Introduction and Scope

This Privacy Policy (“Policy”) sets out the manner in which BESEIN Technologies LLC, a Delaware limited liability company (“BESEIN”, “we”, “us” or “our”), collects, uses, discloses, transfers, retains and otherwise processes Personal Data in connection with the operation of its products and services.

This Policy applies to the use of: (a) our mobile applications, web applications, platforms and websites that reference or link to this Policy (collectively, the “Services”); (b) any account created for or within the the Services, including accounts for Players, Parents or Guardians, Professional Users and other categories of users described in this Policy; and (c) any other interaction you may have with us in the context of the Services, including communications by email, support channels, surveys and events.

The Services are designed to support Players at different stages of their football journey, including those seeking greater visibility to scouts, coaches, clubs and academies as they progress toward higher levels of competition and, where applicable, professional opportunities. A significant proportion of Players using the Services may be Children, and we apply enhanced protections to their Personal Data as set out in this Policy.

By accessing or using the Services, or by otherwise providing Personal Data to us, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you must not access or use the Services.

This Policy is intended to comply with applicable data protection and privacy laws, including, where applicable, Regulation (EU) 2016/679 (the “GDPR”), the UK General Data Protection Regulation (“UK GDPR”), the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (collectively, the “CCPA”), the Children’s Online Privacy Protection Act (“COPPA”), Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other similar laws. Where specific rights or obligations apply only in certain jurisdictions, this will be explicitly stated.

We apply privacy-by-design and privacy-by-default principles in the development and operation of the Services and, where required by law, conduct data protection impact assessments in relation to high-risk Processing activities, including our predictive analysis and profiling programmes.

Definitions

For the purposes of this Policy, the following terms shall have the meanings set out below:

• (a) “Personal Data” means any information relating to an identified or identifiable natural person, as defined under applicable data protection and privacy laws.
• (b) “Processing” means any operation or set of operations which is performed on Personal Data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure or destruction.
• (c) “Player” means a natural person, whether minor, youth or adult, who uses the Services to upload or otherwise provide football (soccer) performance-related content and to receive performance feedback, metrics, predictive analysis, visibility or related services in support of their football development and, where applicable, their progression along an amateur, collegiate or professional pathway.
• (d) “Parent or Guardian” means a parent or legal guardian who creates, supervises or manages a Player account for a minor, or who otherwise acts on behalf of a minor Player.
• (e) “Professional User” means any scout, agent, coach, club, academy, school, representative or other professional stakeholder who uses the Services for talent identification, development, analysis or related professional purposes.
• (f) “Controller” and “Processor” shall have the meanings given to them in the GDPR and UK GDPR.
• (g) “AI Outputs” means derived metrics, analyses, predictions, rankings or other insights generated by BESEIN’s artificial intelligence, machine learning or similar algorithmic systems on the basis of Player content or related data.
• (h) “Child” or “Children” means a Player who is under the age threshold that triggers enhanced child privacy protections under applicable law (for example, under 13 years of age for COPPA in the United States, and under 16, or the lower age specified by local law, in the European Economic Area or United Kingdom).

Terms which are defined in applicable data protection legislation and used in this Policy shall, unless otherwise stated, have the meaning given to them in such legislation.

BESEIN’s Role and Responsibility

In many cases, BESEIN acts as an independent Controller in relation to Personal Data that is collected directly from Players, Parents or Guardians, Professional Users and visitors to the Services, and which is processed for the purposes described in this Policy.

Where a club, academy, school or other organisation (a “Partner Organisation”) uses the Services to onboard or manage Players and determines the purposes and essential means of Processing Player Personal Data within the Services, that Partner Organisation will generally act as a Controller and BESEIN will act as its Processor in respect of such Processing. In such cases, BESEIN will process Personal Data strictly in accordance with the written instructions of the relevant Partner Organisation and the terms of the applicable data processing agreement.

If you are uncertain whether BESEIN is acting as Controller or Processor in relation to your Personal Data, you may contact us using the details in Section 19 of this Policy, and we will provide clarification.

