Privacy Policy

Effective Date: January 1, 2025

Last Updated: January 1, 2025

GDPR/DSGVO & CCPA/CPRA Compliant: This privacy policy complies with the EU General Data Protection Regulation (GDPR/DSGVO) and California Consumer Privacy Act (CCPA/CPRA). Your data is hosted on EU servers in Germany and protected under German data protection law.

1. Data Controller & Contact Information

Data Controller:
Alpha Freeman Elite Soccer Development
Email: [email protected]
Phone: +1 (234) 567-890

Data Protection Officer (DPO):
For data protection inquiries, please email: [email protected]

2. Data We Collect

We collect the following types of personal data:

Personal Information

  • Name, email address, phone number
  • Age, location (city/country)
  • Player position and playing level
  • Playing experience and football history
  • Video footage links (if provided voluntarily)

Automatically Collected Data

  • IP address (anonymized where possible)
  • Browser type and version
  • Device information
  • Pages visited and time spent on site
  • Referral source

Cookies & Tracking

We use essential cookies for website functionality. Analytics and marketing cookies require your explicit consent via our cookie banner.

3. Legal Basis for Processing (GDPR Art. 6)

Contract Performance (Art. 6(1)(b))

Processing necessary to provide consultation services, training programs, and pathway placement you request.

Consent (Art. 6(1)(a))

Marketing communications, analytics cookies, and video analysis (where you provide consent).

Legitimate Interest (Art. 6(1)(f))

Fraud prevention, security, website improvement, and communication regarding your inquiries.

4. How We Use Your Data

  • Provide consultation services and training programs
  • Evaluate player abilities and match with appropriate pathways
  • Communicate regarding bookings, trials, and opportunities
  • Connect players with clubs and coaches (with explicit consent)
  • Send service updates and respond to inquiries
  • Improve our website and services
  • Comply with legal obligations

5. Data Sharing & Third Parties

We may share your data with the following categories of recipients:

Football Clubs & Coaches

With your explicit consent, we share player profiles with clubs and coaches for trial opportunities.

Service Providers

Hosting providers (EU-based), email services, payment processors (all GDPR-compliant).

Legal Obligations

When required by law, court order, or to protect our rights.

Important: We do NOT sell your personal data to third parties.

6. International Data Transfers

EU Data Hosting: Your data is primarily hosted on servers located in Germany (EU) and protected under GDPR/DSGVO.

If we transfer data outside the EU/EEA, we ensure adequate safeguards through:

  • Standard Contractual Clauses (SCCs) approved by the EU Commission
  • Adequacy decisions by the EU Commission
  • Your explicit consent for specific transfers

7. Your Rights (GDPR & CCPA/CPRA)

You have the following rights regarding your personal data:

GDPR Rights (EU/EEA)

  • Right to Access: Request a copy of your data
  • Right to Rectification: Correct inaccurate data
  • Right to Erasure: Request deletion ("right to be forgotten")
  • Right to Restriction: Limit how we use your data
  • Right to Data Portability: Receive your data in machine-readable format
  • Right to Object: Object to certain processing
  • Right to Withdraw Consent: Withdraw consent at any time
  • Right to Lodge Complaint: File complaint with supervisory authority

CCPA/CPRA Rights (California)

  • Right to Know: What data we collect and how it's used
  • Right to Delete: Request deletion of personal information
  • Right to Opt-Out: Opt out of sale/sharing (we don't sell data)
  • Right to Correct: Correct inaccurate information
  • Right to Limit: Limit use of sensitive data
  • Right to Non-Discrimination: No discrimination for exercising rights

How to Exercise Your Rights

To exercise any of these rights, contact us at:

  • Email: [email protected]
  • Subject Line: "Data Rights Request - [Your Name]"
  • Response Time: Within 30 days (GDPR) or 45 days (CCPA)

We may require verification of your identity before fulfilling requests.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

  • Active Clients/Players:

    Duration of service relationship plus 3 years for legal/contractual obligations

  • Inquiries/Contact Forms:

    2 years from last contact (unless consent withdrawn earlier)

  • Marketing Consent:

    Until consent withdrawn or 3 years of inactivity

  • Website Analytics:

    Anonymized after 14 months

After retention periods expire, data is securely deleted or anonymized.

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

Technical Measures

  • • SSL/TLS encryption (HTTPS)
  • • Encrypted data storage
  • • Secure authentication
  • • Regular security updates
  • • Firewall protection
  • • Access controls

Organizational Measures

  • • Staff training on data protection
  • • Limited access (need-to-know basis)
  • • Confidentiality agreements
  • • Regular security audits
  • • Incident response procedures
  • • Data breach notification protocols

10. Cookies & Tracking Technologies

We use cookies and similar tracking technologies. You can manage your preferences through our cookie banner or browser settings.

Essential Cookies (Required)

Necessary for website functionality, security, and form submissions. Cannot be disabled.

Analytics Cookies (Optional)

Help us understand how visitors use our site. Requires your consent.

Marketing Cookies (Optional)

Track effectiveness of marketing campaigns. Requires your consent.

For more details, see our Cookie Policy.

11. Children's Privacy

We work with players aged 13 and older. For users under 16 (GDPR) or under 18 (in some jurisdictions), we require parental/guardian consent before processing personal data.

If you are a parent/guardian and believe your child has provided us with personal information without consent, please contact us at [email protected] and we will delete it.

12. Changes to This Policy

We may update this privacy policy from time to time. The "Last Updated" date at the top will reflect the most recent changes. Material changes will be communicated via email (for active clients) or prominent notice on our website at least 30 days before they take effect.

13. Supervisory Authority Contact

If you're in the EU/EEA and have concerns about how we handle your data, you have the right to lodge a complaint with your local supervisory authority:

Germany (Lead Supervisory Authority):

Bundesbeauftragter für den Datenschutz und die Informationsfreiheit (BfDI)
Website: www.bfdi.bund.de
Email: [email protected]

Find your local supervisory authority: EDPB Member List

Contact Us About Privacy

For any questions, concerns, or requests regarding your privacy or this policy:

Email: [email protected]

General Contact: [email protected]

Phone: +1 (234) 567-890

We are committed to protecting your privacy and will respond to all inquiries within 30 days.