Privacy Policy

1. Introduction and Overview

Welcome to Scout Me Pro, a trading name of Cyco GNMC Holdings Ltd (Company Number: HE458993), a company registered in Cyprus with its registered address at 33 Theklas Lysioti, Dorothea Building, 1st Floor, Office 12, 3030 Limassol, Cyprus ("Company," "we," "us," or "our"). We are committed to protecting your privacy and ensuring the safety of all users, particularly children and young athletes under the age of 16.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website at scoutmepro.com, and related services (collectively, the "Platform"). This policy applies globally and is designed to comply with:

• The General Data Protection Regulation (GDPR) - European Union
• The Children's Online Privacy Protection Act (COPPA) - United States
• The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) - California, USA
• The UK Data Protection Act 2018 and UK GDPR - United Kingdom
• The Personal Information Protection and Electronic Documents Act (PIPEDA) - Canada
• The Australian Privacy Act 1988 - Australia
• The Protection of Personal Information Act (POPIA) - South Africa
• Lei Geral de Proteção de Dados (LGPD) - Brazil
• Other applicable international, federal, state, and local privacy laws

IMPORTANT NOTICE FOR PARENTS AND GUARDIANS: Scout Me Pro is designed for young athletes, including those under 16 years of age. We require verifiable parental consent before collecting any personal information from children under 16. Please read this policy carefully and contact us at legal@scoutmepro.com if you have any questions.

2. Data Controller Information

For the purposes of applicable data protection laws, the data controller is:

For EU residents, we have appointed a Data Protection Officer (DPO) who can be contacted at dpo@scoutmepro.com for any privacy-related inquiries.

3. Information We Collect

3.1 Information You Provide Directly

We collect information you voluntarily provide when using our Platform:

Account Registration Information:

• Full name
• Email address
• Date of birth (to verify age and apply appropriate protections)
• Username and password
• Phone number (optional)
• Profile photograph
• Country and region of residence

Athletic Profile Information:

• Sport(s) played
• Position(s)
• Athletic achievements and statistics
• Team affiliations
• School or academy information
• Height, weight, and other physical attributes (voluntarily provided)
• Athletic biography

Content You Create:

• Videos and photographs uploaded to the Platform
• Comments, messages, and communications
• Profile descriptions and posts
• Feedback and survey responses

Parental/Guardian Information (for users under 16):

• Parent/guardian full name
• Parent/guardian email address
• Parent/guardian phone number
• Consent verification information
• Payment information for consent verification (processed securely, not stored)

3.2 Information Collected Automatically

When you access our Platform, we automatically collect certain information:

Device and Technical Information:

• Device type, model, and operating system
• Unique device identifiers
• Browser type and version
• IP address
• Mobile network information
• Time zone and language settings

Usage Information:

• Pages and features accessed
• Videos viewed and watch duration
• Search queries
• Interactions with content (likes, comments, shares)
• Time spent on the Platform
• Referral sources
• Click patterns and navigation paths

Location Information:

• Approximate location derived from IP address
• Country, region, and city (for content recommendations)
• Precise location only if explicitly enabled and consented to

3.3 Information from Third Parties

• Social media platforms (if you choose to link accounts)
• Authentication providers
• Payment processors (transaction confirmation only)
• Analytics providers
• Content moderation services

4. Special Provisions for Children Under 16 (COPPA and GDPR-K Compliance)

4.1 Verifiable Parental Consent

Before collecting any personal information from a child under 16, we require verifiable parental consent through one of the following methods:

• Credit Card Verification: A card verification check (no charge) to verify parental identity
• Government ID Verification: Secure verification of parent/guardian identity
• Signed Consent Form: Digital or physical signed consent document
• Video Call Verification: Live verification with our trust and safety team

4.2 Limited Data Collection for Children

For users under 16, we limit data collection to only what is reasonably necessary for participation in the Platform:

• We do not collect more personal information than necessary
• We do not condition participation on disclosure of unnecessary information
• We do not share children's personal information with third parties except as necessary for Platform operation
• We do not use children's data for behavioral advertising
• We do not enable children to make their personal contact information publicly available

4.3 Parental Rights

Parents and guardians have the right to:

• Review the personal information collected from their child
• Request deletion of their child's personal information
• Refuse further collection or use of their child's information
• Withdraw consent at any time
• Access their child's account and activity
• Set restrictions on their child's account

To exercise these rights, contact us at legal@scoutmepro.com or through the parental dashboard in the application.

