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 footballers under the age of 16.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform, which includes:

• The Scout Me Pro mobile application for iOS (Apple App Store) and Android (Google Play Store)
• The Scout Me Pro website at scoutmepro.com
• All related services, APIs, and features accessed through any of the above (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
• Apple App Store Guidelines and App Store Review Guidelines
• Google Play Developer Program Policies and Data Safety requirements
• Other applicable international, federal, state, and local privacy laws

IMPORTANT NOTICE FOR PARENTS AND GUARDIANS: Scout Me Pro is for footballers aged 13 and over. Players aged 13 to 15 can create an account, which means we collect their sign-up details (see Section 3.1), but they cannot upload videos and their profile stays private until a parent or guardian gives consent (see Section 5). We do not accept accounts for children under 13. Please read this policy carefully and contact us at support@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
• An email address or a mobile number (you choose which one you sign in with)
• Date of birth (to check your age and apply the right protections)
• Username and password
• Profile photograph
• Cover photograph (optional)
• Country and city of residence

Athletic Profile Information (Athletes):

• Preferred football position (e.g. goalkeeper, centre-back, striker)
• Preferred foot (left, right, or both)
• Team or club name (optional)
• Achievements (up to 10 entries, optional)
• Biography

Scout Profile Information (Scouts):

• Organisation name and type (e.g. professional club, college, agency, independent)
• Organisation website (optional)
• LinkedIn profile URL (optional)
• Years of scouting experience
• Number of players signed or recruited
• Specialisations
• Preferred age range for scouting
• Whether accepting inquiries

Content You Create:

• Videos and photographs uploaded to the Platform
• Video metadata (descriptions, hashtags, text overlays, music selections, visual effects)
• Comments and messages, including voice messages and photos sent in chats
• Profile descriptions and posts
• Support requests and their attachments, feedback and survey responses
• For scouts: private notes, ratings, lists and pipeline stages you keep about players

Parental/Guardian Information (for users under 16):

• Parent/guardian email address and/or phone number
• Consent record (how and when consent was given, and the one-time codes or links used, which expire)

3.2 Information Collected Automatically

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

Device and Technical Information:

• Device type, brand, model, and operating system version
• App version and build number
• Browser type and version (web)
• IP address
• Mobile network information
• Time zone, language, and locale settings
• Screen resolution

Usage Information:

• Which videos and profiles you view (video owners see view counts, and Pro members and scouts can see who viewed their profile)
• Interactions with content (likes, comments, shares, saves)
• Subscription tier and status
• If you agree to analytics: the screens you open and actions such as sign-up, upload and subscription steps, recorded with PostHog (EU). Automatic click tracking and session recording are off. Analytics are always off for players under 16, who cannot turn them on
• Whether you opened our emails and which links you clicked (with a shortened, hashed IP address and device type)

Location Information:

• Approximate country, region and city, worked out from your network connection. We use it to show video owners where their views come from and to send reminders at a sensible local time
• We do not collect precise GPS location data from the mobile application

Crash and Diagnostic Data:

• Application crash reports and error logs
• Stack traces and diagnostic information
• Neither the app nor our website sends screenshots or records replays of your screen
• Performance metrics and response times
• HTTP request failure data

Push Notification Data:

• Push notification token (a unique identifier assigned to your device for delivering notifications)
• A device ID for this app (Apple's identifier for vendor on iOS, the Android ID on Android)
• Device platform (iOS or Android)
• Notification delivery and interaction data

3.3 Information from Third-Party Authentication

If you choose to sign in using a third-party authentication provider, we may receive:

• Apple Sign-In: Name, email address (or a private relay email), and a unique user identifier. Apple may allow you to hide your email address, in which case we receive a relay address.
• Google Sign-In: Name, email address, a Google account ID and a link to your Google photo (we don't use it as your profile photo).

We do not receive or store your third-party authentication passwords.