Categories of Personal Data Processed

Account and Profile Data

Subject to your use of the Services and the role under which you register, we may process the following categories of account and profile data:

• (a) Identification and contact details, including name, display name, email address, telephone number, country, region and time zone;
• (b) Account credentials, including username, password and security settings;
• (c) Demographic and football-related details, including date of birth or age bracket, playing position(s), dominant foot, club, academy or team affiliation, jersey number, height, weight and similar profile details voluntarily provided by you; and
• (d) Professional details (for Professional Users), including organisation name, job title, professional accreditations or licences, and professional contact details.

Account and profile data may include a profile photograph or image that you upload so that your account can be visually identified within the Services.

Player Media and Performance Data

The core functionality of the Services is based on the analysis of football-related content. Accordingly, we may process:

• (a) Video and audio recordings, images and other media files uploaded or transmitted by or on behalf of a Player, together with descriptive information such as titles, labels, tags and contextual information (for example, match, training session, competition level and date);
• (b) Event-level and aggregated performance data derived from such media, including but not limited to sprint speeds, acceleration, work rate, actions per minute, passing patterns, positional tendencies, body mechanics and similar metrics; and
• (c) AI Outputs, including indicative role fit, comparative rankings, performance summaries, developmental insights and any other analytical outputs generated by BESEIN’s systems on the basis of Player content and other relevant inputs.

Usage, Device and Technical Data

When you access or use the Services, we may process certain information automatically, including:

• (a) Technical information relating to your device and software, such as device identifiers, operating system, application version, browser type, language settings and similar device attributes;
• (b) Log information, including dates and times of access, session duration, pages and screens viewed, features used, crash or error reports and referrer URLs; and
• (c) Approximate location data derived from your IP address, used primarily for localisation, security and analytics purposes.

Location Data

Subject to your device and application settings, we may, where strictly necessary for specific features, process more granular location data (such as GPS-based geolocation) for purposes such as tagging training or match sessions. You may control the collection of precise location data by adjusting your device permissions at any time; however, certain features may not operate correctly if such permissions are disabled.

Communications and Interaction Data

We may process information arising from:

• (a) In-platform communications, such as messages exchanged between users, coach feedback, comments and similar interactions;
• (b) Support communications, including enquiries and correspondence with our support channels;
• (c) Participation in surveys, feedback programmes, beta testing, promotions or events; and
• (d) Testimonials or endorsements you provide, subject to any separate consent that may be required for their publication.

Billing, Subscription and Transaction Data

Where you purchase a subscription or other paid service, we may process:

• (a) Subscription tier, billing period, pricing, currency and status;
• (b) Billing address and, where legally necessary, tax-related identifiers; and
• (c) Limited payment instrument details, such as card type and last four digits, to the extent necessary for reconciliation and anti-fraud purposes.

Full payment card numbers, security codes and similar sensitive payment data are collected and processed directly by our third-party payment processors and are not stored by BESEIN.

Data Obtained from Third Parties

We may receive Personal Data about you from third parties, including:

• (a) Partner Organisations which onboard or manage Players and Professional Users within the Services;
• (b) Social sign-in providers, where you elect to authenticate using such services;
• (c) Payment service providers, for purposes of payment confirmation, fraud prevention and reconciliation; and
• (d) Analytics, security and anti-fraud providers, strictly for security, abuse prevention and performance monitoring.

Such data will be processed in accordance with this Policy and any additional restrictions imposed by the relevant third party.

Special Categories and Biometric Data

We do not require you to provide, and we do not intentionally seek to process, special categories of Personal Data within the meaning of applicable law (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health data or data concerning a natural person’s sex life or sexual orientation). We do not use Player media, including profile photographs, for facial recognition or for biometric identification of individuals.

