This Privacy Policy (“Privacy Policy”), is an integral part of our Terms of Use ("Terms"), and governs the collection, processing, usage and transfer of Personal Data by Sports Matching Services Limited (“LEAP”, "we", “us” or “our”) in connection with: (i) visitors of our website available at: https://www.playleap.io/; (ii) users accessing and using our Leap Platform and Leap Services, and whether you are a talent (anyone playing any sports at any level, “Talent”) or fan, sport agent, recruiter, sports brands, clubs, teams and professional (collectively "Explorer") or a legal guardian of the aforesaid (hereinafter defined as a "Parent", and together with the Talent, Explorer and visitors of our website shall be collectively referred to herein as a “user” or “you”).
Any capitalized terms not defined herein shall have the meaning ascribed to them in the Terms. For the purpose of this Privacy Policy, our website, the Leap Platform and the Leap Service will be collectively referred to as the "Leap Services")
This Privacy Policy further explains how you can exercise your rights related to your Personal Data, in accordance with the laws and regulations applicable to you (which may include for example the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
In the event you are a California resident and the CCPA applies to you – please make sure to review our CCPA Privacy Notice to learn more about our privacy practices with respect to the CCPA.
In the event you are a Parent or a child, please see our Children and Parents Privacy Notice that provides further explanation regarding our data collection related to children.
If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Policy, please email us at: support@playleap.io.
Please note, that our Leap Services may contain links to other websites, products or third parties' digital assets or communications, which are not governed by this Privacy Policy. This Privacy Policy does not apply to the practices of entities or any third parties which are not controlled by LEAP.
TABLE OF CONTENTS:
1. DATA CONTROLLER & DATA PROTECTION OFFICER:
Sports Matching Services Limited incorporated under the laws of Cyprus is the controller of your Personal Data.
You may contact us and our privacy team, as follows:
Apsis building Floor 4 Flat 8
Themidos Larnaca 6057
Larnaca
Cyprus
2. THE DATA WE COLLECT:
Depending on your interaction with us, meaning if you browse our website or if you register to our Leap Platform or use our Leap Services, LEAP collects two types of data:
"Non-Personal Data":
Meaning, information which does not identify a specific natural person and cannot reasonably be used for such identification, and for example anonymized and aggregated data. We collect Non-Personal Data regarding use of the Leap Services, such as the scope, frequency, latency, pages accessed and viewed, time and date you have accessed the Leap Services, interactions with content and materials displayed through our Leap Services, language preference, and other technical information regarding the device used to access the Leap Services, for example type of device, type of browser, operating system, etc.
Non-Personal Data is used mainly for click stream analysis in order to maintain and develop our Leap Services, including among others, in order to measure and understand the level of engagement with the Leap Services, for general business analytics for ensuring the technical functioning of our network, to help prevent fraudulent use of the Leap Services and for developing new Leap Services and features.
“Personal Data”:
Meaning, information which identifies or can be reasonably used to identify an individual, and for example your name, phone number, email address, pictures, unique online identifiers etc.
Personal Data Processed by LEAP:
The types of Personal Data collected directly from you or your device through your access and use of the Leap Services are listed below. As explained under this Privacy Policy, some types of Personal Data are required for your use of the all Leap Services (for example, information provided through registration), some types may be required solely for certain features you decide to use, and some are optional, and subject to your discretion (for example, your User Generated Content such as videos, etc.).
Data provided or collected through registration and creation of your Leap Account (including from or of Parents and the child they are registering to the Leap Platform or otherwise approving registration, as applicable):
Data provided when you create and operate your Leap Profile:
Data we collect automatically from your device (including through our use of third parties tracking technologies and cookies):
Electronic activity data associated with your Online Identifiers including information stored on log files when you access our website and Services, such as your usage of Services, Leap Profiles and pages you interact with, people, groups and content you search on the Leap Platform, interactions made with other users on the public interfaces of the Leap Platform. For more information regarding how we our use of third parties cookies, as well as your choices and controls, please see our Cookies Policy.
Data related to your interactions with advertisements in the App or third-party platforms:
Data we collect when you sign up to receive our newsletter and other promotional materials:
If you choose to sign up to receive our newsletter or other updates and marketing materials, we will request you to provide your contact details such as name and email address.
Data we collect from your communications with us, including support, customer services and other inquiries:
If you choose to contact us through the various means of communications we offer, you will provide us with certain information such as your contact details, for example your name, email address or phone number, as well as additional information you voluntarily choose to provide regarding your inquiry. We may also store the contact history and correspondence with you.
