Privacy Policy

Effective Date: 2nd July 2025

Last Revised: 2nd July 2025

1. Introduction - Who Are We?

1.1

Starting11 Limited is a private limited liability company, governed by the Companies and Allied Matters Act 2020 (CAMA) (referred to as “we”, “us”, or “our”). We respect your privacy and are committed to complying with the privacy principles set out in the applicable privacy laws and regulations in the regions where we operate.

1.2

This Privacy Policy (the “Policy”) explains how we collect, hold, process, use, store, and protect and disclose your personal information when you access or use our sports services, features, and website.

2. What Does “Personal Information” Mean?

Personal Information refers to any information about you that identifies you or can be used to reasonably determine your identity.

3. What Type of Information Do We Collect or Process, and What Is Our Basis For Collecting or Processing That Data?

The types of information we collect or process depend on how each user interacts with us. Generally, we collect the following types of information, along with the corresponding basis for collection:

3.1 Account Registration

When you sign up on our platform, we collect personal details such as your full name (Surname, first name and other name), email address, phone number, home address, photograph, payment information, activity data (including viewing habits, preferences, and device information), and location data (if you use location-based features). If applicable, we may also collect sports performance data. This data is necessary to provide you with full access to the functionality of Starting11. We will obtain your explicit consent to use this information.

3.2 Payments

When you make a payment on our platform (or mobile application), we collect payment details such as your payment card information, which are processed via a third-party payment gateway that complies with Payment Card Industry Data Security Standards (PCI DSS). We do not store your payment card details.

3.3 Sports Data

We collect data related to your sports performance, health, wellness, and club-related activities, as permitted by you or our customers. This data is controlled by our customers and processed as part of our contractual obligations. By using this platform, you grant us the right to use this data as part of our services, as outlined in the User Agreement, and no separate consent is required beyond your acceptance of the User Agreement.

4. How Do We Collect Your Personal Data?

4.1 General

  • 4.1.1

    We collect your personal data directly when you interact with our platform or services, such as entering information into our software.
  • 4.1.2

    We will always strive to collect personal data directly from you where possible.
  • 4.1.3

    Regardless of how personal data is collected, whether directly from you, via your interactions, or through third parties, we will ensure it is handled in line with this Policy.

4.2 Cookies

  • 4.2.1

    Our websites use “cookies” to help you sign in and personalize your online experience.
  • 4.2.2

    Cookies may track your activity across devices to enhance your experience, such as storing your preferences and other information to save you time.
  • 4.2.3

    For full details on our use of cookies, please refer to our Cookies Policy. This Policy is incorporated by reference and forms part of this Privacy Policy.

5. How Do We Use Your Information?

We use the information we collect for the following purposes:

5.1 Providing and Maintaining Services

We use your data to deliver services and meet our contractual obligations. For example:

  • 5.1.1

    For Athletes: We use your data to enable you to track training and game-day activity, provide customer support, and generate performance reports within the community.

  • 5.1.2

    For Scouts/Clubs: We use data to fulfill contractual obligations, enhance products and services, and develop new features for Starting11.

5.2 Improving and Developing Services

We use your information to enhance our services, perform data analysis, troubleshoot issues, conduct research, and develop new features.

5.3 Communicating with You

We use your data to respond to inquiries, send notifications, and inform you about new features or products. You can control your marketing and notification preferences via account settings or by using the “Unsubscribe” option in emails.

5.4 Promoting Safety and Security

We use the data we collect to improve the security of our services, authenticate users, protect against fraud, respond to legal claims, and enforce terms and policies.

5.5 Internal Business Purposes

We use personal data for internal operations such as communication, product development, and business management.

5.6 Legal Compliance

We may also use your information to comply with legal obligations.

6. Will We Disclose Your Personal Information to Others?

6.1 General Disclosures

  • 6.1.1

    Performance data of athletes may be shared for rankings and comparisons via our platform’s features.
  • 6.1.2

    We may share information to comply with our contractual obligations with clubs/teams or for product development and enhancement.
  • 6.1.3

    Your personal information may also be disclosed to third parties with whom we collaborate to provide our services.
  • 6.1.4

    We will not disclose your personal information without your consent, unless required by law or as described in this Policy.
  • 6.1.5

    We may disclose information to comply with legal obligations or regulatory requirements.

