Framesports

1. Who we are and how to contact us

We are Framesports Ltd, a company registered in England & Wales under company number 15515721. Our registered office is 18 Bigwood Court, Bigwood Road, London, NW11 6SS, United Kingdom.
We are registered with the UK's data protection regulator, the Information Commissioner's Office (ICO), under registration ZB774949.
For any question about this notice or your personal data, or to exercise your rights, contact support@framesports.ai.
We have considered whether we are required to appoint a statutory Data Protection Officer and concluded that we are not; responsibility for data protection is held by our founders, reachable at the address above.

2. When we are a controller and when we are a processor

We are the controller (we decide the purposes and means) for: creating and running accounts; billing and payments; securing, operating and improving the Services; our own analytics; and our marketing.
We are a processor (we act only on a customer's instructions) for match footage and the player analysis derived from it that a club, school or governing body uploads or connects. That processing is governed by our Data Processing Addendum with that organisation, which is the controller of it.
Where we act as processor, a player or other individual who asks us to exercise their rights over that footage or analysis will be directed to the relevant club, school or governing body, which controls that data. We will help that organisation respond.

3. Who this notice covers

This notice covers: account users (coaches, administrators, staff); players, including those added by a club and those who sign up directly; and visitors to our websites.
It does not cover the people who carry out analysis work for us as contractors.

4. What we collect, why, our lawful basis, and how long we keep it

The table below covers the personal data we process as a controller. (Footage and player analysis handled as a processor are described in our Data Processing Addendum and section 5.)

What we do	Data involved	Lawful basis (UK GDPR)	How long we keep it
Create and run your account; provide the Services	Name, email, phone, password (stored hashed), profile photo, role, account settings	Performance of a contract (Art 6(1)(b))	For the life of the account and up to 2 years after it closes
Billing, payments and credits	Billing contact, billing address, invoices, payment-method tokens (card details held by our payment provider, not us)	Contract (Art 6(1)(b)); legal obligation for tax/accounting (Art 6(1)(c))	Financial records 7 years
Securing, operating and improving the Services; product analytics and session recordings	Usage events, device/browser data, IP address, logs, session recordings	Legitimate interests (Art 6(1)(f)): running a secure, reliable, improving service	Analytics retained on a rolling basis; logs as needed for security
Player profiles, development plans, statistics and CVs (where we act as controller, e.g. for players using the product directly)	Name, jersey number, position, date of birth, performance and event data, images	Contract (Art 6(1)(b)); legitimate interests in player development	For the life of the related account unless deleted earlier
Match footage hosting and delivery	Video and audio of identifiable people	Processor on the club's instruction (the club is controller); see the DPA	For the life of the account unless deleted earlier
Service messages and customer support	Name, email, phone, message content	Contract; legitimate interests in supporting users	While the account is active and a reasonable period after
Marketing and advertising audiences	Name, email, phone, engagement data	Consent, or legitimate interests for business-to-business marketing; you can opt out at any time	Until you unsubscribe or object, then suppressed
Safeguarding and protecting people, where needed	Relevant account/player data	Recognised legitimate interests for safeguarding (Art 6(1)(ea))	As long as needed for the safeguarding purpose

We collect only the personal data we need for these purposes. If we ever want to use your data for a genuinely new purpose, we will tell you first.

5. Where we get player data from

Much of the player information we hold is provided to us by the club, school or governing body you are associated with, rather than by you directly. This includes name, jersey number, playing position, date of birth and age category, contact details where provided, footage and images, performance and event data, and development-plan or CV content.
If you are a player and want to know what we hold or have it corrected or removed, you can contact us at support@framesports.ai, and we will work with your club (which controls that data) to help.

6. Children and young people

Our customers include schools and youth programmes, so we hold footage, profiles and dates of birth of players under 18. We treat children's data with particular care, in line with the ICO's Children's Code.
Children are added to the platform by their club, school or governing body, which is responsible for obtaining any parent or guardian consent required. A child below the age of digital consent (13 in the UK) is not permitted to create an account on their own.
We do not market to children, and we do not make automated decisions about children that produce legal or similarly significant effects. Any profiling of children (for example development plans) is carried out on the instruction of, and in the interests of, the child's club, and is not used for advertising.
We provide a short, plain-language privacy summary for young players, and we ask clubs to share age-appropriate information with the players they add. A parent or guardian can contact us at support@framesports.ai about their child's data.