3. HOW LEAP WILL USE YOUR PERSONAL DATA & OUR LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA:
The table below provides detailed information regarding the purpose LEAP collects the Personal Data detailed above, as well as hoe LEAP will use such Personal Data.
In addition, for EU users, we detail our lawful basis for processing your Personal Data, as required under the GDPR. In general, our lawful basis will be one of the following:
Please note that, certain types of Personal Data might be used for multiple purposes, and accordingly will be processed under different lawful basis.
Type of Personal Data
Purposes of Collection & Use by LEAP
LEAP's Lawful Basis
Data provided or collected through registration creation of your Leap Account:
Data provided when you create and operate your Leap Profile:
Geolocation data:
Data we collect automatically from your device:
Creating your Leap Account and Leap Profile, verification and authentication.
We process this data in order to perform our contract with you, meaning, to create and administrate your Leap Account and Leap Profile in order to enable you to use our Services, including, for example, enabling users to register, log in and activate their Leap Account, as well as creating your Leap Profile according to the information you have provided, such as your nickname, profile picture, etc. and display it to other Leap Platform's users.
We rely on our legitimate interest where we use your phone number and email in order to authenticate and verify your identity, as well as to make sure you do not already have a Leap Account, including, in order to send you a verification code once you sign up.
We further rely on our legitimate interest where we collect online identifiers upon you subscription, for authentication purpose, usually within log files upon your registration.
In addition, we will collect a Parent's phone number, email and name in order to comply with our legal obligations, where we are required under applicable laws to obtain the Parent's consent in order to create a child's account and process the child's Personal Data.
Data provided when you create and operate your Leap Profile:
Geolocation data:
Data we collect automatically from your device:
Providing our Services
We process this data in order to perform our contract with you, meaning, to operate, provide and deliver our Services, including, display your User Generated Content, enabling users to connect, interact and communicate with each other, post and enabling users to search relevant positions or candidates, customizing the content displayed (for example, Leap Profiles from the same area), as well as to send our users operational notifications, including push notification through the App and email notifications, etc.
In addition, as part of our Leap Services, we operate and maintain a media channel that can be used and accessed by all Leap Platform's users, to which we may upload your User Generated Content, at our discretion.
Data provided or collected through registration and creation of your Leap Account:
Data provided when you create and operate your Leap Profile:
Geolocation data:
Data we collect automatically from your device (including through our use of third parties tracking technologies and cookies):
Improving and customizing our Service
We rely on our legitimate interest where we use your Personal Data for the purpose of customizing, improving and developing our Services, including, by using your electronic activity data associated with your Online Identifiers to evaluate the technical functionality and availability of the Services, conduct statistical analysis of the usage and functionality (for example which features and content were popular and used or viewed by many users), use your IP address in order to extract your approximate location and customize our content and offers according to your country of location.
Where we collect such data through our use of third-parties' cookies, and where required under applicable laws, we will obtain your consent, which you may withdraw at any time. For more information, please see the Cookies section below.
Data provided or collected through registration and creation of your Leap Account:
Data we collect automatically from your device (including through our use of third parties tracking technologies and cookies):
Geolocation data:
Data related to your interactions with advertisements in the App or third-party platforms
Advertising
We rely on legitimate interest where we process these types of data in order to enable our third party partners to advertise on our App, as well as to measure and optimize the performance of advertising campaigns on our App. Note that. We will not share your data with such third parties, rather enable the display of advertisement relevant to your country, interests, etc.
Where required under applicable laws, we will obtain your consent to share data with third party-advertisers, for example, through cookies used on our website for such purpose. You have the right to withdraw consent at any time.
Data provided or collected through registration and creation of your Leap Account:
Data we collect when you sign up to receive our newsletter and other promotional materials
LEAP's Newsletter, updates and marketing materials
We rely on our legitimate interest where we use your email address , as well as your personal details, for the purpose contacting you with updates and offers relating to our Services that we believe might interest you.
Please note that even if you choose to unsubscribe from receiving our marketing materials, we may still send you operational messages.
Where you voluntarily sign up to receive our newsletter and marketing materials, we process your information based on your consent. You have the right to withdraw consent at any time.
Data provided or collected through registration and creation of your Leap Account:
Geolocation data:
Data we collect from your communications with us, including support, customer services and other inquiries
LEAP's Customer Support and services.