4.4 Content Moderation for Child Safety

All content involving users under 16 is subject to enhanced review:

• Automated AI screening of all uploaded content
• Human review of flagged content within 24 hours
• Immediate removal of inappropriate content
• Age-appropriate content recommendations
• Restricted messaging capabilities
• No direct contact with unverified adults

5. Legal Basis for Processing (GDPR)

Under the GDPR and similar regulations, we process your personal data based on the following legal grounds:

5.1 Consent (Article 6(1)(a) GDPR)

• Processing of children's data with parental consent
• Marketing communications
• Optional data collection (e.g., precise location)
• Cookies and similar technologies

5.2 Contract Performance (Article 6(1)(b) GDPR)

• Account creation and management
• Providing Platform features and services
• Processing transactions
• Customer support

5.3 Legal Obligation (Article 6(1)(c) GDPR)

• Tax and accounting requirements
• Responding to legal requests
• Child safety reporting obligations
• Regulatory compliance

5.4 Legitimate Interests (Article 6(1)(f) GDPR)

• Platform security and fraud prevention
• Service improvement and analytics
• Enforcing terms of service
• Protecting users from harmful content

Note: We do not rely on legitimate interests for processing children's data. All children's data processing is based on parental consent.

6. How We Use Your Information

6.1 Platform Operations

• Create and manage your account
• Enable you to upload and share athletic content
• Connect athletes with scouts and opportunities
• Provide personalized content recommendations
• Facilitate communication between users
• Process transactions and subscriptions

6.2 Safety and Security

• Verify user identities and ages
• Moderate content for appropriateness
• Detect and prevent fraud, abuse, and policy violations
• Protect the safety of all users, especially minors
• Respond to reports and complaints
• Enforce our Terms and Conditions

6.3 Communications

• Send service-related notifications
• Respond to inquiries and support requests
• Send marketing communications (with consent)
• Notify you of policy changes
• Send parental notifications and reports

6.4 Improvement and Analytics

• Analyze usage patterns to improve services
• Conduct research and development
• Test new features
• Generate aggregated, anonymized insights

6.5 Legal and Compliance

• Comply with applicable laws and regulations
• Respond to legal process and government requests
• Protect our legal rights
• Fulfill reporting obligations

7. How We Share Your Information

7.1 With Your Consent

We share information when you direct us to, such as when you choose to make your profile public or share content with specific users.

7.2 Service Providers

We engage trusted third parties to perform services on our behalf, including:

• Cloud Hosting: Secure data storage and processing
• Payment Processing: Secure transaction handling
• Content Delivery: Video streaming and optimization
• Content Moderation: AI-powered safety screening
• Email Services: Transactional and marketing emails
• Analytics: Aggregated usage analysis
• Customer Support: Help desk and ticketing

All service providers are contractually bound to protect your data and use it only for specified purposes.

7.3 Other Users

Depending on your privacy settings, certain information may be visible to other users:

• Public profile information
• Content you choose to share publicly
• Interactions such as comments and likes

7.4 Legal Requirements

We may disclose information when required by law or when we believe disclosure is necessary to:

• Comply with legal obligations
• Respond to valid legal processes
• Protect the safety of any person
• Prevent fraud or illegal activity
• Protect our rights and property

7.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will provide notice and, where required, obtain consent before any such transfer.

