Privacy policy
1. Our privacy promise
Crowd Scout is a sports talent-discovery platform built to help athletes showcase sporting ability and be discovered. Privacy and safeguarding are part of the design of the Platform, particularly where children and young people are involved.
This Privacy Policy explains what personal data Crowd Scout International Ltd (“Crowd Scout”, “we”, “us” or “our”) collects and uses, why we use it, who it may be shared with, how long it may be kept, and the rights available to you.
We aim to collect only the personal data reasonably necessary to provide, protect and improve Crowd Scout. We do not treat children’s personal data as a commercial advertising asset. We do not sell personal data.
2. Who is responsible for your data?
Crowd Scout International Ltd is the controller of personal data processed for the Crowd Scout mobile application, website and related services unless we expressly tell you otherwise. This means we decide why and how that personal data is processed.
Privacy questions and data-rights requests can be submitted using the privacy or support contact channel published by Crowd Scout. We may need to verify identity before acting on a request.
3. Children and young people
Crowd Scout is designed to be capable of use by young athletes. Children merit particular protection because they may be less aware of privacy risks, consequences and rights. We therefore apply age-appropriate safeguards and treat the best interests of the child as a primary consideration when processing children’s personal data.
Where the Platform requires parent or guardian involvement, we process information needed to establish and operate that relationship and to route protected interactions appropriately. A parent or guardian must not use that role to undermine a young person’s rights or Crowd Scout’s safeguarding controls.
Where consent is the lawful basis for a particular processing activity involving a child, we will apply the requirements that apply to that consent, including parental authorisation where legally required. We do not rely on parental consent as a blanket basis for every use of a child’s information.
4. Personal data we may process
User Content
Sporting videos, photographs or other content uploaded to the Platform, together with associated metadata needed to store, display and manage that content.
Parent and guardian data
Parent/guardian account and contact information, relationship or approval records, and information needed to operate safeguarding and guardian-controlled workflows.
Scout verification data
Information used to assess identity, age, club or organisational affiliation, invitation or verification status, and records concerning continued eligibility for Scout functionality.
Ratings and interaction data
Performance ratings, permitted reactions, content interactions and related signals used to operate Crowd Scout features such as discovery, rankings or league tables.
Safeguarding, reports and moderation data
Reports, concerns, case records, relevant evidence, moderation decisions, enforcement actions and audit/case events needed to protect users and maintain an accountable safeguarding record.
Terms and consent records
Records showing acceptance of Terms, Privacy Policy, safeguarding requirements, permissions or other choices, including the version accepted and relevant timestamps.
Technical and security data
IP address and server/application logs, authentication and security events, device/app or browser information reasonably required for service operation, security, diagnostics and fraud or abuse prevention.
Support communications
Information you provide when contacting Crowd Scout about an account, technical issue, privacy request, complaint or safeguarding concern.
Deletion and rights-request data
Information necessary to process, evidence and administer account deletion, access, correction, objection, restriction or other privacy-rights requests.
5. Information we do not currently collect for core Crowd Scout use
The production Platform is not designed to require continuous GPS/CoreLocation tracking, access to a user’s address book/contacts, or an advertising identifier for behavioural advertising as part of its core service. Crowd Scout profile location is based on location information such as city or country supplied through the Platform rather than continuous live tracking of a child’s device.
If Crowd Scout later introduces a feature that materially changes these practices, we will assess the privacy and safeguarding impact first and update the relevant notices, permissions and controls before or when the feature is introduced as required by law.
6. Why we use personal data and our lawful bases.
7. Legitimate interests and children
Where we rely on legitimate interests, we consider whether the processing is necessary, whether the purpose could reasonably be achieved in a less intrusive way, and whether the individual’s interests, rights or freedoms override our interests. We apply particular caution where the individual is a child. Examples of our legitimate interests include keeping Crowd Scout secure, verifying trusted roles, preventing misuse, safeguarding users, maintaining service integrity and defending legal rights.
