Privacy Policy

1. Introduction

Scout52 ("Scout52", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our football scouting intelligence platform and related services (the "Service").

This policy complies with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations 2003 (PECR).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Data Controller Information

3. Information We Collect

3.1 Personal Information You Provide

• Account Information: Name, email address, password, phone number, job title, organization
• Profile Information: Professional qualifications, scouting credentials, areas of expertise
• Payment Information: Billing address, payment card details (processed securely via our payment provider)
• Communication Data: Messages, emails, and feedback you send to us

3.2 Information Created Through Use of the Service

• Scouting Data: Player evaluations, match reports, performance ratings, tactical assessments
• Usage Data: Features used, time spent on platform, interaction with content
• Collaboration Data: Shared reports, team communications, task assignments

3.3 Automatically Collected Information

• Device Information: IP address, browser type, operating system, device identifiers
• Log Data: Access times, pages viewed, app crashes, system activity
• Location Data: General location based on IP address (not precise GPS location)
• Cookies and Tracking: Session cookies, preference cookies, analytics cookies

3.4 Information About Youth Players (Under 18)

While general Service users must be 18 years or older, we collect and process personal data about youth players aged 7-18 for talent identification and academy recruitment purposes. This processing is conducted under legitimate interests for player development and with explicit parental/guardian consent.

Youth Player Data We Collect:

• Personal details: Name, date of birth, town of birth, postcode, school name and year
• Eligibility documentation: Passport and birth certificate details (country of issue)
• Playing information: Dominant foot, preferred/secondary positions, training frequency, years of experience
• Club affiliations: Current grassroots club, league/division, district and county team participation
• Parent/guardian contact information (name, phone number, email address)
• Emergency contact details
• Basic health screening information (see Section 3.5)
• Performance evaluations and scouting assessments
• Event attendance records

3.5 Health Screening Information

For talent identification events and academy trials, we collect basic health screening information with explicit consent from parents/guardians. This is necessary to ensure participant safety and comply with duty of care obligations.

Health Screening Data We Collect:

We collect YES/NO answers to basic health screening questions, with optional details if answered YES:

• Cardiac screening history (within past 2 years)
• Family cardiac history (relatives under 50)
• Serious injuries (requiring 4+ weeks recovery, hospitalization, or surgery)
• Recurring injuries (muscle strains, growing pains, joint issues)
• Head injury and concussion history
• Medical conditions (asthma, diabetes, allergies)
• Respiratory conditions and exercise-induced symptoms
• Medical limitations on sporting activity
• Current medications and treatment requirements

Legal Basis for Processing Health Data: We process health data under Article 9(2)(a) UK GDPR - explicit consent from the data subject (or parent/guardian for minors).

How We Use Health Data:

• Assessing fitness to participate safely in trials and events
• Providing appropriate support during events
• Responding to medical emergencies
• Complying with safeguarding and duty of care obligations

3.6 Photography and Video Content

During talent identification events, trials, and academy activities, we may capture photographic and video content with your explicit consent for:

• Coaching analysis and player development feedback
• Internal training and assessment purposes
• Academy promotional materials (websites, social media, brochures)
• Club communications and newsletters

You may withdraw consent for future use of photography/video at any time by contacting the relevant academy directly.

4. Legal Basis for Processing

We process your personal data under the following legal bases:

Purpose	Legal Basis
Providing the Service	Performance of contract
Account creation and management	Performance of contract
Payment processing	Performance of contract
Customer support	Performance of contract / Legitimate interests
Talent identification events	Legitimate interests / Consent (for health data)
Health screening	Explicit consent
Marketing communications	Consent / Legitimate interests
Service improvements	Legitimate interests
Legal compliance	Legal obligation
Security and fraud prevention	Legitimate interests

5. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Process transactions and send transaction notifications
• Manage your account and provide customer support
• Organize and manage talent identification events
• Ensure participant safety through health screening
• Facilitate communication between clubs and players/parents
• Send administrative information and service updates
• Respond to your comments, questions, and requests
• Send marketing and promotional communications (with your consent)
• Monitor and analyze trends, usage, and activities
• Detect, prevent, and address technical issues
• Protect against fraudulent, illegal, or harmful actions
• Comply with legal obligations and enforce our Terms of Service
• Develop new features and services

6. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share your information in the following situations:

6.1 With Your Consent

We may share your information with your explicit consent or at your direction.

6.2 Within Football Organizations

For organizational accounts (professional clubs, agencies), information may be shared with authorized users within the organization.

6.3 Service Providers (Data Processors)

We share information with third-party service providers who assist us in operating the Service:

• Cloud hosting provider (Base44 Inc.)
• Payment processors
• Email service providers
• Analytics providers

6.4 Grassroots Football Clubs and Governing Bodies

For talent identification events conducted by professional clubs, we share limited information with grassroots clubs in accordance with Football Association (FA) regulations.

