Privacy Policy
1. Who we are
The Talent ID service is operated by Talent ID LLC (name pending registration), established in Ukraine. Privacy contact: privacy@talent-id.org. This policy is our APP privacy policy under Australian Privacy Principle 1 of the Privacy Act 1988 (Cth); we handle the personal information of people in Australia in line with the Australian Privacy Principles (APPs).
2. What information we collect
Adult users: name, email, mobile number, role, organisation, settings, sign-in logs; if you sign in with Google — the name and email from your Google account (we never receive your Google password); a log of account use (which sections were opened — without their content).
Children (players): name, date of birth, squad, anthropometry (height, weight), test results, coach ratings, medical clearance and check-up dates, wellbeing (a daily check-in, including whether something hurts), recommendations from the coach or the academy doctor (without diagnoses), psychological test results (only with separate parental consent), attendance and training load, readings from the club's sports devices (distance, speed, heart rate during training), tags on training and match videos (only with separate parental consent). A child's information is entered by the club or the parents; parents of a child without a club may keep a short profile themselves (year and quarter of birth, city, height, weight, 30 m sprint, preferred foot).
We do not collect: medical records, diagnoses, photos of children in profiles, biometric information for identification.
Technical: IP address, device type, cookies (see the Cookie Policy).
Wellbeing and clearance information is health information — sensitive information under the Privacy Act — and is collected only with consent.
3. Purposes and legal bases
Providing the service under a contract with an academy, club or school; parental consent — for children's information and for each separate profile disclosure; security and abuse prevention; legal obligations — accounting and lawful requests from authorities. We collect only information reasonably necessary for these purposes (APP 3) and use or disclose it only for the purpose it was collected for or as otherwise permitted by the APPs (APP 6). As the operator is established outside Australia, the Law of Ukraine «On Personal Data Protection» (No. 2297-VI) also applies to our processing. You may deal with us without identifying yourself only where that is practicable — an account requires your name and contact details.
4. Children's information
Children do not have their own accounts. A child's information is processed only with the consent of a parent (legal guardian). The Privacy Act does not set a fixed age at which a child can consent; the OAIC's guidance is that capacity is assessed case by case. Talent ID applies a stricter rule: all consents for a child's information are given by the parent, whatever the child's age (under 18). Once the OAIC registers the Children's Online Privacy Code under the Privacy and Other Legislation Amendment Act 2024, we will apply it. Parents can see the child's information in their account and correct it, download a full copy at any time («My data») or withdraw consent. We do not use children's information for advertising, direct marketing or advertising profiles. Selection decisions are made by the coach — the service only shows calculations.
5. Who we share information with
Coaches and management of your organisation — within their role. Other clubs and academies — only with separate parental consent for each specific request. The football federation or state member federation — if your academy has connected the data exchange and registered the child: only full name, date of birth, academy and squad, position, city and registration number (in return, official match reports are added to the profile); tests, health, family and contacts are not shared. Your academy's own systems via the open API (Elite package) — only if the academy's management has created an access key: full name, date of birth, squad, position, measurements and attendance of that academy's players, read-only (health, wellbeing, family and contacts are not shared); the key can be revoked at any time, every request is logged (30 days). Anyone you yourself send a link to the child's development passport (created by parents only, valid for 7 days, can be revoked): full name, year of birth and age, position, academy and squad, medical clearance status, attendance over 90 days, games and latest measurements — without contacts and without other children's information. A scout or club the academy sends a link to a playlist of video clips (only with the separate parental consent «Clips for scouts and clubs», up to 30 days, parents are notified, can be revoked): full name, year of birth, position and clips featuring the child; a clip plays from the match recording in the academy's video service, so the recipient can technically watch the whole recording. Advertisers — nothing except the number of parents (fewer than 20 is not shown). Service providers under contract: hosting and database in the EU (Ireland, Supabase); content delivery, the «human, not a bot» check and storage of match files in the EU (Cloudflare); an email service; an SMS service for the phone verification code; Google — only if you choose to sign in with Google; a server that detects moments in match videos (Modal, USA) — it receives a match recording only for the time of the analysis and does not keep it; payment services — card data never reaches us. Authorities — only where required or authorised by law.
6. Retention
Account — while it is active, and 30 days after a deletion request. Player information — while the child is at the club and up to 3 years after leaving, for the development history, unless the parents ask to delete it earlier. Original match recordings — 30 days (tags and clips — while the child is at the club). Website error log — 30 days. Account usage log and visit statistics — 13 months. Security logs — 12 months. Payment records — for the periods required by tax law. After that, information is destroyed or de-identified (APP 11.2).
7. Your rights
You can ask for access to the personal information we hold about you and for its correction (APPs 12 and 13), ask for a copy in a machine-readable format, ask us to delete it, and withdraw consent at any time. We reply to requests within 30 days; access is free. If you have a privacy complaint, write to privacy@talent-id.org first — we will respond within 30 days. If you are not satisfied, you can complain to the Office of the Australian Information Commissioner (www.oaic.gov.au, 1300 363 992). You can also complain to the Ukrainian Parliament Commissioner for Human Rights. Most actions are available in your profile: «Language, theme and data».
8. Security
Encryption in transit and at rest, access separation at database level, two-factor sign-in with an authenticator app (available to everyone, recommended for academy management), review of new sign-ups by an administrator, access logs, daily backups, a security review before launch (APP 11). If a data breach is likely to result in serious harm, we will notify you and the OAIC under the Notifiable Data Breaches scheme.
9. International transfers
Talent ID's database is hosted in the European Union (Ireland) and the operator is established in Ukraine, so your information is held and processed outside Australia — in Ireland and other EU countries, in Ukraine and, for video analysis and Google sign-in, in the USA. Before disclosing information overseas we take reasonable steps to ensure the recipient handles it consistently with the APPs (APP 8), using contractual safeguards (EU Standard Contractual Clauses). The EU's General Data Protection Regulation (GDPR) applies to the hosting.
10. Changes
We will announce material changes by email and in the service at least 14 days in advance.