buy an EDGE device from us directly and download the PlayerData App to create an account, we collect Personal Data about you including your name, phone number, email address, date of birth, country, area and gender. If you are the parent of an individual under the age of 13 who has purchased an EDGE device from us, we will receive your email address from your child during the sign-up process in order to collect your consent.
• When you contact us or otherwise interact with us. If you contact us using a contact form, via email, or by other means, you may provide us with Personal Data, such as your name and contact details (including email address), the team or organization you represent, and the content, date and time of our communications.  

Information collected via automated means

• Technical information and log files. This may include your IP address, browser type and clicks we gather when you use our website (for further information see our section on cookies below).
• When you use an EDGE device. If you make use of an EDGE device, we will collect information when you activate it through the PlayerData App and use it during a session. The information we collect includes your geolocation using GPS and/or satellite reference sensors. We use this information to calculate the distance you travel and your speed, as well as other performance metrics relating to your training (e.g., the number of accelerations and decelerations in a session). 
• Cookies and similar technologies. We use cookies and similar technologies to ensure that our Services function properly, to improve our products and services and to assist with marketing campaigns. See the “How We Use Cookies” section below for more details regarding our use of cookies.  

Information we generate through our services

• Information generated through EDGE devices. We process Personal Data collected through EDGE devices to produce aggregate statistics about product usage and player and team performance. These statistics are aggregated to a level at which individuals are no longer identifiable. We use this information for purposes including measuring product performance, and providing insights.  

OUR LEGAL BASIS FOR PROCESSING PERSONAL DATA

If you are located in the European Economic Area, Switzerland or the United Kingdom (“Europe”), we only process your Personal Data where we have a legal basis to do so. The legal bases we rely on include:

• Necessary to perform a contract. We will process your Personal Data where it is necessary to give effect to a contract between you and us, for example when you order an Edge device or accessory from us. 
• Necessary for compliance with a legal obligation to which we are subject. We may process your Personal Data where we are required to do so to comply with our legal obligations, for example to comply with tax and accounting obligations. 
• Necessary for a legitimate interest that we pursue. Where we or a third party have a legitimate interest in processing your Personal Data, we may do so provided that our interest is not overridden by your rights and interests. We may rely on this legal basis to, for example, keep business records, respond to unsolicited communications from you, assert our legal rights and obtain professional advice. 
• Consent. We may process your Personal Data on the basis of consent in some circumstances. For example, we may ask you to consent to our use of certain cookies and similar technologies, or to sign up to direct marketing. You may withdraw your consent at any time by contacting us. 

HOW WE USE PERSONAL DATA

We process the Personal Data listed above for the following purposes:

• Providing our Services. We use Personal Data about you to operate, maintain, personalize, and provide our Services, including the PlayerData App and website and the performance metrics and information made available through them. 
• Delivering products you order. If you order an EDGE device or accessories from us, we will use your Personal Data to fulfill your order. 
• To provide support services. We may use your contact details and other information you provide us to contact you for administrative and support purposes. 
• Analytics, product development and improvement. We use Personal Data that is produced through use of the Services to analyze usage trends, performance metrics, and for other research and development purposes (e.g., to develop and improve new products, services, features and functionalities). We may anonymize or aggregate your Personal Data to carry out these analytics. 
• Billing. We will use your Personal Data, such as details about your purchases and subscription, for billing purposes. 
• Legal. We may use your Personal Data to enforce the terms of any agreement we have in place with you, to defend our legal rights and to comply with our legal obligations and internal policies.    
• Marketing. We may use your Personal Data to develop and provide you with relevant marketing materials.

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We may also use your Personal Data for other purposes for which we provide specific notice at the time the information is collected.    

HOW WE USE COOKIES

We use cookies, pixel tags, SDKs, and other tracking technologies (collectively “Cookies”) on our Services in order to help improve our Services and provide you with a more personalized experience. Cookies are small text files, placed on your hard disk by a web page server.

We use information gathered from Cookies to improve your online experience. We and third party service providers may use the following Cookies: 

• Functional cookies. Some Cookies that we deploy are strictly necessary to make our Services available to you. This includes Cookies that are required to provide login functionality, or to allow you to fill out forms in our checkout process.
• Analytics cookies. We use Cookies that allow us to measure the usage of our Services. We use the information collected to operate, maintain and improve our Services, and to track whether you open emails that we send you. We work with third parties such as Hotjar and Google Analytics for these purposes. 
• Advertising cookies. We may work with third party advertising providers such as Meta to show you ads that we think will interest you. These advertising partners may set and access their own Cookies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. 

If you wish to restrict or block the Cookies that are set by our website, you can do this through your browser settings. If you choose to restrict or block any Cookies, this will result in certain features of the website not being provided, including not being able to log in to the application, and accordingly you will not be able to take full advantage of the website’s features.

DATA SECURITY

Please be aware that the transmission of information via the internet is not always completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the complete security of your data transmitted to us electronically; any transmission is at your own risk. 