We process this data in order to perform our contract with you, meaning to assist with your inquiry and provide you with the request ed support.
We rely on our legitimate interest where we use your information, including our contact history and communications, in order to improve our Services.
All types of Personal Data collected and stored by LEAP, as set forth above.
To keep our Services safe and secured, prevent malicious behavior and fraud, as well as defend our rights and enforce our policies.
All types of Personal Data collected by LEAP might be further used, under our legitimate interests, to protect and secure our Services and enforce our polices. For example, Online Identifiers can be automatically monitored in order to prevent malicious attacks and fraud. We may further use electronic activity data and User Generated Content in order to track, investigate, log and block users that infringed our policies or reported by other users.
All types of Personal Data collected and stored by LEAP, as set forth above.
Comply with our legal obligations and public interests
Certain types of Personal Data will be used and further stored where it is required for us in order to comply with our legal obligations, including, where required in order to comply with any law enforcement bodies such as binding order. We may further process Personal Data in very limited events, where it is necessary for the purpose of protecting your or third party's life safety and security as well as humanitarian purposes.
4. DO WE USE COOKIES?
Yes, we use cookies and similar technologies. The way in which we, and third parties placing cookies in connection with the Leap Services, use cookies and collect data, is explained in our COOKIES POLICY.
5. DATA SHARING - CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH
LEAP will share Personal Data with third parties, mainly for the purpose of the operation of the Services, as well as to improve, protect and advertise the Services. The circumstances in which LEAP will share your Personal Data, as well as the categories of such third-party recipients, are as follows:
In addition, please note that when you share content on the Leap Platform, such content and your interaction with it will be publicly shared on the Leap Platform and might be shared by other users outside the Leap Platform.
6. RETENTION AND SECURITY OF DATA
In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you will express your preference to opt-out, where applicable.
The criteria used by us to determine our retention periods are as follows:
We may at our sole discretion, rectify or erase information from our systems, without prior notice to you, once we deem it is no longer necessary for such purposes.
We take great care in implementing physical, technical, and administrative security measures that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. You need to remember, however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the full security of data transmitted via our website, and any transmission of your data shall be done at your own risk.
7. DATA TRANSFER
We store Personal Data mainly within cloud services in the EU. . In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union.
8. PERSONS UNDER 13
Please be aware that you may not upload to the Leap Platform any data concerning persons under the age of 13, without appropriate consent of a parent or guardian. If you are a Parent or a child, please see our Children and Parents Privacy Notice.
9. USER RIGHTS
Depending on your jurisdiction, data protection and privacy laws provide you with the ability to exercise certain rights regarding your Personal Data that we process. Please note that, unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements. If you object to the aforesaid collection, use and sharing of data, please immediately cease using the Services and/or Platform.
Where provided under applicable law (such as, within the European Union), you may have the right to ask us to delete Personal Information, subject to applicable exceptions, such as in order to preserve that information for anticipated litigation or demands from a regulator, or some or all of the following rights: the right to obtain information on our use of your Personal Data, the right to obtain a copy thereof, the right of data rectification, the right to data portability, the right to object to processing based on our legitimate interests, the right to restriction of the processing, and the right to withdraw your consent.
To assert any of these rights, please contact us at: support@playleap.io. Note that we may request proof of identity, and we reserve the right to charge fees were allowed by law, such as in circumstances where your request is excessive. In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable law (as is the case in the European Union).
Note that, you may exercise some of your rights independently through your Leap Account, for example, delete you Photos and User Generated Content, review your Personal Data by accessing your Account on the Leap Platform, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the Leap Platform, as applicable to you.
If you are a Parent or a child, please see our Children and Parents Privacy Notice.
10. CHANGES AND UPDATES
We reserve the right to amend this Privacy Policy at any time. As such we recommend that you re-visit this page frequently and review the Privacy Policy for any changes that we may have made. In the event that we made any substantial changes to this Privacy Policy, we will make reasonable efforts to provide you with notification with respect to such changes, if we are required to do so by applicable law. The changes to this Privacy Policy will go into effect as of the date listed in the “Last Updated” heading located at the top of this Privacy Policy.
11. CONTACT US
If you have any questions or concerns regarding privacy issues, or if you wish to be provided with any other information related to our privacy practices, please contact us at:
Sports Matching Leap Services Limited
Apsis building Floor 4 Flat 8
Themidos Larnaca 6057
Larnaca
Cyprus
