Privacy Policy
1. Who we are
The Talent ID service is operated by Talent ID LLC (name pending registration), established in Ukraine, the data controller. Data protection officer: privacy@talent-id.org. We process the personal data of data subjects in Ghana in line with the Data Protection Act, 2012 (Act 843); before launch we will register with the Data Protection Commission as a data controller (section 27) and renew the registration as the Act requires.
2. What data we process
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, team, 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 data 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 process: medical documents, diagnoses, photos of children in profiles, biometrics for identification.
Technical: IP address, device type, cookies (see the Cookie Policy).
Wellbeing and clearance data are health data, and the data of a child under parental control is special personal data under section 37 of Act 843 — they are processed only with the consent of a parent or legal guardian.
3. Purposes and legal bases
Providing the service under a contract with an academy, club or school; consent of a parent or legal guardian — for children's data and for each separate profile disclosure; legitimate interest — security and abuse prevention; legal obligations — accounting and lawful requests from authorities. These are lawful bases under Act 843; for special personal data — consent under section 37. We collect only the data that is adequate, relevant and limited to these purposes. As the operator is established outside Ghana, the Law of Ukraine «On Personal Data Protection» (No. 2297-VI) also applies to our processing.
4. Children's data
Children do not have their own accounts. The personal data of a child (a person under 18, as under the Children's Act, 1998 (Act 560)) is special personal data under section 37 of Act 843 and is processed only with the consent of a parent or legal guardian; we take reasonable steps to verify that consent. In every decision the best interests of the child come first (Children's Act, 1998, section 2). Parents can see the child's data in their account and correct it, download a full copy at any time («My data») or withdraw consent. We do not use children's data for advertising and do not build advertising profiles. Selection decisions are made by the coach — the service only shows calculations; no decision that significantly affects a person is based solely on automated processing (Act 843, section 41).
5. Who we share data with
Coaches and management of your organisation — within their role. Other clubs and academies — only with separate parental consent for each specific request. The Ghana Football Association (GFA) or its regional football association — if your academy has connected the data exchange and registered the child: only full name, date of birth, academy and team, 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, team, 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 team, medical clearance status, attendance over 90 days, games and latest measurements — without contacts and without other children's data. 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). Data processors under written contracts that oblige them to apply security measures (Act 843, section 30): 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. We never sell personal data. Authorities — only on a lawful basis.
6. Retention
Account — while it is active, and 30 days after a deletion request. Player data — 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 documents — for the periods required by tax law. Data is not kept longer than necessary for the purposes for which it was collected.
7. Your rights
Under Act 843 you have the right to be informed, to access your data and get a copy (sections 32 and 35), to have it corrected or deleted (sections 33 and 44), to prevent processing that causes damage or distress (section 39), to stop direct marketing (section 40), not to be subject to a decision based solely on automated processing (section 41), and to withdraw consent at any time without affecting the lawfulness of earlier processing. You can also download your data in a commonly used, machine-readable format. We reply to requests within 30 days. If you are not satisfied with our answer, you can lodge a complaint with the Data Protection Commission (dataprotection.org.gh). 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 (Act 843, section 28). If personal data has been accessed or acquired by an unauthorised person, we will notify the Data Protection Commission and the persons concerned as soon as reasonably practicable after the discovery (Act 843, section 31).
9. International transfers
Talent ID's database is hosted in the European Union (Ireland) and the operator is established in Ukraine, so your data is transferred outside Ghana — to Ireland and other EU countries, to Ukraine and, for video analysis and Google sign-in, to the USA. Wherever it is stored, your data remains protected in line with Act 843, and we tell you about these transfers before you give consent. Transfers are made only to recipients bound by written contracts that ensure an adequate level of protection — including the EU Standard Contractual Clauses and the EU's General Data Protection Regulation (GDPR), which applies to the hosting. We keep a record of the basis for each transfer.
10. Changes
We will announce material changes by email and in the service at least 14 days in advance.