At STATSports we are committed to protecting the privacy and security of your personal information. We developed this Privacy Policy to describe how we collect, use, share and store your personal information and applies to the information that we may obtain from you through your use of STATSports’ software and services (including Apex Athlete Series, Apex Coach Series, STATSports wearable devices, our mobile apps, our websites, and our APIs), collectively called the “Services”. If you have any questions or need more information about these Services, please contact us at [email protected]

Within this Privacy Notice we will cover the following topics, to go to a specific section, please just click the relevant link below:

About us and this notice

• The information we collect and how we collect it

• How we use the information we have collected

• How information is shared

• Storage and security

• Notice in respect of children

• Retention of your personal data

• How to access or delete your data

ABOUT US AND THIS NOTICE

Company Ltd Name: STATSports Group Ltd.

Company Registered Number: NI641589

Company Registered Office Address: Drumalane Mill, The Quays, Newry, Northern Ireland, BT35 8QS

STATSports Group Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

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 information about you, so that you are aware of how and why we are using such information.

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice or how we handle your personal information, please contact our DPR, Paul McKernan at [email protected]. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

Personal information means any information about an individual from which that person can be identified. When you use our Services, we collect the following types of personal information:

Information you provide to us:

• Order and Account Information

Some information is required to place an order for our products on our website, which includes your first and last name, email address, delivery address and contact telephone number (if relevant). You may choose to checkout as: (i) a guest, in which case this information will only be stored for as long as it takes to fulfil your order; or (ii) set up a STATSports’ Website account, this will make it handier to make future orders, and in this case we will store your information in accordance with this policy.

Once you download our app you will need to create a STATSports’ App account, this does not link to your Website account. Therefore, we will ask you to provide some personal information, including your email address and name (you do not have to use your full name, but you may if you wish). Your STATSports’ device will link exclusively to your App account and no one else’s. This account will be password protected and you will use your email address to access your account. You can add other information to your account profile such as your location, gender, height, weight, date of birth, and the activities you participate in (e.g. football, running, golf etc.). This information will be used for calculating the calories you burn and to provide insights about your activities (durations, distances etc.).

• Apex Coach Series Information

The information shared with the Apex Coach Series: first and last name, DOB, Avatar, all session data you the player has chosen to sync with the squad, Coach can also send push notifications to tell the player to sync if they haven’t already. The Apex Athlete Series receives the following information from the Apex Coach Series: squad name, squad badge/avatar, coach first name & last name, session name, type, time for any squad session that the Coach creates in Coach Series.

• Additional Information

To help improve your experience or enable certain features, you may choose to provide us with further additional information. For example, you may connect with friends on the Service or invite friends who have not yet joined by providing their email addresses or using a contact list on your device. We do not store your contact list and delete it after it is used for adding contacts as friends.

If you contact us or participate in a survey, contest or promotion, we collect the information you submit such as your name, contact information and message.

• Payment Information

If you purchase STATSports’ products on our website, you provide your payment information, including your name, credit, debit card or PayPal account details and billing address. We do not store this information. We do store your shipping address to fulfil your order.

• Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.

Information we receive from your use of our Services:

• STATSports Product Information

STATSports’ devices collect raw data to estimate certain metrics regarding your sporting activity. These metrics include: Total Distance, High Metabolic Load Distance, High Speed Running, Metres per Minute, Step Balance, Accelerations, Decelerations, Dynamic Stress Load, Current Heart Rate, Maximum Heart Rate, Average Heart rate, Time in “Red Zone”, Current Speed, Max Speed, Sprint Distance, Number of Sprints and Average Calories expended. The measurements recorded depend upon the model device you own. Your device will transfer the raw data to your App Account via Bluetooth. You will be able to view your current workout metrics on your App. When your App Account syncs with our servers over Wi Fi, the measurement metrics are backed up to our servers. This back up enables you to track your progress and view your historic work outs.

• Location Information

Our Services include certain features that use location data, including GPS, accelerometers, Wi-Fi, and Bluetooth. These features include heat map generation and distance travelled.

• Usage Information

We collect usage data when you use our Services. This includes information about your interaction with our Services, for example when you view content, install applications, create an account, pair your device or interact with your device via the application. We also collect cookie information and IP address information about the device or computer you use to access our Services. This will only be used for analysis purposes

HOW WE USE THE INFORMATION

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

• Where we need to perform the contract we have entered into with you, for instance to fulfil your order for our products and provide our sports tracking and stats service.

• Where we need to comply with a legal obligation.

• 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.

• When you have consented to us using your information in a particular manner, for example to market other relevant products to you which may be requested as part of the order process or if relevant, transfer your data to the US Soccer database or the Apex Coach Series.

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).

• Where it is needed in the public interest.

We need your personal information primarily to allow us to perform our contract with you to provide our goods and services and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.

• Administering the contract we have entered into with you.

• To provide, improve and develop our Services.

• To communicate with you.

• To promote safety and security

• To prevent fraud.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as fulfilling your order or providing our service).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

HOW INFORMATION IS SHARED

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.  The following third-party service providers process personal information about you for the following purposes: AWS (Amazon Web Services) and Shopify.

Which third-party service providers process my personal information?

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal information with other entities in the group?

We will share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.

STORAGE AND SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

NOTICE IN RESPECT OF CHILDREN

Our Services are not directed to individuals under the age of 13. If it comes to our attention that we have collected the information of a child under the relevant minimum age (13 years old), we will delete the information as soon as we can. Parents who think their child has submitted personal information to us may contact our customer services team by emailing [email protected].

RETENTION OF YOUR PERSONAL DATA

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

If you fail to access your STATSports’ account for a period of 12 months we will securely destroy all your personal information we hold in accordance with applicable laws and regulations, at which point you will no longer be able to access your sports measurements and records.

HOW TO ACCESS OR DELETE YOUR DATA

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing.

• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our customer service team by emailing [email protected].

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

In the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, for instance to provide you with marketing communication via email or SMS or transfer your data to the US Soccer Federation or the Apex Coach Series, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our customer service team by emailing [email protected] or alternatively, please follow click here https://support.statsports.com/hc/en-us/requests/new to withdraw your consent on our website. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.