You have the right to object to processing based on legitimate interests. See section 16.
8. Special category and sensitive information
Crowd Scout is not intended to require health, biometric, racial or ethnic origin, religious belief, sexual-orientation or other special-category information as a routine condition of creating a standard athlete profile. A sporting video may nevertheless reveal information about a person from their appearance or circumstances. We do not infer special-category characteristics from sporting videos for advertising or unrelated profiling.
If a future feature genuinely requires special-category data, Crowd Scout will identify an Article 6 lawful basis and an applicable special-category condition before processing it and will provide any additional notice or choice required.
9. Videos, visibility and discovery
An athlete who uploads sporting content is using Crowd Scout so that eligible Platform users can view and evaluate that sporting performance in accordance with the relevant account permissions and product design. Profile information and sporting content may therefore be made visible within Crowd Scout to the audiences permitted by the Platform.
Verified Scouts may use permitted profile attributes and sporting-performance signals to identify athletes who match legitimate scouting criteria. Crowd Scout applies additional safeguards to young athletes and does not provide a general-purpose private messaging system between Scouts and children.
Users should not upload information that is unnecessary for sporting discovery, such as a home address, school timetable, private telephone number or other information that could unnecessarily identify a young person’s routine or precise whereabouts.
10. Location information
Crowd Scout may process location information that a user supplies as part of a profile, such as city and country, so that relevant discovery and search functions can operate. This is different from continuously collecting the precise GPS location of a device.
Crowd Scout’s core production service is not designed to continuously track a child’s live GPS location. If a future feature proposes to use device geolocation, Crowd Scout will assess necessity, granularity, defaults, transparency and safeguarding before introducing it and will provide the controls and notices required by applicable law.
11. Ratings, rankings and profiling
Crowd Scout processes ratings, reactions and profile information to generate or display sporting-performance signals, rankings, league tables and discovery results. This can amount to profiling because information is used to evaluate or organise aspects of sporting performance or interest.
These signals are designed to assist discovery. They are not a professional determination of an athlete’s ability and do not themselves decide whether an athlete receives a trial, contract, scholarship, employment or selection.
Crowd Scout does not use these signals to make solely automated decisions that produce legal effects or similarly significant effects on an athlete. Sporting decisions remain decisions for Scouts, clubs and other relevant people or organisations.
12. Who we may share personal data with
We share personal data only where there is a legitimate operational, safeguarding or legal reason. Depending on the service and circumstances, recipients may include:
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other Crowd Scout users to the extent information is intended to be visible through the relevant Platform feature and account permissions;
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verified Scouts and authorised club or organisational users where necessary for legitimate talent discovery;
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parents or guardians where required by Crowd Scout’s protected-account and safeguarding workflows;
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service providers acting on our instructions, such as hosting/cloud infrastructure, database, authentication, storage, email/communications, security, monitoring, support and other technology providers;
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professional advisers, insurers, auditors or corporate advisers where reasonably necessary;
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law enforcement, courts, regulators, safeguarding bodies or other competent authorities where disclosure is required by law or reasonably necessary to protect a child or another person, investigate suspected criminal conduct, or establish or defend legal rights;
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a purchaser, investor, successor or relevant adviser in connection with a genuine financing, reorganisation, merger, acquisition or sale, subject to appropriate confidentiality and data-protection safeguards.
We do not sell personal data. We do not permit third-party behavioural advertisers to build advertising profiles of children from Crowd Scout activity.
13. Service providers and international transfers
Some technology providers used to operate Crowd Scout may process personal data outside the United Kingdom. Where a restricted international transfer occurs, Crowd Scout will use a lawful transfer mechanism as required by UK data-protection law, such as UK adequacy regulations or appropriate contractual safeguards, together with supplementary measures where necessary.
Users may contact Crowd Scout for further information about the safeguards relevant to their personal data. Our provider arrangements may change as infrastructure evolves; we assess material providers and transfers as part of our data-protection governance.
