Privacy Policy

Background

Framesports Ltd. (Company Number 15515721) ("we," "us," or "our") understands that your privacy is important and that you care about how your personal data is used and shared. We value and respect the privacy of everyone who uses our website(s), software, and/or services (collectively "Services") and will only collect and use personal data in accordance with our obligations under data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (collectively, "Data Protection Legislation").

You will be required to read and accept this Privacy Policy when signing up for an account or when using the Services in any way. If you do not accept and agree with this Privacy Policy, you must stop using our Services immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have these meanings:

  • "Account" means an account required to access and/or use our Services.
  • "Cookie" means a small text file placed on your computer or device when you visit certain parts of our Services and/or when you use certain features of our Services. Details of the Cookies used by our Services are set out in section 13 below.
  • "Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended).
  • "Customer" means a customer of ours who has entered into a contract for the provision of our Services.
  • "Personal data" is defined by the UK GDPR and Data Protection Act 2018 as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

2. Information About Us

  1. We are Framesports Ltd, a company registered in England & Wales under company number 15515721.
  2. Our registered office is: 2 Ferry Lane, Bath, BA2 4HS, United Kingdom
  3. We are regulated by the UK's supervisory authority, the Information Commissioner's Office (ICO).

3. What Does This Policy Cover?

This Privacy Policy applies to our use of any and all data we collect in relation to your use of our Services. It does not extend to any websites or services that are linked to or accessible from our Services if they are not owned or operated by us.

4. Your Rights

As a data subject, you have the following rights under Data Protection Legislation, which this Policy and our use of personal data are designed to uphold:

  1. The right to be informed about our collection and use of personal data.
  2. The right of access to the personal data we hold about you (see section 11).
  3. The right to rectification if any personal data we hold about you is inaccurate or incomplete.
  4. The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you if there is no legal basis for us to continue processing it.
  5. The right to restrict (i.e. prevent) the processing of your personal data in certain circumstances.
  6. The right to data portability (i.e. obtaining a copy of your personal data to re-use with another service or organisation).
  7. The right to object to us using your personal data for particular purposes.
  8. Rights related to automated decision making and profiling where applicable.

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 below and we will do our best to resolve the issue. If we are unable to help, you also have the right to lodge a complaint with the ICO (www.ico.org.uk).

5. What Data Do We Collect?

Depending on how you use the Services, we may collect some or all of the following personal and non-personal data:

  1. Name
  2. Date of birth
  3. Gender
  4. Business/company name
  5. Job title
  6. Profession
  7. Contact information such as email addresses and telephone numbers
  8. Demographic information such as postal code, preferences, and interests
  9. Financial information such as credit or debit card numbers
  10. IP address
  11. Web browser type and version
  12. Operating system
  13. A list of URLs starting with a referring site, your activity on our website, and the site you exit to
  14. Profile picture or other images
  15. Sports played (if relevant to the Services)
  16. Team history or affiliation (if relevant)
  17. Weight and height (if relevant)
  18. Equipment or clothing brand usage (if relevant)
  19. Personal data pertaining to children (see section 12 if children's data is involved)
  20. Sporting performance level or other performance data

We collect only the personal data we need to provide and improve the Services.

6. How Do We Use Your Data?

  1. All personal data is processed and stored securely. We retain it only for as long as necessary for the reasons it was collected, or as required by law.
  2. Our lawful bases for using your personal data include the following:
    • Contractual Necessity – to perform a contract with you (e.g., to supply the Services).
    • Consent – when you have expressly given us consent.
    • Legitimate Interests – where processing is in our legitimate business interest, balanced against your fundamental rights and freedoms.
  3. Specifically, we may use your data for:
    • Providing and managing your Account.
    • Providing and managing your access to the Services.
    • Personalising and tailoring your experience of our Services.
    • Administering our products and services to you.
    • Personalising and tailoring our products and services for you.
    • Communicating with you and responding to your enquiries.
    • Supplying you with emails or other marketing you have consented to receive (you may unsubscribe at any time).
    • Conducting market research or gathering analytics to improve our Services.
    • Anonymising/pseudonymising personal data for internal business insights.
  4. Marketing: With your permission (or if otherwise permitted by law), we may also use your data for marketing purposes, which may include contacting you via email, telephone, text message, or post with information, news, and offers. We do not send unsolicited marketing or spam. You can unsubscribe from marketing messages at any time.
  5. Data Retention: We only keep personal data for as long as we need it for the above purposes, or as required by law. Examples include:
    • Account holder data is stored while your subscription remains active and for up to two years after termination, unless otherwise requested by you or required by law.
    • Financial records are retained for seven years per statutory obligations.
    • Web analytics data may be retained for a shorter period (e.g., 14 months).