The "7-Day Approach" Notification:

Under FA rules, professional clubs must notify a player's current grassroots club when they attend a talent identification event. This notification includes:

• Player name
• Date and nature of the event
• Contact information for the professional club

This notification is sent to the grassroots club contact email address provided on the registration form, typically 7 days before the event.

6.5 Legal Requirements

We may disclose information if required by law or in response to valid requests by public authorities.

6.6 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

6.7 Protection of Rights

We may disclose information to protect the rights, property, or safety of Scout52, our users, or others.

7. Data Processors and International Transfers

7.1 Base44 Inc. as Data Processor

Scout52 operates on infrastructure provided by Base44 Inc., a technology platform provider based in the United States. Base44 processes personal data on Scout52's behalf under their Data Processing Addendum (incorporated into their Terms of Service).

Base44's obligations include:

• Processing data only on Scout52's instructions
• Maintaining SOC 2 Type II and ISO 27001 certified security measures
• Complying with UK GDPR requirements
• Using EU Standard Contractual Clauses for international transfers
• Notifying Scout52 of data breaches without undue delay
• Assisting with data subject rights requests
• Transparent sub-processor management with 7-day notice of changes

Base44's full Data Processing Agreement and security measures are available at: base44.com/legal/dpa

7.2 International Data Transfers (UK to USA)

Your personal data is transferred to and stored on servers located in the United States. We ensure these transfers comply with UK GDPR requirements through:

• EU Standard Contractual Clauses (as approved by the European Commission)
• Transfer Impact Assessments evaluating risks and additional safeguards
• Technical measures including encryption in transit and at rest
• Organizational measures limiting access to authorized personnel only

By submitting personal data through Scout52, you acknowledge and consent to the transfer of your data to the United States under these safeguards.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit (HTTPS/TLS) and at rest
• SOC 2 Type II and ISO 27001 certified hosting infrastructure
• Access controls and authentication mechanisms
• Regular security monitoring and updates
• Regular backups and disaster recovery procedures
• Employee training on data protection
• Incident response procedures

While we strive to protect your personal information, no security system is impenetrable, and we cannot guarantee absolute security.

10. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or you request earlier deletion.

Retention Periods:

Data Type	Retention Period
Account Information	Duration of account + 1 year
Scouting Reports	As specified by user/organization (default: 3 years)
Talent ID Event Registration	12 months from event date
Health Screening Data	14 days after event (then automatically deleted)
Photography/Video (Promotional)	Until consent withdrawn or 5 years (whichever is sooner)
Photography/Video (Coaching)	Duration of academy involvement + 1 year
7-Day Approach Notifications	2 years from sending date
Payment Records	7 years (legal requirement)
Marketing Preferences	Until consent withdrawn
Support Tickets	2 years after resolution
Log Data	90 days

Note: Talent identification data may be retained longer if a player joins an academy programme, at which point retention follows academy player record requirements.

11. Children's Privacy

General Service Use:

The Scout52 platform (account registration, scouting tools, reporting features) is intended for use by individuals aged 18 and over. We do not knowingly allow children under 18 to create accounts or use the Service independently.

Talent Identification and Youth Player Data:

While Service users must be adults, we collect and process personal data about youth players aged 7-18 for legitimate talent identification and academy recruitment purposes. This processing is conducted:

• With explicit consent from parents or legal guardians
• In accordance with FA safeguarding requirements
• Under enhanced security and access controls
• With appropriate safeguards for health screening information

Parental Rights:

Parents and guardians have full control over their child's data and may exercise all rights under UK GDPR on their child's behalf, including:

• Accessing all data we hold about their child
• Requesting correction of inaccurate information
• Withdrawing consent at any time
• Requesting deletion of their child's data
• Objecting to processing

To exercise these rights, parents/guardians should contact info@scout52.com or the relevant academy directly.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Service.

Types of Cookies We Use:

Essential Cookies

Required for the Service to function properly (e.g., authentication, security).

Performance Cookies

Help us understand how users interact with the Service (with consent).

Functionality Cookies

Remember your preferences and settings.

Marketing Cookies

Used for marketing purposes (only with explicit consent).

You can control cookies through your browser settings. Note that disabling certain cookies may limit Service functionality.

13. Marketing Communications

In compliance with PECR and UK GDPR:

• We will only send marketing emails with your explicit consent or to existing customers about similar services
• All marketing emails include an unsubscribe link
• You can opt-out at any time by emailing info@scout52.com
• We maintain a suppression list to ensure opt-outs are honored

14. Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

15. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify the Information Commissioner's Office within 72 hours
• Notify affected users without undue delay
• Document the breach and actions taken
• Implement measures to prevent future breaches

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy on this page
• Updating the "Last Updated" date
• Sending email notification for material changes
• Obtaining consent where required by law

17. Complaints

If you have concerns about how we handle your personal data, you have the right to lodge a complaint with:

18. Contact Us

For questions about this Privacy Policy or our privacy practices, please contact us:

For exercising your data protection rights: info@scout52.com