14. How long we keep information
15. Account deletion
Crowd Scout provides a route to delete an account. Account deletion removes the account from ordinary Platform use and triggers deletion or de-identification of personal data that is no longer required.
Deletion is not an absolute requirement to erase every record immediately. We may retain limited information where necessary for safeguarding, legal compliance, fraud or abuse prevention, security, dispute resolution, enforcement of our Terms, or the establishment, exercise or defence of legal claims.
Where information must be retained, access will be restricted according to its purpose and it will not remain available as an ordinary active profile.
16. Your data-protection rights
Depending on the circumstances and lawful basis, UK data-protection law may give you rights to:
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be informed about how your personal data is used;
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access your personal data and obtain a copy;
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have inaccurate or incomplete information corrected;
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request erasure in circumstances where the right applies;
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request restriction of processing in circumstances where the right applies;
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receive certain information in a portable format where data portability applies;
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object to processing based on legitimate interests, including profiling based on that ground;
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withdraw consent at any time where processing relies on consent, without affecting processing already lawfully carried out;
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raise concerns about automated decision-making where the relevant legal protections apply;
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complain to the UK Information Commissioner’s Office (ICO).
Right to object: where Crowd Scout relies on legitimate interests, you may object to that processing. We will consider the objection in accordance with applicable law and stop processing where the law requires us to do so.
Children have data-protection rights in their own right. A parent or guardian does not automatically own a child’s personal data or privacy rights. We will consider the child’s age, understanding, circumstances and applicable law when handling a request involving a young person.
17. How to exercise your rights
Submit a request through the privacy or support contact channel published by Crowd Scout. Tell us what right you wish to exercise and provide enough information to locate the relevant account or records. We may ask for proportionate evidence of identity or authority where necessary to prevent disclosure to the wrong person.
We will respond within the period required by applicable law. If a request is complex or numerous, the law may permit additional time. We will explain any lawful extension or refusal.
18. Security
Crowd Scout uses technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Measures may include access controls, authentication, encryption where appropriate, logging, secure infrastructure, restricted administrative access, monitoring and incident-response procedures.
No online service can guarantee absolute security. Users should protect account credentials and report suspected compromise promptly.
19. Safeguarding records and disclosures
Safeguarding information is handled on a need-to-know basis. Where Crowd Scout reasonably believes information is necessary to protect a child or another person, investigate suspected abuse or criminal conduct, preserve evidence, or meet a legal duty, we may restrict access, retain relevant records and disclose information to an appropriate authority or safeguarding body.
Safeguarding considerations may justify retaining a limited record after content or an account has otherwise been deleted. Such information is not retained for ordinary marketing or discovery use.
20. Cookies, similar technologies and analytics
Crowd Scout may use strictly necessary technologies and limited first-party or service-operational analytics to authenticate users, maintain sessions, protect security, diagnose faults and understand whether core Platform functions operate effectively. We do not use Crowd Scout activity to support third-party behavioural advertising to children.
Where a technology requires consent under applicable privacy or electronic-communications law, we will request that consent before using it unless an exemption applies. Website cookie information may also be provided through an appropriate cookie notice or preference mechanism.
21. Marketing
Crowd Scout will not send electronic direct marketing where consent or another legal condition is required unless that condition has been met. Users can use any unsubscribe or preference control provided. Operational, security, safeguarding and service messages are not marketing and may still be sent where necessary to administer the Platform.
22. Future commercial and digital-asset features
Crowd Scout may in future introduce commercial features, including digital collectibles, tokenised assets or NFTs. Before processing personal data for a materially new purpose, we will assess the lawful basis, transparency, children’s safeguards, financial or regulatory implications, data sharing and international transfers. Additional privacy information and choices will be provided where required.
The existence of a future commercial feature does not give Crowd Scout ownership of an athlete’s personal data, identity or underlying User Content. Content ownership and commercial rights are addressed separately in the Terms & Conditions.