8. International Data Transfers

Scout Me Pro operates globally, and your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place:

8.1 Transfer Mechanisms

• Standard Contractual Clauses (SCCs): EU-approved contractual safeguards
• Adequacy Decisions: Transfers to countries with adequate protection
• Binding Corporate Rules: For intra-group transfers
• Your Consent: For specific transfers with your explicit agreement

8.2 Data Storage Locations

Our primary data storage is in the European Union. Some data may be processed in:

• European Union (primary)
• United States (with appropriate safeguards)
• Other jurisdictions as necessary for service provision

9. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this policy:

9.1 Retention Periods

9.2 Deletion Requests

Upon receiving a valid deletion request, we will delete or anonymize your data within 30 days, except where retention is required by law or for legitimate purposes (such as fraud prevention).

10. Your Privacy Rights

Depending on your location, you have various rights regarding your personal information:

10.1 Universal Rights

• Access: Request a copy of your personal information
• Correction: Request correction of inaccurate data
• Deletion: Request deletion of your data
• Portability: Receive your data in a portable format
• Withdraw Consent: Withdraw previously given consent

10.2 GDPR Rights (EU/UK Residents)

• Right to Erasure: Request deletion of your data
• Right to Restriction: Limit how we process your data
• Right to Object: Object to certain processing activities
• Right to Lodge a Complaint: File a complaint with a supervisory authority
• Right Not to be Subject to Automated Decision-Making: Request human review of automated decisions

10.3 CCPA/CPRA Rights (California Residents)

• Right to Know: Know what personal information is collected
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of the sale/sharing of personal information
• Right to Non-Discrimination: Not be discriminated against for exercising rights
• Right to Correct: Correct inaccurate personal information
• Right to Limit: Limit use of sensitive personal information

10.4 How to Exercise Your Rights

To exercise any of your privacy rights, you may:

• Email us at legal@scoutmepro.com
• Use the privacy settings in your account
• Submit a request through our Privacy Request Form at scoutmepro.com/privacy-request

We will respond to your request within 30 days (or as required by applicable law). We may need to verify your identity before processing certain requests.

11. Cookies and Tracking Technologies

11.1 Types of Cookies We Use

Essential Cookies

Required for basic Platform functionality. Cannot be disabled.

Functional Cookies

Remember your preferences and settings.

Analytics Cookies

Help us understand how users interact with the Platform.

Marketing Cookies

Used to deliver relevant advertisements (adults only, with consent).

11.2 Managing Cookies

You can manage cookie preferences through:

• Our cookie consent banner
• Your browser settings
• Account privacy settings

11.3 Do Not Track

We honor Do Not Track (DNT) signals. When DNT is enabled, we limit tracking to essential functionality only.

12. Data Security

We implement comprehensive security measures to protect your personal information:

12.1 Technical Safeguards

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Secure authentication mechanisms
• Regular security assessments and penetration testing
• Web Application Firewall (WAF)
• DDoS protection
• Intrusion detection systems

12.2 Organizational Safeguards

• Employee background checks
• Privacy and security training
• Access controls and least privilege principles
• Incident response procedures
• Regular audits and compliance reviews

12.3 Data Breach Notification

In the event of a data breach affecting your personal information, we will:

• Notify affected users within 72 hours of discovery
• Report to relevant supervisory authorities as required
• Provide information about the breach and remedial steps
• Take immediate action to mitigate harm

13. Third-Party Links and Services

Our Platform may contain links to third-party websites or services. We are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party services you access.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes:

• We will update the "Last Updated" date
• We will notify you via email or in-app notification for material changes
• For significant changes affecting children, we will obtain new parental consent
• We will provide at least 30 days' notice before changes take effect

Continued use of the Platform after changes constitutes acceptance of the updated policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

16. Supervisory Authorities

If you believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with a supervisory authority:

• EU: Your local Data Protection Authority
• UK: Information Commissioner's Office (ICO)
• USA: Federal Trade Commission (FTC)
• Cyprus: Commissioner for Personal Data Protection