3.4 Information from Other Third Parties

• Apple, Google and RevenueCat (whether you have an active subscription; no card details)
• Content moderation services (safety assessments)

3.5 Information We Do Not Collect

The Scout Me Pro mobile application does not collect or access:

• Precise GPS or geolocation data
• Contacts or address book data
• Calendar data
• Health or fitness data
• Biometric data (fingerprints, facial geometry). The only face images we collect for checking identity are the ID photo and selfie a scout sends for verification, which a person checks by eye (see Section 3.6)
• Payment card numbers (handled entirely by Apple, Google, or RevenueCat)
• IMEI or serial numbers
• Advertising identifiers (IDFA/GAID)
• Call logs or SMS messages

3.6 Scout Verification

Verification is optional. Only verified scouts can message footballers under 18 in the app, so a scout who wants to do that can ask to be verified. If you ask, we collect:

• Your full legal name, your role or job title, your organisation's name and type, and your country
• A photo of your photo ID (for example a passport, national ID card or driving licence) and a selfie, either holding the ID or on its own
• If you choose to add them: a work email address (which you confirm with a one-time code we email to it), your organisation's website, someone at your organisation we can contact about you, details and photos of licences or certificates (for example a FIFA football agent licence, a national FA scouting certificate or a coaching licence), links to public profiles (such as LinkedIn, Transfermarkt or a club staff page) and any note you add

Why we collect it: to check that you are who you say you are and that you really work in football before we let you message footballers under 18. This protects the children who use Scout Me Pro. We don't ask for criminal record certificates, so please don't send them.

How we check it: a member of the Scout Me Pro team looks at everything by hand. We do not use automated face recognition or an outside identity-checking company. We may look at the websites and links you give us, search public sources (such as your organisation's website or the FIFA register of licensed agents) and contact the person you name at your organisation.

Who can see it: only Scout Me Pro staff who review verification requests. Your photos are kept in private storage with our database provider (Supabase) and are never shown to footballers, parents or anyone else on the app. If you are verified, other users see a "Verified scout" badge on your profile, nothing more.

How long we keep it: we delete your ID, selfie and certificate photos 30 days after we make a final decision (approving or not approving your request, or later removing your verification). We keep the decision, the reason for it and the details you typed for as long as your account is open, so we can show why an account is or isn't verified and look into any later safety concern. If you delete your account, we delete all of it, photos included. The codes used to confirm a work email are deleted within 30 days.

Your verification record (without the photos) is included when you use "Download my data" in the app. You can ask us to delete your photos sooner, or for a copy of them while we still hold them, by emailing legal@scoutmepro.com.

4. Mobile Application Permissions and Data

The Scout Me Pro mobile application requests the following device permissions. Each permission is only used for the stated purpose and is requested at the time it is needed:

All permissions are optional and requested at the point of use. If you deny a permission, the related feature will be unavailable but the rest of the app will continue to function normally. You can change permission settings at any time through your device's Settings app.

4.1 Mobile Data Storage and Security

Sign-in tokens on your phone are kept in encrypted secure storage (iOS Keychain / Android Keystore). Some app data is kept in the app's private storage on your phone, such as a short-lived cache of the video feed and your date of birth from sign-up until you finish setting up your profile. Videos you are editing stay in temporary app storage until you upload them. On Android, if you allow it, a sign-in key is backed up to your Google account so you are signed back in on a new phone.

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

5.1 Verifiable Parental Consent

A player aged 13 to 15 can create an account and look around before a parent or guardian consents. Until consent is given, they cannot upload videos and their profile stays private and hidden from our website. The parent or guardian gives consent in one of two ways:

• Email: a link sent to the parent or guardian's email address (valid for 30 days)
• Text message: a one-time code sent to the parent or guardian's phone, which they enter with the player

If consent is not given, we send reminders. If it still is not given, we may close the account after at least 14 days' notice and delete its data. When a player turns 16, the consent requirement ends automatically; we keep the consent record. We do not accept accounts for children under 13 and close any we find.

5.2 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
• Phone numbers, email addresses and social media handles are blocked in chats with players under 18, in captions and comments involving them, and in their profile bios
• Usage analytics are always off for players under 16, and they cannot turn them on
• We never send marketing emails, or emails asking them to buy or keep Pro, to players under 16
• Children's profiles default to private and are only made public after parental consent is verified

5.3 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

There is no separate parent account or dashboard. To exercise these rights, contact us at support@scoutmepro.com; we may ask you to confirm you are the parent or guardian. A copy of the child's data can also be requested in the app (Settings, Account, Download my data), and the account can be deleted there too (Settings, Danger Zone, Delete account).

