DRAFTD

Privacy Policy

1Introduction

1.1

This Privacy Policy (“Policy”) explains how Draftd LLC, a company established under the laws of Delaware, USA, with its registered address at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA (“Operator”, “we”, “us” or “our”), collects, uses, discloses, stores and otherwise processes personal data in connection with draftd.com, its website, mobile applications (including versions distributed through third-party application stores), features, content and related digital services (collectively, the “Platform”).

1.2

The Platform identifies, showcases and shares the stories, achievements, development and potential of emerging sports talents (“Athletes”). It may publish Athlete profiles, biographies, sporting achievements, photographs, videos, interviews, statistics and related information.

1.3

This Policy applies to website visitors, mobile application users, account holders, Athletes featured on the Platform, their parents or legal guardians, contributors (including coaches, clubs and sports organisations), and persons contacting the Operator.

1.4

This Policy should be read together with the Platform’s Terms and Conditions (“Terms”). Capitalised terms not defined here have the meanings given in the Terms where applicable. The Terms govern use of the Platform; this Policy describes personal-data processing and does not itself substitute for consent where consent is required.

2Controller and Contact Details

2.1

Draftd LLC is the controller of personal data for processing activities for which it determines the purposes and means, unless another entity independently acts as controller.

2.2

Operator: Draftd LLC. Registered address: 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA. Website: www.draftd.com. Privacy contact email: team@draftd.com

2.3

Requests concerning privacy, Athlete profiles, correction, removal or account deletion may be sent to the contact details in Section 2.2.

3Categories of Personal Data

3.1

Athlete data may include names, age or date/year of birth, nationality, sporting discipline, club/team affiliation, training and competition history, results, rankings, awards, sporting aspirations, biographical narratives, interviews, quotations, photographs, video and audio recordings.

3.2

Parent, guardian and representative data may include names, contact details, relationship or authority to act for an Athlete, consent and permission records, verification information reasonably needed to confirm authority, and related correspondence.

3.3

Account data, where registration is available, may include name, username, email, authentication information, account preferences and account activity.

3.4

Technical and usage data may include IP address, browser and operating system, device type and model, app version, device or application identifiers, pages/screens viewed, interaction events, session information, diagnostic logs, crash reports and security records.

3.5

Communications data may include messages, inquiries, complaints, content-submission correspondence, correction or takedown requests and our responses. We seek to avoid collecting information not necessary for the relevant purpose.

4Sources of Personal Data

4.1

We may receive data directly from Athletes and users; from parents, legal guardians, coaches, clubs, sports organisations or other authorised contributors; through Platform interactions; and from publicly accessible sporting records where lawful.

4.2

A person submitting data about another individual must have the authority or other lawful basis required by applicable law. Public availability of information does not, by itself, remove applicable restrictions on its use or republication.

4.3

We may seek reasonable evidence of identity, age, authority or permission before publishing or continuing to publish an Athlete’s Content, particularly where a minor is involved.

5Purposes of Processing

5.1

We process data as appropriate to (a) receive and assess Content submissions; (b) create, edit, publish, maintain and promote Athlete stories and profiles; (c) verify permissions and protect minors; (d) operate accounts and Platform features; (e) respond to inquiries and rights requests; (f) maintain security, prevent misuse and diagnose technical problems; (g) measure performance and improve the Platform; (h) provide service communications and optional notifications; and (i) meet legal obligations and resolve disputes.

5.2

We will not use personal data for an incompatible purpose without an appropriate legal ground and any additional notice or consent required by law.

6Legal Grounds and Consent

6.1

Depending on the jurisdiction and activity, processing may rely on consent; performance of an agreement; compliance with legal obligations; legitimate interests where recognised and appropriately balanced against individual rights; or another ground permitted by applicable law.

6.2

Where consent is required for publication of personal information, images, interviews or information about a minor, we will seek the relevant consent or authorisation. Acceptance of the Terms alone is not a substitute for separate consent where law requires it (Terms, Section 12.8).

6.3

Consent may be withdrawn in accordance with applicable law. Withdrawal does not retrospectively invalidate earlier lawful processing. Requests affecting published material are handled under Sections 15 and 16 of this Policy and Section 11 of the Terms.

