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Technical Hub

Privacy Policy

Last updated: [date] · Provided under Art. 13-14 of EU Reg. 2016/679 (GDPR)

Template notice: complete the bracketed fields and have the text validated by legal counsel before publishing.

1. Data Controller and Processor

For account and billing data, the Data Controller is [Provider legal name], [address], email [privacy@___]. For data uploaded into its own workspace (players, staff, health data, analysis), the Data Controller is the individual registered club; the Provider acts as Data Processor under Art. 28 GDPR. Data Protection Officer (DPO), if appointed: [name and contact].

2. Categories of data processed

(a) user identification and contact data; (b) technical and usage data (logs, IP address, area visited); (c) player and staff data entered by the club; (d) health-related data (special category under Art. 9 GDPR) within the Medical area.

3. Purposes and legal bases

Performance of the contract and provision of the Service (Art. 6.1.b); legal and tax obligations (Art. 6.1.c); legitimate interest in platform security (Art. 6.1.f). Health data is processed by the club as Controller on an appropriate Art. 9.2 GDPR condition (e.g. occupational/sports medicine, consent, or other applicable basis) with enhanced security measures.

4. Special category data (Art. 9) and the Medical area

Access to the Medical area is restricted to authorised staff, protected by a PIN and subject to a declaration of compliance with GDPR obligations (Art. 9), recording date, time, user and IP address for audit purposes. Access is logged.

5. Processors and sub-processors

To deliver the Service we rely on providers acting as processors/sub-processors: infrastructure hosting, transactional email (Resend), IP geolocation (ip-api.com), payments (Stripe). An up-to-date list is available on request.

6. Retention

Data is retained for the duration of the relationship and, after termination, for the period needed to meet legal obligations; the club's data can be exported within [n] days and is then deleted. Security logs are kept for [n] months.

7. Transfers outside the EU

Data is processed preferably within the EU/EEA. Where a provider processes data outside the EEA, the transfer is covered by appropriate safeguards (e.g. Standard Contractual Clauses under Art. 46 GDPR).

8. Security measures

Encryption in transit (HTTPS), role-based access control, per-area PINs, per-club data segregation (multi-tenant), logging of sensitive access.

9. Data subject rights

Data subjects may exercise the rights of access, rectification, erasure, restriction, portability and objection (Art. 15-22 GDPR) by writing to [privacy@___]. For data entered by a club, requests should be addressed to that club as Controller.

10. Complaint to the Supervisory Authority

Data subjects have the right to lodge a complaint with the Italian Data Protection Authority — Garante per la protezione dei dati personali (www.garanteprivacy.it) — or with the authority of their EU country of residence.

11. Changes

This notice may be updated; the current version is always published on this page with its date.