5.4 Content Moderation for Child Safety

Safety checks apply to everyone, with extra protections for players under 18:

• Every video is checked automatically before anyone else can see it; videos the check flags go to a person for review
• Captions, comments, profile bios and messages are checked automatically. For players under 18, text is held back if the check cannot run, and a bio that breaks the rules is removed
• Content found to break our rules is removed
• Unverified scouts cannot message anyone under 18
• Anyone else who wants to message a player under 18 sends a message request, and the player only sees the message after they accept it

6. Legal Basis for Processing (GDPR)

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

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

• Uploads and a public profile for players under 16 (consent from a parent or guardian)
• Product analytics in the app and on the website (only if you agree, and never for players under 16)
• Push notifications (you allow them on your phone)
• Featuring your clips on our social media (only if you agree, or your parent does if you are under 18)

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

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

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

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

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

• Platform security and fraud prevention
• Checking content, messages and new scout profiles, and assessing account risk, to protect users from harm
• Crash reporting and diagnostic data collection
• A few usage events our servers record (for example, a video uploaded or an analysis finished), as anonymous counts with no account ID
• Enforcing terms of service
• Emails about new features and Pro to account holders, which you can turn off at any time (players under 16 never get marketing emails or emails asking them to buy or keep Pro)

Note: for players under 16, uploading videos and having a public profile depend on a parent or guardian's consent. Running their account (sign-up details, messages, support) is part of providing the service under our Terms, and keeping them safe (content and message checks, handling reports) relies on our legitimate interests and legal obligations. We never use children's data for advertising.

7. How We Use Your Information

7.1 Platform Operations

• Create and manage your account
• Enable you to upload and share football videos
• Help scouts find footballers
• Facilitate communication between users
• AI video analysis (Pro): Google Gemini watches the clip you choose and Anthropic Claude writes your report from it
• Process transactions and subscriptions
• Deliver push notifications for messages, updates, and alerts

7.2 Safety and Security

• Check ages, and verify scouts who ask to be verified
• Check videos, captions, comments, profile bios, messages and photos sent in chats, using automated tools including AI
• Check what new scouts write about themselves (using AI) and assess account risk from reports, blocks and message patterns. These checks can lead to automatic warnings or a pause on messaging; you can ask in the app for a person to review it
• 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

7.3 Communications

• Send service-related notifications (email, push, and in-app)
• Respond to support requests. Our AI support assistant (Anthropic Claude) sorts and translates requests and drafts replies. Some replies are sent without a person reading them first; those say so, and a person reads every conversation afterwards
• Send emails about new features and Pro. These are on by default for account holders aged 16 and over; turn them off in Email preferences or with the link in any email. Players under 16 never get marketing emails or emails asking them to buy or keep Pro
• Notify you of policy changes
• Contact parents and guardians about consent, and pass on messages from scouts who use "Contact parent or guardian"

7.4 Improvement, Analytics, and Diagnostics

• Analyse usage patterns to improve services
• Monitor application performance and stability
• Diagnose and fix crashes, errors, and bugs
• Test new features
• Generate aggregated, anonymised insights

7.5 Legal and Compliance

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

8. How We Share Your Information

8.1 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. If you agree (or your parent or guardian does, if you are under 18), we may post your clips on Scout Me Pro's social media with your first name, position and country. You can withdraw that agreement at any time.

8.2 Other Users

If your profile is public, anyone online can see it, including search engines: your name, photo, bio, location, team, position, height, weight, age and your approved videos. If you make it private (Settings, Content & Activity, Profile visibility), only you can see your profile, videos, comments and likes: no other user can, scouts included, and people you already chat with see "Private account" instead of your name and photo. Profiles of players under 16 stay private until a parent or guardian gives consent. If your profile is public, other users can also see:

• Your comments and likes
• That you viewed their profile (Pro members and scouts can see who viewed theirs)
• Your video's view counts and where views come from, for the video's owner

8.3 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

8.4 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.

9. Third-Party Service Providers and SDKs

We use the following third-party service providers and software development kits (SDKs) to operate our Platform. All service providers are contractually bound to protect your data, process it only for specified purposes, and comply with applicable data protection laws.

We encourage you to review the privacy policies of each third-party provider. Links are available upon request at legal@scoutmepro.com.

9.1 Data Processing Agreements

We maintain Data Processing Agreements (DPAs) with all service providers that process personal data on our behalf, ensuring they meet the requirements of GDPR and other applicable data protection laws.

9.2 Children's Data and Third Parties

For users under 16, we limit data sharing with third-party services to only what is strictly necessary for Platform operation. We do not share children's data with third parties for advertising, profiling, or marketing purposes.