To the extent that you choose to disclose any special category data in your interactions with the Services (for example, in free-text fields or messages relating to injuries or personal circumstances), you do so at your own discretion, and such data will be processed only as necessary for the purposes described in this Policy or as otherwise required by law. Where we explicitly request information relating to injuries, medical conditions or other health related matters for the purposes of specific features of the Services, we will do so only where necessary and, where required by law (including Article 9 of the GDPR and UK GDPR), on the basis of your explicit consent, which you may withdraw at any time. In such cases, we will provide you with additional information at the point of collection.

Purposes and Legal Bases of Processing

We process Personal Data only where we have a valid legal basis under applicable law. Depending on the jurisdiction and the context, such legal bases may include:

• (a) the performance of a contract or the taking of steps at your request prior to entering into a contract;
• (b) our legitimate interests, provided that such interests are not overridden by your interests or fundamental rights and freedoms;
• (c) your consent, where required; and/or
• (d) compliance with a legal obligation.

Without limitation, we may process Personal Data for the following purposes:

• (a) Provision of the Services. We process Personal Data to register, authenticate and administer user accounts; to enable Players to upload and manage media and performance data; to generate AI Outputs and similar analytics, including our predictive analysis programmes; to facilitate visibility to Professional Users in accordance with the applicable settings and this Policy; and to provide customer support. This Processing is generally necessary for the performance of our contract with you and, where relevant, for our legitimate interests in operating and improving the Services.
• (b) Improvement and Development of the Services. We process Personal Data to monitor performance, diagnose and correct errors, evaluate and enhance features, train and validate our AI, predictive analysis and analytics models, and conduct product research and development. Where reasonably possible, we use aggregated, pseudonymised or de identified data for these purposes. We do not provide Player Media or identifiable Personal Data to third parties for the purpose of training their own general-purpose AI models, unless we have entered into appropriate contractual arrangements and, where required by law, provided notice and obtained any necessary consent. The legal basis is typically our legitimate interests in improving and developing the Services.
• (c) Personalisation and Recommendations. We process Personal Data to personalise your experience, including the presentation of content, recommendations, predictive insights and developmental guidance tailored to your profile, usage patterns and performance history. This Processing is based on our legitimate interests in providing a relevant and effective service and, where required by law, your consent.
• (d) Communications. We process Personal Data to communicate with you regarding account administration, transactional matters, security notifications, changes to our terms and policies and similar service-related information. We may also send you marketing communications concerning our products and services where permitted by law or where you have given your consent. You may withdraw consent or opt out of marketing communications at any time, without affecting our Processing for other lawful purposes.
• (e) Security, Abuse Prevention and Legal Compliance. We process Personal Data to protect the security and integrity of the Services; to detect, prevent and investigate fraud, spam, abuse, cheating, unauthorised access or other harmful or unlawful activities; to enforce our Terms of Use and other contractual rights; and to comply with legal and regulatory obligations, including responding to lawful requests from public authorities. The legal bases for this Processing include compliance with legal obligations and our legitimate interests in protecting our business and users.
• (f) Research, Statistics and Reporting. We process Personal Data, often in aggregated, anonymised or de-identified form, for internal analytics, research and statistical purposes, and to provide high-level, non-identifying insights to Partner Organisations and stakeholders. We may use aggregated, anonymised or otherwise de-identified data derived from the Services for research and academic purposes, including the preparation of publications, presentations and case studies concerning talent identification, performance analysis, predictive modelling and player development, provided that such outputs do not identify any individual. Where we wish to use identifiable Personal Data for research or publication beyond the purposes described in this Policy, we will obtain your explicit consent or ensure that another appropriate legal basis applies.

AI, Profiling and Automated Decision-Making

BESEIN employs artificial intelligence, machine learning and other algorithmic techniques in order to analyse Player Media and Performance Data and to generate AI Outputs. Such Processing may constitute “profiling” or “automated decision-making” under certain data protection laws.

AI Outputs, including those generated through our marquee predictive analysis programmes, are inherently probabilistic and are intended to provide indicative assessments of performance, playing style or potential. They are designed to support long term player development from both a sporting and human development perspective. They do not constitute guarantees of future performance or professional outcomes and should be interpreted in conjunction with expert human judgment from coaches, scouts and other professionals. BESEIN does not grant or deny contractual rights, or make legally binding decisions that produce legal effects concerning you, based solely on automated Processing without appropriate human involvement.