SHARING OF YOUR INFORMATION

The information you provide to us may be disclosed to other parties in the following circumstances: 

• Service Providers. We work with third party service providers to operate our Services, including to process orders, receive payments, prepare invoices and analyze data. These service providers also assist us in providing IT-hosting and maintenance, and other services. These third parties may have access to or process your Personal Data as part of providing those services to us. 
• Analytics Partners. We use analytics services such as Google Analytics and Firebase Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout. 
• Advertising Partners. We work with third-party advertising partners to collect and process your information in order to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info) and serve ads through cookie-based technologies. Please visit their opt-out pages to learn about how you may opt out of receiving certain web-based personalized ads from member companies. These opt-outs will apply only to our third-party advertising partners that are members of these organizations. These opt-outs will not apply when our partners serve ads through non-cookie based technologies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
• Legal. We may disclose Personal Data to third parties where required to do so by law, or in the good-faith belief that such an action is necessary to comply with applicable laws, in response to a court order, judicial or other subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We may also disclose your Personal Data where necessary to (i) protect our interests or property; (ii) protect ourselves against fraudulent, abusive or otherwise unlawful activity; (iii) protect the security and integrity of our services. 
• Merger or corporate event. We may disclose Personal Data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a merger, acquisition, debt financing, investment, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy or receivership in which information is transferred to one or more third parties as one of our business assets. 
• Consent. We may also disclose your Personal Data with your permission.

YOUR CHOICES

Location Information. You can prevent your mobile device from sharing precise location information at any time through your device’s operating system settings. However, location is core to our Services and without it, you may not be able to successfully use our Services.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

CHILDREN’S PRIVACY 

The PlayerData App and associated devices may in certain cases be used by players under the age of 13 under the supervision of a coach, sports team organizer, educational professional, parent, or legal guardian. The information below is for parents and guardians to understand our privacy practices with respect to children under the age of 13. We do not process personal information of children under the age of 13 without the consent of the parent or legal guardian, except as permitted under applicable law.

We process the following information from children under 13 when they use our services:

• Registration information, including name, phone number, email address, date of birth and gender.
• Information about the child’s use of the Edge device collected through the PlayerData app, including geolocation using GPS and/or satellite reference sensors. We use this information to calculate the distance they travel and their speed, as well as other performance metrics relating to their training (e.g., the number of accelerations and decelerations in a session). 
• Information about the child’s interactions on our Services, like the browser they use to access the Services, the pages and other content they view, referrer information (the website you visited before coming to our services), and the dates and times of their visits.
• Persistent identifiers, such as IP address, mobile device identifiers, or identifiers associated with cookies.

We use the information we collect from children under 13 for the following purposes:

• To operate, maintain, personalize, and provide our Services, including the PlayerData App and website and the performance metrics and information made available through them;
• To analyze usage trends, performance metrics, and for other research and development purposes (e.g., to develop and improve new products, services, features and functionalities);
• To generate anonymized or aggregated data containing only de-identified, non-personal information that we may use for analytics purposes;
• To communicate with them, provide them with updates and other information relating to our Services, provide information that they request, respond to comments and questions, and otherwise provide customer support; and
• To enforce the terms of our legal agreements, to defend our legal rights, and to comply with our legal obligations and internal policies.

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We disclose the information that we collect from children under 13 in the following circumstances:

• We share information with third-party service providers (e.g., data storage and processing facilities) that assist us in providing the Services. 
• We may share information with an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
• We may share information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of the Services and other users of the Services.

Children under 13 may not make their personal information publicly available.

Requests to Access or Delete a Child’s Information

If you would like to review or delete the personal information we have collected from your child, or refuse to permit further collection or use of your child’s information, you can do so by emailing us at dataprotection@playerdata.co.uk. If you have any questions please contact us at dataprotection@playerdata.co.uk, FAO PlayerData Inc, 4043 Walnut Street, Philadelphia PA 19104, or +1 888-413-6220.

TRANSFERS OUTSIDE OF EUROPE

If you are located in Europe, please be aware that we may transfer your Personal Data outside of Europe if necessary for the purposes detailed in this Notice, including to third parties as described above.

Whenever we transfer your Personal Data out of Europe, we take steps to comply with applicable data protection laws. In particular we will rely on (i) an EU Commission, UK or Swiss government adequacy decision, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. If you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer Personal Data. 

HOW LONG WE WILL KEEP YOUR INFORMATION

We review our data retention periods regularly and will only hold your Personal Data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information).

Where we have a contract with you under which we are required to provide products or services to you, we will retain your Personal Data for the duration of our contract with you and for one year afterwards.

We may retain data in anonymised form for longer periods for research and development purposes.

Retention periods:

• Data required to fulfill our obligations under a contract – for the duration of the contract plus one year afterwards.
• Data required for legitimate business interest – we may retain data in anonymised format for longer periods for research and development purposes. All other forms of personal data will be held for as long as necessary to fulfil the purpose it was collected for.

YOUR RIGHTS

Depending on where you reside, you may have the following legal rights: 

• Access and Portability. You may 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. You may also request a machine-readable copy of your Personal Data, and request information about its processing. 
• Rectification and Deletion. You may ask us to update or correct inaccurate Personal Data that we hold about you. You may also ask to have Personal Data anonymized or deleted.
• Restriction and Objection. You may object to the processing of your Personal Data, or ask that we restrict our processing of it. 
• Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the change to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.  

If you wish to discuss or exercise any of these rights, please contact dataprotection@playerdata.com.

CHANGES TO OUR PRIVACY POLICY

We may update this Notice from time to time to reflect changes in our privacy practices. Any changes we make to this Notice in the future will be posted on this page and, where appropriate, notified to you via the PlayerData App.

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V2.0.0 

Effective Date: 27th November 2024

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