Effective as of March 2022
We respect your privacy and it is important to us. We are Pllinx Ltd (we, our, or us).
We operate the Pllinx platform which links global recruitment agencies (Recruiters) with college coaches (Coaches) with an aim of enhancing the recruitment process. Student athletes (Student Athletes) are invited to join the platform by their Recruiter, allowing Student Athletes to connect with Coaches. Coaches are able to search, connect, follow, message and short-list Student Athletes. Recruiters and their Student Athletes who are seeking sport scholarships may use the App to provide relevant information for the purposes of engaging with Coaches.
What Information We Collect
We collect information from you when you set up an account with us and you voluntarily submit your details and information to us in your use of the App and Portal. This can include information you provide when you register to use the App, upload content, complete a form, subscribe to our mailing lists or other marketing communications or take an action on the App or Portal (such as when you upload photos or videos, perform a search, communicate with other users of the App or Portal users).
We also collect information about the pages you look at on our App and Portal and/or the device you use to access them.
We collect and use information to operate our App and Portal and to deliver our services, as well as to provide useful updates and other information about our services. In this context, we are a ‘data controller’.
We have set out below the information we may collect, use, store and transfer:
- Contact data of Coaches, Recruiters and Student Athletes and their parents/guardians including name, address, country of residence, email address and telephone numbers.
- Identity data of Coaches, Recruiters and Student Athletes and their parents/guardians, including your name, username, title, and for Student Athletes, information relevant to sports scholarships, including your date of birth, gender, height, weight, graduation year, college entrance exam scores, grade point average, sporting achievements, academic information and social media accounts and usernames.
- Transaction data for Coaches and Recruiters, including details about payments made and other details of services purchased when paying for a subscription.
- Technical data including information about use of our App and Portal, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, screen resolution and other technical characteristics of your device, your use of our services and applications and connection to our App or Portal.
- Profile data including usernames and passwords, preferences, including sport preference data, feedback and survey responses.
- Usage Dataincluding information about your visit, the path that you take through and from the App or Portal (including date and time); pages that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Marketing and communications data including preferences in receiving marketing from us and third parties and communication preferences.
- Aggregated data such as statistical or demographic data. Aggregated data may be derived from your information but is not considered ‘personal data’ in law as it does not reveal your identity. However, if we combine or connect such data with your information so that it can directly or indirectly identify you, we will apply this policy to such combined data.
We do not knowingly collect any special categories of personal data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data (other than your height and weight and any fitness statistics you may voluntarily choose to upload as a student athlete for coaches to view) or information about criminal convictions and offences.
Information relating to children
The Portal and App are not intended for children under the age of 13. We do not knowingly collect data from anyone under the age of 13. In the event we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible.
If you are under 18 years old (a Student Athlete Young User) you need to make sure you have your parent’s or guardian’s permission to use our App and to provide us your personal information. Please also read our Student Athlete Young User’s Privacy Notice for information about how we collect and use information about you.
How we collect your information
We use different methods to collect data including through:
Information you provide to us directly.
Recruiters: you may give us details such as your name, email address and title when you set up an account to use our Portal. You may also give us names and email addresses of your Student Athletes for whom you set up a profile (Profile) to use the App which may also include their eligibility, grade point average, recruiting class and sport and other information relevant to their sporting and academic details.
Coaches: you may give us your name, email address, title and information about your sports program, including without limitation, team videos, introductory videos for the purposes of introducing Student Athletes to the university, coach biographies, team statistics, links to team rosters and the program’s sporting successes.
Student Athletes: when you use our App, you may give us your personal details when you put information into your Profile, such as your username, email address, telephone number. date of birth, nationality, gender, parents’ names and email addresses, height, weight, high school, graduation year, college entrance exam scores, grade point average (GPA), academic information and sporting achievements, sport and position played, and social media accounts and usernames.
Parents or guardians of Student Athletes: you may give us your name, email address, address and telephone number so that you can use the App to view your child’s activity on the App and to see when Coaches contacts your Student Athlete in connection with a sports program.
Users of our App or Portal may also give us information in person, or by filling in forms on our Portal or by corresponding with us by post, phone, email, social media and/or otherwise. This includes information provided when you
- request our services;
- contact one of our staff;
- are introduced to one of our staff by another contact;
- participate in an event which we have attended or organised;
- contact us via our App or Portal;
- subscribe to our publications or newsletters;
- request information to be sent to you;
- request support;
- respond to a survey, promotion or competition;
- contact us about, or apply for, a role with us; and
- make a complaint or give us some feedback
Information provided by social networks you connect or link to our App: If as a Student Athlete you choose to connect your Profile to an account on a social network, such as Facebook, Twitter or Instagram you are consenting to us collecting personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, Facebook id, Twitter handle, profile picture, gender, username, user ID, age or age range, language, country, friends list, follower list and any other information you have agreed it can share.
Why we collect and use your information
We will only collect and use information when the law allows us to. Most commonly, we will use your information so we can provide our services, for marketing and if required by law.
Type of data
Lawful basis for processing (including basis of legitimate interest)
To register you as a new or prospective user and to deliver services to you
(c) Marketing and Communications
(a) Performance of a contract with you
To manage our relationship with you, which may include
(b) Asking you for feedback or to take a survey
(a) Performance of a contract with you
To administer and protect our business, App and Portal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant content and measure or understand the effectiveness of such content
Necessary for our legitimate interests (to study how users use our App and services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our App, Portal, services, marketing and customer relationships and experiences
(a) Necessary for our legitimate interests (to define types of users for our App and Portal, to keep our App and Portal updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To process a job application and keep you informed of employment, freelance, contractor or other opportunities
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to recruit good candidates for our business)
Where we need to collect information by law, or under the terms of a contract and you do not provide the information when requested, we may not be able to perform the contract. In this case, we may have to cancel a service you have with us but we will notify you of this at the time.