In jurisdictions where the GDPR or UK GDPR applies, you may have the right, in certain circumstances, to request human intervention in respect of decisions that are based solely on automated Processing and which produce legal effects concerning you or similarly significantly affect you.

Where the GDPR or UK GDPR applies, you also have the right, in certain circumstances, to object at any time to the Processing of your Personal Data for profiling or for our legitimate interests, including in connection with discovery, ranking and recommendation features. Further information on how to exercise this right is set out in Section 14. If you exercise this right, we will cease such Processing unless we demonstrate compelling legitimate grounds for the Processing which override your interests, rights and freedoms, or the Processing is necessary for the establishment, exercise or defence of legal claims.

Children and Minors

The Services are used by Players of different ages. We recognise that a significant proportion of Players are Children and we take their privacy and safety very seriously. The unsupervised use of the Services by Children under thirteen (13) years of age is not permitted. If you are under thirteen (13), you may only use the Services through and under the supervision of a Parent or Guardian who has accepted the relevant Terms of Use and this Policy and who has provided any required consent.

In circumstances where COPPA or equivalent laws apply, we will not knowingly collect Personal Data from a Child under the age of thirteen (13) without verifiable parental consent. The methods we use to obtain and verify parental consent may vary depending on the circumstances and applicable law and may include, for example, requiring a signed consent form, using a payment card or other online payment method in the Parent or Guardian’s name, conducting a brief video call, or using other verification methods permitted by law. Where we become aware that a Child under the relevant minimum age has provided Personal Data to us in contravention of this Policy, we will take reasonable steps to delete such data and to terminate any associated account.

Parents and Guardians of minor Players may, in accordance with applicable law:

• (a) request access to Personal Data relating to their child;
• (b) request correction or deletion of such Personal Data;
• (c) withdraw consent for any Processing that is based on consent; and
• (d) request closure of the child’s account.

We do not knowingly engage in direct electronic marketing communications to Children under the age of sixteen (16). Any informational communications relating to a minor Player’s account or use of the Services may be directed to the relevant Parent or Guardian where appropriate and feasible.

Parents and Guardians may exercise the rights described in Sections 7.3 and 14 by (i) accessing and managing the relevant Player account where they have direct access; or (ii) contacting us using the details in Section 19 and specifying the nature of their request. We may take reasonable steps to verify the identity of the Parent or Guardian and their relationship to the minor, which may include, for example, requesting confirmation via a known email address or telephone number associated with the account, requesting copies of identification or guardianship documentation, or using other methods permitted by law. Certain features of the Services may also provide a dedicated parent or guardian view or dashboard; where such features are made available, they may be used to review and manage a minor Player’s information.

Visibility, Discovery and In-Platform Sharing

A key function of the Services is to facilitate controlled visibility of Players to Professional Users for legitimate talent identification and development purposes, across different levels of competition. The degree of visibility may depend on:

• (a) the account type and settings selected by or for the Player or Partner Organisation; and
• (b) the subscription tier and configuration of relevant Professional Users.

Subject to such settings, and in accordance with this Policy:

• (a) certain elements of a Player’s profile, such as name or display name, age bracket, playing position, club or academy affiliation and selected performance metrics, may be made available to authenticated Professional Users within the Services;
• (b) Player Media, Performance Data and AI Outputs may be surfaced in discovery feeds, search results, watchlists and similar features accessible to such Professional Users; and
• (c) Player contact information (such as email address or telephone number) shall not be disclosed in a public or unrestricted manner, but may be made available through controlled mechanisms or mediated contact flows consistent with our safety policies and any applicable law.

Where messaging or contact features are enabled between Professional Users and Players, we may implement safeguards for minors, including restrictions on direct contact, routing communication through Parents or Guardians or Partner Organisations, or monitoring communications for safety, abuse prevention and compliance purposes, to the extent permitted by law.

