Privacy & Cookies Notice
Effective Date: 16 June 2025 | Version 2.0 | LSR Sports Ltd | www.ftballer.com
LSR Sports Ltd (trading as ftballer) is committed to protecting your privacy. This Notice explains how we collect, use, share and protect personal data in connection with our Football Pathway Intelligence services. Please read it carefully.
1. Who We Are
LSR Sports Ltd (trading as ftballer) is the data controller responsible for personal data collected through our Services. We are registered with the Information Commissioner's Office (ICO) in the UK (Registration No: [INSERT]).
Privacy contact: privacy@ftballer.com | www.ftballer.com | [INSERT REGISTERED ADDRESS]
2. Information We Collect
2.1 Parent / Guardian Information
- Name, email address, telephone number, country of residence
- Account login details and account history
- Payment information (processed securely by third-party payment providers — we do not store card details)
2.2 Player Information
- Name, date of birth, age, gender
- Football background, current club, training history and playing position
- Educational information and academic records (where provided)
- Assessment questionnaire responses and any other information voluntarily provided
- Performance data and profiling data derived from video analysis and AI-assisted scoring
2.3 Coach Information
- Name, role and club affiliation
- Assessment feedback provided about a Player
2.4 Uploaded Content
- Video footage (match or training)
- Supporting documents, images and academic records
- Any other pathway documentation you choose to provide
2.5 Technical Information
- IP address, browser type and version, device type and operating system
- Website usage data, session data and analytics
- Cookie data (see Section 10)
2.6 Aggregated and Derived Data
We may generate anonymised and aggregated data from Assessments (for example, trends in pathway outcomes across our user base). This data cannot identify any individual and is used to improve our services, methodology and AI tools.
3. Children's Data — Special Protections
We take the collection of children's data extremely seriously and apply enhanced protections in line with the UK Children's Code (Age Appropriate Design Code).
We collect personal data relating to Players under the age of 18 only with the explicit consent of a parent or legal guardian. Our Services are not directed at children directly — all purchases are made by adults.
We apply the following protections for children's data:
- Data minimisation: we collect only the minimum personal data about a child necessary to deliver the Assessment
- Children's data is not used for marketing purposes
- Children's data is not shared with third parties for their own commercial purposes
- High-privacy default settings apply to any child's data profile
- Children's data is not subject to automated decision-making that produces significant effects without parental consent and human review
How a player's data is used
A Player's data is used for one purpose only: to produce that Player's own Pathway Report. We do not use it for analytics profiling, we do not use it to train AI models, we do not build audience segments from it, and we never market to under-18s. Marketing preferences are not offered on Player accounts at all.
Parents and guardians may request access to, correction of, or deletion of their child's personal data at any time (subject to legal retention obligations) by contacting privacy@ftballer.com.
4. Why We Use Your Information and Our Lawful Basis
| Purpose | Lawful Basis | Details |
|---|---|---|
| Deliver Assessments and generate Reports | Contract performance | Necessary to provide the service purchased |
| Process payments | Contract performance | Handled by third-party payment processors |
| Manage your account | Contract performance | To maintain your access and records |
| AI-assisted scoring and video analysis (including profiling) | Contract performance + Legitimate interests | Supported by human review; right to request human-only review available |
| Improve services, methodology and AI tools (using anonymised data) | Legitimate interests | We use anonymised/aggregated data where possible and will not identify you |
| Platform monitoring (security and compliance) | Legitimate interests | To protect the integrity and security of the Platform |
| Prevent fraud and abuse | Legitimate interests / Legal obligation | To protect Platform and user integrity |
| Comply with legal obligations | Legal obligation | E.g. tax and accounting records |
| Specialist referrals (with your consent) | Consent | Your contact details shared with third parties only with explicit consent |
| Marketing communications | Consent | Only where you have opted in; withdraw at any time via unsubscribe link or by contacting us |
If you do not provide information we require to deliver a Service, we may be unable to complete that Service or element of the Service. We will notify you if this is the case.
5. Automated Decision-Making, AI and Profiling
Some elements of our Assessment process involve automated analysis, including AI-assisted scoring of questionnaire responses and video analysis. These tools produce profiling data about a Player (for example, ratings of technical ability, development potential and pathway suitability).
We do not make fully automated decisions — with no human involvement — that produce significant legal or similarly significant effects on individuals. All AI-assisted outputs are reviewed by our team before any Report is finalised.
Where AI tools are used to process children's data, we apply additional safeguards and parental consent is obtained specifically for this processing.
You have the right to request that a human reviews any automated or AI-assisted output relating to you or your child. To exercise this right contact privacy@ftballer.com.
6. International Data Transfers
As we serve customers internationally and use cloud-based technology providers, your personal data may be transferred to and processed in countries outside the UK or EEA, including the USA.
Where we transfer personal data outside the UK, we ensure appropriate safeguards are in place, which may include:
- UK International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs)
- Transfers to countries with adequacy decisions from the UK ICO
- Other lawful transfer mechanisms as required under applicable law
We conduct Transfer Impact Assessments (TIAs) where required to ensure that personal data transferred internationally receives an essentially equivalent level of protection to that provided under UK GDPR.
For information about the specific safeguards applicable to your data, contact privacy@ftballer.com.