7. How and Where Do We Store Your Data?

  1. We will store your data in compliance with Data Protection Legislation and take appropriate technical and organisational measures to secure it.
  2. We may store some of your personal data within the UK or the European Economic Area (EEA). Transfers to the EEA are lawful.
  3. Where we transfer personal data to a "third country" outside the UK/EEA, we will ensure appropriate safeguards are in place (e.g. adequacy regulations, standard contractual clauses) so that your data is treated securely and in accordance with UK data protection law.
  4. Security measures we use include but are not limited to:
    • SSL encryption (HTTPS)
    • Strong password policies and role-based access
    • Two-factor authentication
    • Regular backups and software updates
    • Written agreements with third-party processors
    • Data minimisation, anonymisation, and pseudonymisation where possible
  5. Please note that data transmission over the internet may not always be completely secure. You should take appropriate measures when transmitting personal data online.

8. Do We Share Your Data?

  1. We may sometimes contract with third parties to supply certain products and services on our behalf (e.g., payment processing, analytics, marketing). In some cases, these third parties may require access to personal data. We ensure they only have access to what is necessary and that they are contractually obligated to protect it.
  2. We may share anonymised, aggregate statistics (e.g., usage data) with third parties such as investors or partners. This data cannot identify you or any individual.
  3. We may disclose your personal data where required to do so by law, a court order, or a government authority.

9. What Happens If Our Business Changes Hands?

  1. We may expand or reduce our business and this could involve the sale or transfer of control of some or all of our business. In this case, any personal data you have provided may be transferred to the new owner under the same terms of this Privacy Policy.
  2. You will not necessarily be contacted in advance of such a transfer. However, after a transfer, the new owner will only be permitted to use your personal data for the same purposes you originally provided it for.

10. How Can You Control Your Data?

  1. When submitting personal data, you may be given options to restrict our use of that data, including for marketing purposes.
  2. You can unsubscribe from marketing emails at any time by using the "unsubscribe" link or by contacting us directly.
  3. You can also sign up to the UK preference services (TPS, CTPS, MPS) to limit unsolicited marketing.

11. How Can You Access Your Data?

You have the right to ask for a copy of any personal data we hold about you (commonly known as a "subject access request"). If you would like to request a copy, please contact lachlan@framesports.ai

12. How We Manage Personal Data Pertaining to Children

  1. Our Services are not specifically designed for individuals under the age of 18; however, where children's data is processed, we do so with appropriate safeguards.
  2. Children below the age of digital consent in their country (13 in the UK unless otherwise specified) are not permitted to create an account unless a parent, guardian, or relevant authority (e.g., school) provides verifiable consent.
  3. We only collect as little information as necessary about children to deliver our Services (e.g., name, email for account creation). Any additional data volunteered to us is processed with the explicit consent of the relevant adult/organisation or as otherwise permitted by law.
  4. We do not market to children or engage in automated decision-making about children that may adversely affect them.
  5. We enable strict access controls to ensure only our internal analysts and your allow-list of users can see the footage.

13. Our Use of Cookies

  1. Our website uses "Cookies" to distinguish you from other users, provide essential functionality, and enhance your experience.
  2. Some Cookies are strictly necessary for the functioning of our website (e.g., login and session cookies) and are placed on your device when you access our site.
  3. Other Cookies, including analytics and advertising Cookies, require your prior consent. We use tools such as Google Analytics or similar. These help us understand how you use our site, but they do not identify you personally.
  4. You can refuse or manage Cookies at any time using our Cookie consent tools and/or your browser settings. Please note that disabling certain Cookies may prevent the full functionality of our Services.

14. Contacting Us

If you have questions about our website or this Privacy Policy, or you wish to exercise any of your legal rights regarding your data, please contact Lachlan McGrigor (lachlan@framesports.ai)

Please clearly state your request (e.g., if it is a subject access request or a complaint).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes or we change our business in a way that affects personal data). Any changes will be posted to our website, and you will be deemed to have accepted these changes on your first use of our Services following the alterations. We recommend checking this page regularly to stay up to date.