Professional Users are contractually prohibited from using Player data obtained through the Services for purposes that are unrelated to legitimate scouting, development, recruitment or similar professional use, including any unauthorised scraping, resale, commercial reuse or creation of independent databases. BESEIN reserves the right to suspend or terminate Professional User accounts, and to notify relevant organisations or authorities, in the event of misuse or abuse.

Cookies, SDKs and Similar Technologies

We may use cookies, software development kits (SDKs), web beacons and similar technologies (“Cookies”) in connection with your use of the Services. Cookies enable, among other things, the recognition of your device, the maintenance of your session, the storage of preferences, the collection of usage data and the support of security measures.

Where required by applicable law, we will obtain your consent before placing non-essential Cookies on your device. This will generally be done via a cookie banner or consent management platform presented to you on your first visit to the Services (and periodically thereafter), where you can accept, reject or customise your Cookie preferences. You may also manage your Cookie preferences through your browser or device settings and, where applicable, through in-product consent tools. Disabling certain Cookies may impair the functionality of the Services.

Disclosure of Personal Data to Third Parties

We do not sell Personal Data within the meaning of applicable privacy laws, nor do we share Personal Data with third parties for their independent marketing or advertising purposes.

We may disclose Personal Data to the following categories of recipients for the purposes described in this Policy:

• (a) Service Providers and Vendors. We may engage third-party service providers to perform services on our behalf, including cloud hosting, data storage, analytics, security monitoring, customer support, communications delivery, payment processing and similar services. Such providers are contractually bound to process Personal Data only on our documented instructions and to implement appropriate technical and organisational security measures. We may use, for example, cloud hosting providers, payment processors, analytics providers, communications providers and customer support platforms. Key third-party processors currently engaged by BESEIN include:
  • • Stripe – Payment processing services (Privacy Policy)
  • • Amazon Web Services (AWS) – Cloud hosting and data storage (Privacy Policy)
  • • Google Cloud & Firebase – Authentication, analytics, and app infrastructure (Privacy Policy)
  • • Twilio – Communication and messaging services (Privacy Policy)
  • • Meta (Facebook) – Social authentication services (Privacy Policy)
  • • Apple – Social authentication services (Privacy Policy)
  This list may be updated from time to time as we engage additional partners to support our Services.
• (b) Partner Organisations and Professional Users. To the extent necessary for the operation of the Services, we may disclose relevant Player data to Partner Organisations and Professional Users in accordance with the visibility settings, account configuration and this Policy. Such recipients are contractually or legally obligated to use Personal Data obtained via the Services solely for legitimate, authorised purposes and to maintain appropriate confidentiality and security.
• (c) Affiliates. We may disclose Personal Data to our subsidiaries, parent company or other affiliated entities, provided that such entities process Personal Data in a manner consistent with this Policy.
• (d) Corporate Transactions. In the event of any merger, acquisition, reorganisation, sale of assets, financing or similar corporate transaction involving BESEIN, Personal Data may be transferred to one or more third parties as part of the transaction, subject to obligations ensuring a level of protection consistent with this Policy.
• (e) Legal and Regulatory Disclosures. We may disclose Personal Data where we believe such disclosure is required or appropriate: (i) to comply with applicable law, regulation, legal process or governmental request; (ii) to enforce our Terms of Use or other contractual rights; (iii) to protect the rights, property or safety of BESEIN, our users or the public; or (iv) to detect, prevent or address fraud, security, safety or technical issues.
• (f) Child Protection and Vital Interests. We may disclose Personal Data where we reasonably believe that there is a risk of harm to a Child or another person, including to child protection agencies, law enforcement authorities or other appropriate bodies, in order to comply with our legal obligations or to protect vital interests.

International Transfers

BESEIN is headquartered in the United States and the primary processing and storage of Personal Data may occur in the United States and other jurisdictions which may have data protection laws that differ from those in your country of residence.