7. Who we share data with

We use trusted third parties to run the Services. They fall into these categories: cloud hosting and storage; video processing and delivery; payment processing; messaging and email; product analytics and session recordings; customer support; AI-based detection of players and the ball in footage; customer-relationship management; and advertising platforms. Each is bound by data protection terms and may only use the data to provide its service to us.
For advertising, we share limited contact details (such as email and phone, in hashed form) with Meta to build and target advertising audiences. You can object to this (section 10).
Where a game is shared across accounts through a competition or a governing-body relationship, the relevant organisations can access that game's footage and data, as the customers control.
A fuller list of the third parties we use is available to customers on request. We may also disclose data where required by law, a court order or a public authority.
We do not sell personal data.

8. How we use AI and improve the product

We use third-party artificial intelligence to detect players and the ball within footage (for example to help attach events to the right player). This identifies positions and jersey numbers; it is not facial recognition.
We use footage and usage data, including de-identified data, to develop, train and improve our analytics and AI models, except where a customer's agreement with us provides otherwise. Where we handle a club's footage as a processor, we do this only as that club's agreement with us permits, and some customers' agreements restrict or exclude it.
We do not use the personal data of children, or special category data, to train our models other than in de-identified form.
Where we rely on our legitimate interests to use data we control for this purpose, you can object at any time by contacting support@framesports.ai.
We may also create anonymised, aggregated insights (such as performance benchmarks) that do not identify any individual, and use them to improve the Services. We do not sell personal data.

9. Profiling and automated decisions

We produce analysis such as statistics, development plans and percentile rankings. This is decision-support for human coaches and staff; we do not make decisions about individuals that are based solely on automated processing and produce legal or similarly significant effects.

10. Marketing and advertising

With your consent, or where the law allows for business-to-business marketing, we may contact you about our products, news and offers. You can unsubscribe at any time using the link in our messages or by contacting support@framesports.ai.
We use advertising tools and audiences (see sections 7 and 11). You can object to advertising-related processing at any time, and manage tracking through our cookie settings.

11. Cookies and similar technologies

We use cookies and similar technologies that are strictly necessary to run the site and keep you signed in. These do not require consent.
We also use, with your consent where required, tools that help us understand and improve the product and run advertising. These include PostHog (product analytics and session recordings, which can be linked to a signed-in user), Google Tag Manager, advertising tags from Google and Meta, and Intercom (support messaging).
You can accept or reject non-essential cookies, and change your choice at any time, through our cookie settings and your browser controls. Rejecting some cookies may limit certain features.

12. Storing and transferring data internationally

We store data in the United Kingdom and the European Economic Area, and some of our providers are located in other countries, including the United States.
Where we transfer personal data outside the UK, we rely on a valid safeguard: UK adequacy regulations (including the UK–US Data Bridge for certified providers); or the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, supported by a transfer risk assessment. You can ask us for more detail on the safeguard used.

13. How we keep data secure

We use appropriate technical and organisational measures, including encryption in transit, hashed passwords, two-factor authentication, role-based access, logging, regular backups, and contractual confidentiality and security obligations on our staff, contractors and providers.
No transmission over the internet is ever completely secure; please take care when sending information online.

14. Your rights and how to exercise them

You have the right to be informed; to access your data; to rectification; to erasure; to restrict processing; to data portability; to object to processing; and rights relating to automated decision-making. Where we rely on consent, you can withdraw it at any time, without affecting processing already carried out.
To exercise any right, contact support@framesports.ai. We will respond within one month (we may extend this for complex requests, and will tell you if so). Where a request concerns footage or analysis we hold as a processor, we will direct it to the relevant club and help them respond.

15. Complaints

If you are unhappy with how we have handled your personal data, please contact us first at support@framesports.ai. We will acknowledge your complaint within 30 days and respond as soon as we can.
You also have the right to complain to the Information Commissioner's Office (www.ico.org.uk).

16. Business changes and updates to this notice

If our business is sold or reorganised, personal data may be transferred to the new owner, who may only use it for the purposes set out in this notice.
We may update this notice from time to time. We will post changes here and update the version and date at the top. For significant changes we will take reasonable steps to tell you.

SMS / text messaging consent

Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. Any other mentions in this policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. If you wish to be removed from receiving future communications, you can opt out by texting STOP.

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