7. Data Retention
| Data Category | Retention Period |
|---|---|
| Active accounts | Duration of the account relationship |
| Accounts after closure | 24 months (to handle post-closure queries and disputes) |
| Assessment Reports | 7 years (for legal and regulatory purposes) |
| Payment records | 7 years (UK tax law requirement) |
| Uploaded videos | 3 years after last Assessment, unless earlier deletion requested |
| Profiling / AI-derived data | Retained as part of the Report for the same period as Assessment Reports (7 years), in anonymised form where possible after closure |
| Marketing consents | Until consent is withdrawn |
| Children's data | Subject to the periods above; parents/guardians may request earlier deletion subject to legal obligations |
When retention periods expire, data is securely deleted or anonymised. We conduct periodic reviews of data we hold to ensure we are not retaining data longer than necessary.
8. Sharing Your Information
We may share personal data with the following categories of recipients:
- Technology and hosting providers (who process data on our behalf under data processing agreements)
- AI and video analysis tool providers (where used in Assessments, under appropriate agreements)
- Payment processors (to handle transactions securely)
- Coach contributors (limited data shared for the purpose of obtaining their Assessment feedback)
- Professional advisers (legal, accounting, insurance) bound by confidentiality obligations
- Law enforcement or regulatory authorities where required by law or to protect our legal rights
We do not sell personal data. We do not share personal data with third parties for their own marketing purposes.
We will only share your contact details with specialist third-party service providers following an Assessment with your explicit prior consent.
8.1 Business Sale or Merger
In the event that ftballer or LSR Sports Ltd is sold, merged with or acquired by another business, personal data we hold may be transferred to the new owner as part of that transaction. We will notify you in advance of any such transfer and, where required, seek your consent. Any new owner will be required to use your personal data in accordance with this Privacy Notice or provide you with a new notice.
9. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data:
| Right | What it means |
|---|---|
| Access | Request a copy of personal data we hold about you (a Subject Access Request) |
| Correction | Have inaccurate or incomplete personal data corrected |
| Deletion (right to be forgotten) | Request deletion of your personal data, subject to legal retention obligations |
| Restriction | Ask us to restrict processing of your personal data in certain circumstances |
| Portability | Receive your personal data in a structured, commonly used, machine-readable format |
| Object | Object to processing based on legitimate interests, including profiling |
| Withdraw consent | Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of prior processing |
| Human review of AI decisions | Request human review of any automated or AI-assisted output that relates to you or your child |
To exercise any of these rights, contact privacy@ftballer.com. There is no fee for making a request in ordinary circumstances, although we reserve the right to charge a reasonable fee or refuse requests that are manifestly unfounded or excessive.
We may need to verify your identity before responding to a data request. We will respond within one calendar month of receipt of a valid request. Where a request is complex or we have received a number of requests, we may extend this period by a further two months — we will notify you within the first month if this is necessary and explain the reason for the extension.
If you are unhappy with our response, you have the right to complain to your local data protection authority:
- UK: Information Commissioner's Office (ICO) — ico.org.uk | 0303 123 1113
- Ireland: Data Protection Commission (DPC) — dataprotection.ie
- USA: Federal Trade Commission (FTC) — ftc.gov
- Australia: Office of the Australian Information Commissioner — oaic.gov.au
- UAE: UAE Data Office (under UAE PDPL) — uaedataoffice.ae
10. Cookies
10.1 What are cookies?
Cookies are small text files placed on your device when you visit our website. They help us operate the site, remember your preferences and understand how visitors use our services.
10.2 Categories of cookies we use
| Category | Consent Required? | Purpose |
|---|---|---|
| Strictly Necessary | No | Essential for the website to function: login sessions, security, checkout and form submission. These cannot be disabled. |
| Analytics | Yes | Measuring website traffic and usage patterns to understand how users interact with our Platform and improve our service. |
| Marketing / Advertising | Yes | Tracking visitor behaviour to show relevant advertising across third-party platforms (only if/when used). |
Non-essential cookies (analytics, marketing) are switched off by default and will only be placed on your device following your consent, obtained via our cookie consent banner when you first visit our website. Rejecting them is as easy as accepting them. Your choice is stored in a first-party cookie on your device for 12 months and is not linked to your account. You can withdraw or update your consent at any time via the "Cookie settings" link in the footer of our website.
10.3 Managing cookies in your browser
You can also control and delete cookies through your browser settings. Disabling strictly necessary cookies may impair website functionality. For guidance on managing cookies, visit www.aboutcookies.org or www.allaboutcookies.org.
11. Security
We implement appropriate technical and organisational security measures to protect personal data against unauthorised access, misuse, alteration, disclosure or loss. These include encryption of data in transit and at rest, access controls, staff training and regular security reviews.
We have formal procedures for handling suspected personal data breaches. Where a breach is likely to result in a risk to your rights and freedoms, we will notify you as soon as reasonably practicable. Where required, we will notify the ICO within 72 hours of becoming aware of a breach.
No internet-based system can be guaranteed completely secure. If you believe your account has been compromised, contact privacy@ftballer.com immediately.
12. Changes to This Notice
We may update this Privacy & Cookies Notice from time to time. We will notify you of material changes by email or via a prominent notice on our website before changes take effect. The updated Notice will show the revised effective date.
13. Contact Us
For any privacy-related queries, to exercise your rights, or to make a complaint:
LSR Sports Ltd trading as ftballer
Email: privacy@ftballer.com | Website: www.ftballer.com
Registered Office: [INSERT ADDRESS] | ICO Registration No: [INSERT]