Where the GDPR, UK GDPR or similar laws apply to the transfer of your Personal Data to countries outside the European Economic Area (“EEA”) or the United Kingdom, we will implement appropriate safeguards for such transfers, which may include, without limitation, reliance on the Standard Contractual Clauses adopted by the European Commission in Decision (EU) 2021/914, the UK International Data Transfer Addendum or International Data Transfer Agreement, or any successor instruments or other lawful transfer mechanisms recognised under applicable law from time to time.

Further information regarding the safeguards used for international transfers may be requested using the contact details set out in Section 19.

Data Retention

We retain Personal Data for no longer than is reasonably necessary to fulfil the purposes for which it was collected or for which it is further processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, and in accordance with our internal retention policies.

Without prejudice to the generality of Section 12.1:

• (a) Account and profile data will generally be retained for the duration of your active account. Following closure of your account, we will retain account and profile data for a period of up to three (3) years, to the extent necessary for record-keeping, the establishment, exercise or defence of legal claims, and compliance with legal obligations, after which it will be deleted or irreversibly anonymised.
• Player Media, Performance Data and AI Outputs will generally be retained while the relevant account remains active. Upon closure of the account, or upon a valid erasure request, Player Media, Performance Data and AI Outputs will be retained for a period of no longer than twenty-four (24) months, unless a longer period is required by law or is necessary for the establishment, exercise or defence of legal claims, after which such data will be deleted or irreversibly anonymised.
• (c) Usage, technical and log data (including security and diagnostic logs) will generally be retained for a period of between twelve (12) and twenty-four (24) months from the date of collection, unless a longer period is required for security, fraud-prevention or legal compliance purposes, after which such data will be aggregated or anonymised.

We may retain aggregated, anonymised or de-identified data indefinitely, as such data does not identify any individual.

Security of Personal Data

We implement and maintain appropriate technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access and other forms of unlawful Processing. Such measures include, as appropriate, encryption in transit, access controls, role-based permissions, secure development practices, monitoring and logging, vulnerability management and incident response procedures.

While we endeavour to protect Personal Data, no system or transmission of data over the internet is completely secure. We therefore cannot guarantee the absolute security of Personal Data. To the extent permitted by applicable law, our responsibility for any security incident will be determined in accordance with applicable legal standards and our contractual obligations.

You are responsible for maintaining the confidentiality of your account credentials and for restricting access to your devices. You should notify us promptly if you become aware of any unauthorised access to, or use of, your account or any other security incident.

In the event of a Personal Data breach, we will take all steps that we consider reasonably appropriate to mitigate its possible adverse effects. Where required by applicable law, we will notify the relevant supervisory authorities without undue delay and, where feasible, not later than seventy-two (72) hours after becoming aware of the breach, and we will notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

Rights of Data Subjects

General Rights

Irrespective of your location, you may, subject to applicable law:

• (a) access and review certain Personal Data via your account settings;
• (b) update, correct or complete your Personal Data where it is inaccurate or incomplete;
• (c) close your account, in which case we will handle the resulting deletion or anonymisation of your Personal Data in accordance with Section 12; and
• (d) opt out of marketing communications by following the instructions in such communications or by contacting us.

Rights under GDPR and UK GDPR

Where the GDPR or UK GDPR applies and BESEIN acts as Controller, you may have the following rights, subject to the conditions and limitations set out in law:

• (a) the right of access to your Personal Data;
• (b) the right to rectification of inaccurate Personal Data;
• (c) the right to erasure of your Personal Data in certain circumstances;
• (d) the right to restriction of Processing;
• (e) the right to data portability in relation to Personal Data you have provided to us;
• (f) the right to object to Processing based on our legitimate interests, including profiling; and
• (g) the right to withdraw consent at any time where Processing is based on consent, without affecting the lawfulness of Processing carried out before such withdrawal.

You also have the right to lodge a complaint with a competent supervisory authority in the EEA or the UK, including, for example, the supervisory authority in the Member State or the UK where you have your habitual residence, place of work or place of the alleged infringement. Details of supervisory authorities are available on the website of the European Data Protection Board and the UK Information Commissioner’s Office. If we appoint an EU or UK representative or designate a lead supervisory authority, details will be published on our website or in a supplemental notice.