10. 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. As detailed in Section 9, some of our service providers operate in the United States and other jurisdictions. We ensure appropriate safeguards are in place for all international transfers:

10.1 Transfer Mechanisms

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

10.2 Data Storage Locations

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

• European Union (primary — Supabase, PostHog, Sentry, SightEngine, Infobip)
• United States (with appropriate safeguards — Vercel, Inngest, RevenueCat, Expo, Resend, Anthropic, Google Gemini and Cloud Vision, Apple, Amazon Web Services, Zernio, Slack)
• Global CDN (Cloudflare — video content is distributed globally for performance)

11. Data Retention

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

11.1 Retention Periods

11.2 Deletion Requests

When you ask us to delete your data, we delete it within 30 days, except what we keep as safety evidence (reports, and videos or messages that were reported or removed by moderation) or where the law requires us to keep it. We automatically delete your data from our video host (Cloudflare), our subscription provider (RevenueCat) and our analytics provider (PostHog). Our other providers delete it under their own retention limits (see Section 9).

11.3 Account Deletion

You can delete your account at any time in the app (Settings, Danger Zone, Delete account) or by emailing support@scoutmepro.com. Then:

• Your account is deleted 30 days after you confirm. Until then, you can sign back in and tap "Keep my account"
• On that day we delete your profile, login, videos (including at our video host), photos, scout verification files, support requests, subscription history and your record at RevenueCat
• Messages you sent stay visible to the people you sent them to, shown as "[Message from deleted user]"
• Reports made by or about you, and any reported video, are kept as safety evidence
• Deleting your account does not cancel an App Store or Google Play subscription; cancel it in the store first

12. Your Privacy Rights

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

12.1 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

12.2 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

12.3 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

12.4 How to Exercise Your Rights

To exercise any of your privacy rights, you may:

• Email us at support@scoutmepro.com (or legal@scoutmepro.com)
• Get a copy of your data in the app: Settings, Account, Download my data (once a day; you get a file of your data plus your videos, by email or on that screen, and the links last 14 days)
• Correct your details by editing your profile, or change your email in Settings, Account, Email address
• Use the account deletion option in the mobile application settings

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.

13. Cookies and Tracking Technologies

This section applies primarily to the Scout Me Pro website. The mobile application does not use cookies but may use equivalent technologies as described in Sections 3, 4, and 9.

13.1 What We Use

• Your cookie choice: saved in your browser's local storage so we don't ask again
• Analytics (PostHog, EU): cookies are set only if you accept them in the banner
• Error monitoring (Sentry, EU): if a page breaks, your browser sends us an error report with the error, the page address (never anything after ? or #) and your browser type, and Sentry works out an approximate country and city from the connection. Nothing is sent unless an error happens. It sets no cookies, stores nothing in your browser and never records your screen, so it does not depend on the cookie banner
• Email tracking: our emails about new features and Pro include a small image and tracked links that tell us whether the email was opened or a link clicked

We do not use marketing or advertising cookies, and we do not load advertising or ad-measurement tools.

13.2 Managing Cookies

Choose in the cookie banner on your first visit. To change your choice later, clear this site's data in your browser and choose again. In the app, you can turn usage analytics on or off in Settings.

13.3 Do Not Track

Our website does not respond to Do Not Track signals. Analytics run only if you accept analytics cookies.

14. Data Security

We use these measures to protect your personal information:

14.1 Technical Safeguards

• Encryption in transit (HTTPS) and at rest, provided by our hosting providers
• Passwords stored only as secure hashes
• Sign-in tokens kept in your phone's secure storage (iOS Keychain / Android Keystore)
• Database access rules that limit each user to the data they are allowed to see, and regular security reviews of our code and those rules
• DDoS protection from our hosting providers

14.2 Organisational Safeguards

• Admin tools limited to named members of our team
• Scout verification documents are seen only by the staff who review them

14.3 Data Breach Notification

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

• Report it to the relevant supervisory authority within 72 hours where the law requires
• Tell affected users without undue delay if it is likely to put them at high risk
• Provide information about the breach and remedial steps
• Take immediate action to mitigate harm

15. Third-Party Links and Services

Our Platform may contain links to third-party websites or services, including social media platforms such as WhatsApp, X (Twitter), Instagram, and TikTok. We are not responsible for their privacy practices. We encourage you to read the privacy policies of any third-party services you access.

16. 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
• For material changes, we will tell you by email or in the app at least 30 days before they take effect
• Where the law requires it, we will ask parents and guardians for consent again

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

17. Contact Us

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

18. 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