Data Processing Annex

This Data Protection Annex forms part of the Subscription Agreement and relates to the processing of personal data when using the Platform.

The Annex is agreed between SportsFi (company number 13839769, 71 Queen Victoria Street, London EC4V 4BE, UK) and the contracting User entity. SportsFi processes Personal Data on behalf of the User acting as Processor where applicable.

Terms include Controller, Processor, Data Subject, Personal Data, Personal Data Breach, Platform, User Data, Sub-Processor, and Data Protection Law (including GDPR, UK GDPR, DPA 2018, PECR and applicable regulatory or court pronouncements).

In case of conflict, this Annex prevails for personal data processing obligations.

The User is expected to act as Controller and SportsFi as Processor in relation to User Data. Each party remains responsible for applicable compliance duties and must cooperate where required.

SportsFi and the User may each act as Controller for contact data used to administer access, billing, support, legal compliance and relationship management.

For User Data processed on behalf of the User, SportsFi will process only on documented instructions (unless legally required otherwise), maintain confidentiality, implement security measures, support data-subject rights, support incident response, and return/delete User Data at the end of services unless law requires retention.

SportsFi has general authorisation to appoint sub-processors subject to prior notice, opportunity to object, and data-processing terms that are no less protective than this Annex.

SportsFi states that User Data is not transferred outside the UK/EU. If this changes, SportsFi will implement appropriate transfer safeguards and cooperate with the User for compliance.

Processing purpose: operation of the Platform for football player acquisition/transfer workflows, deal management, and financing support. Data categories include contact data and player transaction-related data. Retention is limited to what is necessary for service and legal obligations.