How we use your information
Most commonly, we will use your information:
- Where we need to perform the contract we are about to enter into or have entered into with you;
- Where it is in our legitimate interest to do so (or those of a third party) and it is proportionate to do so;
- Where we need to comply with a legal or regulatory obligation.
Change of use
We will only use your information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at: firstname.lastname@example.org
If we need to use your information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Who we share your information with & why
We may share your information with others, particularly those that help us run our business effectively. We require others to respect the information we share with them, and to only use it in ways the law allows. We only allow others to use such information for the specific purposes we set out, and not for any other purposes.
- Information available to other users of the App and Portal
The App and Portal are designed to help Student Athlete (and their Recruiters) to connect and interact with Coaches and as a result some of the information generated through the App and Portal is shared with other users as follows:
- As a Student Athlete your Profile will be visible to Coaches, your Recruiter (but not other recruiters), your parents and other Student Athletes. You, your parents/guardians and your Recruiter will be notified when a Coach follows or shortlists you and when they message you directly. Such activity is not visible to other users and other users cannot contact you through the App.
- As a Coach, Student Athletes and their parents/guardians and Recruiters can view the information you post about you/your sports program in the App. Student Athletes can message you in the App, but other users cannot.
- Third Parties
We may have to share information with third parties (including those below) for the purposes set out in the table above:
- Within our organisation (i.e. our directors, staff and contractors)
- Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, third parties who host, store and manage data or provide programming or technical support, etc.
- Professional advisers including our accountants, insurers and brokers, etc.
- Analytics partners to analyse Portal traffic and understand customer needs and trends.
- Marketing service providers to help us to communicate with you.
- If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our App and Portal or customers.
- Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.
We will share information, without notice, only if we are required to do so by law or we, in the good faith, believe that it is necessary to:
- comply with legislation or any legal process served on us;
- protect and defend our rights and/or property; and
- to protect personal safety.
We do not give or provide in any other way your data or any customer lists to third parties.
Personal information we collect may be stored in or transferred to countries (including to the USA) outside of the country where you live, including outside the UK or European Economic Area (EEA). This is particularly the case for Student Athletes, as most Coaches that you interact with are in the US. It also includes companies within our group and to third-party service providers. It may also be processed by staff (who work for us, or for one of our suppliers), and other users of the App or Portal (including Coaches and Recruiters) operating outside the EEA, in order to interact with you, to fulfil a purchase, process payment details and provide support and verification services. Whenever we store or transfer personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer information to countries that have been deemed to provide an adequate level of protection for personal data by the UK and European Commission.
- Where we use certain service providers, we may use specific contracts approved by the UK and European Commission which give information the same protection it has in the UK and Europe.
- Where we use services providers in the US, we may transfer data to them if they have agreed to the Standard Contractual Clauses, which requires them to provide similar protection to personal information shared between the EEA and UK and the US.
Third-party links and services
How we protect your information
We take steps to keep your information secure and we delete it when we no longer need it.
Security of your personal data
We have put in place appropriate security measures to prevent information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to information to those of our staff and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will retain information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we process the information and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you have an account with us your personal information will be kept by us for as long as your account remains active. If you deactivate your account, your personal information will be kept for a reasonable period of time after this so that we can complete any activities already initiated or where we have a need to retain your personal information for legal or technical reasons (including back-up systems). Following this period we will either delete the information or change it to a form that does not identify you.
You can choose whether to receive marketing from us and you can ask us what information we have about you. Your rights are set out below.
- Opt Out Rights
You may, at any time opt-out of receiving certain types or all communications from us by contacting us: email@example.com or selecting the “unsubscribe” option in any e-communication from us.
- Other Legal Rights
You have the right to:
- Request access. This means you can ask us to give you a copy of the information we hold about you.
- Request correction. This means if we have incomplete or inaccurate information, you can ask us to correct it. It is important that the information we hold about you is accurate and current. Please keep us informed if the information you provide us changes as our relationship evolves. Note, we may need to verify the accuracy of the new data you provide to us.
- Request erasure.This means you can ask us to delete or remove any information we have if there is no good reason for us continuing to have it. You also have the right to ask us to delete or remove information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing. This means you can contact us if you feel our use of your information impacts on your rights and freedoms. This applies if we are: (a) relying on our legitimate interest (or those of a third party) to use your information; (b) if we are using your information for direct marketing purposes; (c) if you believe we are using your information unlawfully; or (d) where we need to erase you information to comply with local laws. It is unlikely, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction. This means you can ask us to suspend using your information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer. This means you can ask us to transfer the information we hold on you to you, or to a third party. We will provide to you, or the third party you have chosen, your information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
- Withdraw consent. This means you can tell us that you no longer consent to our use of your information at any time where we are relying on consent to process your information. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Note that this will only apply to any information where we were previously relying on consent as the legal basis to use your information. This action will also not affect the lawfulness of any processing carried out before you withdraw your consent
What we may need from you
We may need to request specific information from you to help us confirm your identity and your rights in relation to your request. This is a security measure to ensure that information is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
No fee usually required
You will not have to pay a fee to exercise the rights listed above. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally, it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How to contact us
The App and Portal are run by Pllinx Ltd, a company established in Scotland (company number SC702880) and whose registered office is at 10 Newton Terrace, Charing Cross, Glasgow, G3 7PJ, United Kingdom. If you have any questions about this policy, please do get in touch at firstname.lastname@example.org