23. International users and local privacy rights
Crowd Scout is operated from the United Kingdom and this Privacy Policy is principally written to meet the requirements of UK data-protection law. Crowd Scout may, however, make the Platform available to people in other countries and territories.
Where the privacy or data-protection laws of another country, territory or US state apply to Crowd Scout or to particular processing, Crowd Scout will comply with applicable mandatory requirements. Those requirements may give users additional rights or impose additional obligations beyond those described in this Policy.
Nothing in this Privacy Policy is intended to waive, restrict or replace mandatory privacy rights that cannot lawfully be excluded under the law applicable to a user.
As Crowd Scout expands internationally, we may publish jurisdiction-specific privacy supplements, notices or disclosures for particular countries, regions or states. Those supplements will form part of this Privacy Policy for users to whom they apply and may address matters such as local privacy rights, children’s consent and parental authorisation, regulatory contacts, international transfers, targeted advertising restrictions, sale or sharing definitions, and other local requirements.
Before deliberately launching or materially expanding Crowd Scout in a new jurisdiction, we may assess whether additional privacy, safeguarding, age-assurance, representation, consent or regulatory measures are required. Availability of the Platform in a location does not mean that every future feature, including commercial or digital-asset functionality, will necessarily be offered there.
Where personal data is transferred internationally, section 13 of this Policy applies in addition to any local transfer requirements.
24. Changes to this Privacy Policy
We may update this Policy when the Platform, law, regulation or our processing changes. We will make the current version available through Crowd Scout. Where a change materially affects users’ privacy, we will provide additional notice or seek renewed permission where required.
25. Complaints and the ICO
Please contact Crowd Scout first if you have a privacy concern so that we can investigate it. You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. The ICO’s official website is ico.org.uk.
26. Privacy by design commitments for young users
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Best interests first — children’s interests are a primary consideration in design decisions affecting their personal data.
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High privacy by default — young users should not have to weaken privacy protections simply to use the core service.
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Data minimisation — collect and retain only what is reasonably necessary for the feature being used.
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No unnecessary precise location tracking — core discovery uses supplied profile location rather than continuous live GPS tracking.
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Safeguarded discovery — Scout access and contact pathways are deliberately constrained, particularly for minors.
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No behavioural advertising model for children — Crowd Scout does not build its youth proposition around selling or monetising children’s behavioural profiles.
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Transparent sporting signals — ratings and rankings support discovery but are not represented as automated professional selection decisions.
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Accountability — reports, safeguarding actions and relevant approvals can be recorded so important safety decisions are auditable.
Schedule 1 - Privacy and product governance
Crowd Scout should maintain internal records supporting this public Policy, including a record of processing activities where required, data-flow mapping, retention rules, processor/vendor review, international-transfer assessment, legitimate-interest assessments where relied upon, security controls, and a Data Protection Impact Assessment addressing children’s use of the Platform.
Material new features should be reviewed before launch for privacy-by-design and safeguarding impact, particularly features involving children, location, profiling, messaging/contact, identity verification, artificial intelligence, biometrics, advertising, payments or digital assets.
Schedule 2 - Principal UK legal and regulatory framework
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UK General Data Protection Regulation (UK GDPR).
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Data Protection Act 2018.
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Data (Use and Access) Act 2025, including the enhanced statutory focus on children’s higher protection matters in data protection by design.
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Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR), where applicable.
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Information Commissioner’s Office Age Appropriate Design Code (Children’s Code) and associated guidance.
This Policy should be read alongside Crowd Scout’s Terms & Conditions, Safeguarding Policy, Child Protection Policy, Community Guidelines, Scout Verification Standard and Scout Code of Conduct.
Legal review status
This document is Crowd Scout’s final publication draft for operational review. Because Crowd Scout is a child-accessible technology platform and its processing may evolve, specialist UK data-protection and technology-law review is recommended before first public issue and following material product change.