6.4

An intellectual-property licence to use submitted Content under Section 7 of the Terms is distinct from the legal ground for processing personal data and does not override applicable privacy, image or personality rights.

7Children and Young Athletes

7.1

The Platform may feature Athletes who are minors. Where applicable law requires parental or legal guardian consent or other authorisation, relevant personal data and Content will be submitted or published only with the required permission (Terms, Section 2).

7.2

We may verify the authority of a person acting for a minor and may decline or remove material if consent cannot be established or publication may present a privacy or safety risk.

7.3

We do not intentionally publish a minor’s home address, private telephone number, private contact details or other information creating an unreasonable safety risk. Sensitive information, including medical details, requires an appropriate lawful ground and any additional required consent.

7.4

Parents, legal guardians and Athletes may request review, correction or removal, subject to applicable law and the minor’s own rights and interests.

8Public Athlete Profiles and Media

8.1

The Platform’s central purpose is public presentation of selected Athlete information. Subject to the applicable permissions and legal grounds, published Content may include names, sporting histories, achievements, photographs, videos, interviews and stories.

8.2

Material may be submitted via the website, mobile application or another channel authorised by the Operator (Terms, Section 4.6). Media may be technically adapted for publication across devices and Platform features in accordance with the Terms and applicable permissions.

8.3

Public material may be viewed internationally, indexed by search engines where technically accessible, or copied or shared by third parties. Removal from the Platform may not immediately remove independently held copies or search-engine caches.

8.4

Use of Athlete images or personal information for independent advertising, endorsements or promotional activities beyond the authorised presentation and promotion of the Platform may require additional permission or consent.

8.5

We do not disclose an Athlete’s non-public contact details to clubs, scouts, sponsors or other third parties merely because an Athlete is featured on the Platform.

9Website, Mobile App and Device Permissions

9.1

The Platform may be accessed through a browser, mobile application or other supported interface. Certain app functions may request access to a camera, photo library, microphone or notification settings for features such as capturing or uploading Content and receiving notifications.

9.2

Device permissions are managed through the relevant operating system and, where available, Platform settings. Denying or withdrawing a permission may prevent the related feature from working.

9.3

Permission granted through an operating-system prompt does not itself constitute consent to public publication of an Athlete’s personal data or image where separate consent is required.

9.4

We do not describe precise geolocation collection as a standard Platform function. If location access or another material permission is introduced, this Policy and any required notices or consents must be updated before deployment.

10Cookies, Analytics and Notifications

10.1

We may use essential cookies, authentication/session technologies, mobile identifiers, diagnostic tools and, where implemented, analytics technologies to operate, secure and improve the Platform.

10.2

Non-essential cookies, tracking technologies or identifiers will be subject to applicable law and user choices. We will seek separate consent where required and provide appropriate preference controls.

10.3

Mobile applications may offer push notifications relating to account activity, stories or Platform updates. Users may manage notification permissions in device settings. Marketing messages will be subject to any required opt-in and opt-out rules.

10.4

Specific cookies, software development kits (SDKs), analytics providers, identifiers and retention periods should be identified in a supplementary cookie/technology notice or in this Policy before those tools are enabled.

11Sharing and Recipients

11.1

We may share personal data, where lawfully necessary, with hosting and cloud service providers, app infrastructure and maintenance providers, security and diagnostic vendors, communication and notification services, professional advisers, and competent public authorities where legally required.

11.2

We seek appropriate contractual and security safeguards for service providers processing personal data on our behalf.

11.3

Publicly published Athlete Content is accessible to Platform visitors. This public disclosure is distinct from sharing non-public account, contact or consent-verification information with service providers.

11.4

We do not sell Athletes’ or users’ personal data. We do not provide minors’ non-public information for independent commercial solicitation without an appropriate lawful basis and required permissions.

12International Access and Transfers

12.1

The Operator is established in Delaware, USA. The Platform may be accessible globally, and service providers may process data in countries other than the country where an individual resides.

12.2

Where international transfers are regulated, we will apply safeguards or obtain authorisations or consent as required by the laws applicable to the particular processing activity.

