The Athlete Place (the Company) seeks to ensure that it retains only data necessary to effectively conduct its Services and work in fulfilment of its mission.

The need to retain data varies widely with the type of data and the purpose for which it was collected.

The Athlete Place strives to ensure that data is only retained for the period necessary to fulfil the purpose for which it was collected and is fully deleted when no longer required. This policy sets forth The Athlete Place’s guidelines on data retention and is to be consistently applied throughout the organisation.

Scope

This policy covers all data collected by The Athlete Place and stored on Company-owned or leased systems and media, regardless of location. It applies to both data collected and held electronically (including photographs, video and audio recordings) and data that is collected and held as hard copy or paper files. The need to retain certain information may be mandated by federal or local law, federal regulations, legitimate business purposes, and the EU General Data Protection Regulation (GDPR).

Reasons for Data Retention

The Athlete Place retains only data that is necessary to effectively conduct its Services, fulfil its mission and comply with applicable laws and regulations.

The Athlete Place will use, process and store Personal Data to provide the services outlined in their Terms of Use to connect users with support, content and opportunities relevant to their sporting and user needs. The Athlete Place’s lawful bases for processing personal data and the purpose for processing it are as follows:

To fulfil our contract with the user:

By creating an account on one of our software products, we will be required to collect, store, use and otherwise process information about users for any purposes deemed necessary for the use of The Athlete Place software products and for the performance of user agreement with The Athlete Place including:

• Providing services such as allowing users to access and consume content that will support them as student-athletes.
  

• Delivering notifications about content, opportunities, and important communications by email in accordance with user account settings and communication preferences.
  

With user consent:

For some uses, The Athlete Place will obtain consent from users to provide additional services. Such uses include:

• Allowing users to choose to share their profile publicly, with other users and to be introduced using the profile information users have set as public information. Completely optional and can be disabled by The Athlete Place if this is not a preference.
  

• Contacting users about additional features or Platform Partner services you might be interested in and that improve the Service.
  

• Personalising tools that make up our software products. For example, The Athlete Place may suggest opportunities or content to users based on the sport, age, or demographic information the user provides.
  

For our legitimate interests:

Processing of user personal data may also be necessary for the pursuit of our legitimate interests – but only where the processing is not unwarranted and will not cause a prejudicial effect on your rights and freedoms, or legitimate interests. Examples are:

• Processing user data along with other users’ data to provide activity and engagement reports to Platform Partners.

• Researching new ways to improve our software products.

• The Athlete Place will only use personal data for the purposes for which it is collected, unless The Athlete Place reasonably consider that The Athlete Place need to use it for another reason and that reason is compatible with the original purpose.

No special category or sensitive data will be processed.

Data Duplication

The Athlete Place seeks to avoid duplication in data storage whenever possible, though there may be instances in which, for programmatic or other business reasons, it is necessary for data to be held in more than one place. This policy applies to all data in The Athlete Place’s possession, including duplicate copies of data.

Retention Requirements

The Athlete Place has set the following guidelines for retaining all personal data as defined in the Company’s data privacy policy

• User data will be retained as long as necessary to provide the service requested/initiated through the Company’s website.

• User data will be retained for the duration in which the individual has a registered account and then for 12 months after the date of the last login to ensure accounts are not prematurely deleted. Financial information will not be retained longer than is necessary to process a single transaction.

• If users register at no cost as a result of partnerships with teams or institutions (i.e., academic institutions), user accounts and data will be deleted at the end of the agreed term unless renewed.

Please note that some or all of the User Provided Data may be required in order for our software products to function properly. As a corporately responsible business, mindful of the data protection principle of storage-limitation and data-minimisation, we perform a disposal and archiving exercise at least once per annum, at which all data sets will be reviewed and obsolete data will be deleted from our systems (including our back up facilities).

Data Destruction

Data destruction ensures that The Athlete Place manages the data it controls and processes it in an efficient and responsible manner. When the retention period for the data as outlined above expires, The Athlete Place will actively destroy the data covered by this policy. If an individual believes that there exists a legitimate business reason why certain data should not be destroyed at the end of a retention period, he or she should identify this data to his/her supervisor and provide information as to why the data should not be destroyed. Any exceptions to this data retention policy must be approved by The Athlete Place’s data protection offer in consultation with legal counsel. In rare circumstances, a litigation hold may be issued by legal counsel prohibiting the destruction of certain documents. A litigation hold remains in effect until released by legal counsel and prohibits the destruction of data subject to the hold.

If you’d like us to delete User Provided Data that you have provided via one or more of our software products, please contact our Data Protection Officer at joe@theathleteplace.com.