6.2 Sub-processors

  • 6.2.1

    We may engage third-party service providers (sub-processors) to help us deliver services. These third parties may have access to personal data.
  • 6.2.2

    We ensure these sub-processors comply with the necessary data protection standards.

7. Will We Disclose Your Personal Information Outside Your Region?

  • 7.1

    Your information may be transferred outside your region to provide customer service and support. We ensure that any such transfer is consistent with applicable contractual terms.
  • 7.2

    If your information is transferred outside your region, we will take steps to ensure it is protected in line with this Policy and applicable laws.

8. How Do We Keep Your Personal Information Secure?

  • 8.1

    We implement reasonable security measures to safeguard your personal data from loss, misuse, unauthorized access, modification, or disclosure.
  • 8.2

    Security measures include:
    • 8.2.1

      Secure premises and access controls.
    • 8.2.2

      Confidentiality agreements for employees.
    • 8.2.3

      Firewalls and restricted access to personal information.
    • 8.2.4

      Regular computer maintenance to prevent unauthorized access.
    • 8.2.5

      Secure document handling, including shredding.
    • 8.2.6

      Storage and processing of data on secure cloud services, ensuring compliance with industry-standard security protocols.

9. What Are Your Rights?

9.1 Accessing and Exporting Information

  • 9.1.1

    Athletes (or team manager) can access personal information by logging into their account.
  • 9.1.2

    Other users can access personal information by contacting us at via the support email or in-app channels.

9.2 Editing and Deleting Information

  • 9.2.1

    Athletes can modify and delete their information through account settings.
  • 9.2.2

    Other users may request edits or deletions by contacting us at via the support email or in-app channels.
  • 9.2.3

    We may retain data for legal or preventative reasons.

9.3 Further Rights

  • 9.3.1

    If you are in the European Economic Area, United Kingdom, and Switzerland, you can object to processing based on legitimate interests.
  • 9.3.2

    You have the right to object to direct marketing at any time.
  • 9.3.3

    You can request restrictions on processing your data.
  • 9.3.4

    To exercise your rights under (9.3.1)-(9.3.3) above, contact us via the support email or in-app channels.
  • 9.3.5

    If you need further assistance regarding your rights, please contact our Data Protection Officer by email [email protected], and we will consider your request in accordance with applicable laws.

9.4 Direct Marketing

  • 9.4.1

    We may use your personal information to offer services that we believe you may be interested in. You can opt out of marketing communications at any time.
  • 9.4.2

    We do not share your personal information with third parties for marketing purposes.

9.5 Policies for Children

  • 9.5.1

    We appreciate the importance of taking additional measures to protect children’s privacy.
  • 9.5.2

    We do not allow users below the minimum age for registration without parental control. If a user is registering someone who is under the applicable minimum age, you agree and acknowledge that appropriate parental or legal guardian consent has been given by virtue of your registration and your acceptance of the User Agreement, (which incorporates this policy by reference).
  • 9.5.3

    If we discover that we have collected information from a child under the minimum age without consent, we will either secure consent or delete the information.

10. How Long Do We Store Your Information?

  • 10.1

    We store your information for the duration of our contractual relationship and as required by law.
  • 10.2

    We may retain and use full, identifiable data to support business analysis, growth and decision-making. Once no longer necessary for these purposes, we may anonymize or aggregate the data for continued use in research or commercial purposes.
  • 10.3

    We may retain aggregated or anonymized data for research or commercial purposes, but such data will not identify you personally.

11. Changes to This Privacy Policy

We may update this Policy to reflect legal or operational changes. Any material changes will be posted on our website. If you object to the amendments, you should stop using the service and delete your account by contacting us.

12. How Do You Access the Personal Information We Store?

  • 12.1

    You can request access to your personal information by contacting us at [email protected].

  • 12.2

    We will respond to your request promptly, within the timeframe required by law.

13. Complaints About Breaches of Privacy

  • 13.1

    If you believe that we have violated your privacy, please contact us by email:[email protected]

  • 13.2

    We will respond to you within 30 days and explain what actions we will take in response to your complaint.