12.3

Details of material transfer destinations and safeguards will be provided where required by law.

13Retention

13.1

We retain personal data for as long as reasonably necessary for the purposes described in this Policy, subject to applicable law, continuing publication, consent status, security needs, and legal claims or recordkeeping obligations.

13.2

Following a justified removal or deletion request, data will be deleted, anonymised, restricted or retained only where permitted or required by law. Some copies may remain temporarily in technical backups or lawfully retained records.

13.3

We will review retention practices periodically. Specific retention periods or objective criteria should be published once the Platform’s systems and legal requirements are confirmed.

14Accounts and Account Deletion

14.1

Where accounts are available, users may request deletion through the procedure made available on the Platform or by contacting the Operator (Terms, Sections 3.6 and 15.5).

14.2

Deleting an account does not necessarily result in automatic deletion of an Athlete profile concerning another person. Such profiles and related requests are assessed separately under Section 16 of this Policy and Section 11 of the Terms (Terms, Section 3.7).

14.3

Deletion requests will be processed in accordance with applicable law. Certain information may remain in legally retained records or backups as described in Section 13.

15Individual Privacy Rights

15.1

Subject to applicable law, individuals may have rights to obtain information, access personal data, request correction or deletion, withdraw consent, object to or restrict processing, obtain portability where available, and complain to a competent regulator.

15.2

Requests may be sent to the contact in Section 2. We may request information reasonably necessary to verify identity or authority and will respond within applicable legal deadlines.

15.3

Rights may be subject to lawful exceptions, including protection of other individuals’ rights, legal obligations and the establishment or defence of claims.

16Athlete Profile Correction and Removal

16.1

Athletes, parents, legal guardians and other authorised persons may ask us to review, correct, restrict or remove published Athlete profiles or related personal information.

16.2

Requests should identify the relevant Content and explain the concern. We assess identity and authority, applicable legal grounds, accuracy, the Athlete’s rights and safety (especially for minors), third-party rights and any legal exceptions.

16.3

Where justified, we may correct or remove specific material, restrict public access or delete a profile. The content-review and takedown procedure is also described in Section 11 of the Terms.

16.4

Where Content was supplied by another contributor, we may contact that person where appropriate and consistent with the Athlete’s privacy and safety.

17Security

17.1

We seek to implement appropriate technical and organisational measures to protect personal data, including access restrictions, authentication, secure communications, monitoring, backup and confidentiality measures as appropriate.

17.2

No online or mobile service is completely secure. We will assess and address suspected data breaches and provide notices where required by applicable law.

18Third-Party Services and App Stores

18.1

The Platform may link to third-party websites, social-media services or applications. Such providers independently determine their own privacy practices, which are governed by their policies.

18.2

Mobile applications may be distributed through Apple App Store, Google Play or other app stores. Store operators may independently process information about downloads, installation, updates and their services. Their separate privacy policies apply to that processing (Terms, Sections 1.6 and 13.5).

18.3

We are not responsible for processing independently undertaken by those third parties.

19Changes to This Policy

19.1

We may update this Policy to reflect changes in Platform functions, processing practices or legal requirements. The current version will be available through the website and, where appropriate, the mobile applications, with an updated date.

19.2

Where required, we will provide additional notice or seek new consent before materially changing the purposes or grounds of processing.

20Applicable Law and Complaints

20.1

Draftd LLC is established in Delaware, USA. Processing will be governed by applicable privacy and data protection laws, including mandatory laws applying to individuals in other jurisdictions where relevant. The governing-law and dispute provisions of the Terms appear in Section 21 of the Terms; they do not remove mandatory statutory privacy rights.

20.2

Privacy concerns may be raised with us using Section 2. Individuals may also contact competent regulatory authorities or seek remedies available under applicable law.

21Final Provisions

21.1

This Policy applies to both the website and mobile application versions of the Platform.

21.2

In the event of inconsistency between this Policy and the Terms regarding the description of personal-data processing, this Policy governs that description, subject to mandatory law. Neither document substitutes for separate consent where required.

21.3

Effective date: October 30, 2026. Operator: Draftd LLC.