Rights under California Privacy Law

Where the CCPA/CPRA applies, California residents may have rights including:

• (a) the right to request that we disclose certain information about our collection, use and disclosure of their Personal Data;
• (b) the right to request deletion of Personal Data, subject to statutory exceptions;
• (c) the right to request correction of inaccurate Personal Data; and
• (d) the right to be free from unlawful discrimination for exercising any privacy rights.

BESEIN does not sell Personal Data and does not share Personal Data for cross-context behavioural advertising as those terms are defined under California law. Because we do not sell Personal Data or share Personal Data for cross-context behavioural advertising, we do not provide a “Do Not Sell or Share My Personal Information” opt-out mechanism at this time. If our practices change in the future, we will update this Policy and, where required, provide a dedicated “Do Not Sell or Share My Personal Information” link or page and honour any opt-out requests.

Rights under Canadian Law (PIPEDA)

Where PIPEDA or substantially similar Canadian privacy law applies, individuals in Canada may have the right to:

• (a) request access to Personal Data that we hold about them and obtain information about how that Personal Data has been used and disclosed;
• (b) request correction of inaccurate or incomplete Personal Data;
• (c) withdraw consent to the Processing of Personal Data where Processing is based on consent, subject to legal and contractual restrictions; and
• (d) lodge a complaint with the Office of the Privacy Commissioner of Canada or a relevant provincial privacy commissioner.

We will respond to such requests in accordance with applicable Canadian law and may require verification of identity before responding.

Exercise and Verification

Requests to exercise rights may be submitted using the contact information in Section 19. We may take reasonable steps to verify your identity and, where applicable, your relationship to a minor or another individual, before responding to a request. In certain circumstances, we may be unable to fully comply with your request where an exception or limitation applies under applicable law; in such cases we will provide an explanation.

Third-Party Services, Links and Content

The Services may contain links to, or integrations with, third-party websites, applications or services that are not owned or controlled by BESEIN. This may include, for example, social media platforms, mapping or geolocation services and third-party content.

This Policy does not apply to such third-party services, and we are not responsible for the privacy, security or practices of any third party. Your use of third-party services is governed by the terms and privacy policies of the relevant third party. We encourage you to review such policies before providing Personal Data to third parties.

“Do Not Track” and Similar Signals

Certain browsers or devices may enable you to send “Do Not Track” signals or similar mechanisms to indicate your preference that your online activities not be tracked. The Services do not currently respond to such signals. However, you may manage certain tracking technologies through your browser and device settings and, where required, through in-product consent tools.

Changes to this Policy

We may amend or update this Policy from time to time to reflect changes in our Processing activities, the Services, legal requirements or technological developments.

When we make material changes to this Policy, we will update the “Effective Date” at the top of the Policy and will provide additional notice, such as by email or an in-Service notification, where required by applicable law.

Your continued use of the Services after the effective date of any updated Policy constitutes your acceptance of the updated Policy. If you do not agree with any changes, you should discontinue use of the Services and may request closure of your account.

Relationship to Other Terms; Governing Law

This Policy forms part of, and is incorporated by reference into, the BESEIN Terms of Use or equivalent contractual terms applicable to your use of the Services. In the event of any conflict or inconsistency between this Policy and the Terms of Use regarding the handling of Personal Data, this Policy shall prevail.

Subject to any mandatory provisions of applicable data protection law, this Policy and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the laws of the State of Delaware, United States of America, without giving effect to any choice or conflict of law provision or rule.

Contact Details

If you have any questions, concerns or requests in relation to this Policy or our Processing of Personal Data, you may contact us as follows:

BESEIN Technologies LLC

Email: play@beseinsports.com

Website: https://beseinsports.com

Where required by applicable law, we may appoint a Data Protection Officer, EU representative, UK representative or other designated contact. Details of any such appointment will be made available in an appropriate notice or supplement and, where applicable, on our website.