Privacy notice: Nothing Unlucky

This is a draft. It has not yet been reviewed by a solicitor.

1. Who this is from

This notice says what Egon Expert Ltd ("we", "us") does with personal information when you use Nothing Unlucky (the "platform") and its website. Egon Expert Ltd · registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. You can write to us at [email protected]. Egon Expert Ltd is registered with the Information Commissioner's Office, registration number ZA262820. For anything about data protection, write to the address above.

2. Two roles

A club's own information. The names, notes, photos, voice notes, video, drawings, sessions, line-ups and reviews that a club puts into the platform, including everything about its players, are the club's. The club decides what is recorded and why, and is responsible for it (the "controller"). We look after it for the club and do only what the club asks and the terms of service allow (the "processor"). If you have a question about a child's information, ask the club first. The terms for that are in Schedule 1 of the terms of service.
Account, payment and website information. Who the head coach, coaches and players are as users of the platform, and what is needed to sell the plan, take payment and run the platform and this website, is information we decide how to use. We are responsible for it.

3. What we hold, and why

Who you are on the platform. If you are a head coach, a coach or a player: your name, your email address, which club and team you belong to, your role, the time you last signed in and, if you sign in with Google, the stable identifier Google gives us for you. We use it to let you in, to keep each club's information apart from every other club's, and to tell you about what you have signed up for.
Players. A coach adds a player with the name the coach knows them by and an email address, and the player is invited to sign in. We hold whether the invitation is waiting, accepted, declined or ended, and which notes the coach has chosen to show the player. What a coach writes about a player is the club's information (section 2).
What a club records. Events and the match clock; notes, photos and voice notes; match video the club uploads (a video that is only linked from YouTube or Veo stays with them); drawings and clips; training sessions and line-ups; and each player's review. These can include the names, images and voices of children.
Words made from a voice note. If the club has it switched on, a speech-to-text service on our own server turns a voice note into words. The recording does not leave our servers.
Translations and summaries (off unless switched on). To translate a note, or to write a draft summary, the words of the note are sent to an AI service run by another company. Never audio, photos or video. For a summary, the names on the club's roster are first replaced by labels such as "Player 12". A translation is sent as the coach wrote it, so a name in the note goes with it.
Payment. The head coach pays by card through Stripe, our payment provider. Stripe collects and holds the card details; we never see the card number. We keep Stripe's references for the customer and the subscription, the plan, the number of seats, the dates, the head coach's email address, and any notice Stripe sends about a dispute or a refund. We keep payment records while the club exists, and for 6 years after its plan ends, for our accounts and to deal with disputes.
Emails we send. Invitations, sign-in links, and notices about a plan or a club's notes, sent through an email delivery provider. We keep a record of each (the address, the subject and whether it was delivered) for 30 days.
Notifications on your device. If you turn on push messages, your browser gives us a push address, which belongs to its maker's push service, and we keep it with the name of the browser until you turn them off. A push message is short: for example, that a player accepted an invitation.
Places. If the club has place suggestions switched on, the text a coach types for an event's place, the country and a session code are sent to Google's Places service to suggest places. We keep the name of the place chosen and Google's code for it.
Keeping the platform safe. Sign-in attempts are counted by IP address, in the platform's memory only, to slow down guessing. The platform keeps no log of requests and no record of IP addresses of its own. The providers that host the platform and carry its traffic see the IP address and technical details of every request and keep their own records, under their own notices.
This website. At the time of writing it sets no cookies, runs no advertising, and loads nothing from other websites. It counts visits without cookies and without saying who: for each page opened and each press of the buttons to ask for an invitation or to sign in, one is added to that day's count, by page, by the website the visitor came from, and by whether the device was a phone, a tablet or a computer. Nothing in the count says who a visitor is, no address is kept with it, and nothing is counted for a browser that asks not to be tracked. The counts are kept for 400 days. If you write to us, we keep your email and what you wrote so that we can reply, and delete it 12 months after the last message between us.
Asking for an invitation. If you ask for one on the website, we keep what you wrote (the club, its teams, your name and email address) so that we can reply and set the club up, and we send you one email to say we have it. We delete the request 30 days after you make it.
On your device. The platform keeps a few things in your browser, such as the notes the phone has not yet sent. The cookie notice lists them.

The legal grounds we rely on. To let you in, keep each club's information apart, run the platform for a club and take payment, the ground is that it is needed for our contract with the club. To keep accounts and tax records, it is a legal obligation. To keep the platform secure, count visits to the website without saying who, and answer your enquiries and requests for an invitation, it is our legitimate interests in running a safe service and replying to people who write to us, which we weigh against your rights. For push messages, it is your consent, which you withdraw by turning them off. For a club's information, including a player's, the club is responsible and decides the ground it relies on.

4. Children

Nothing Unlucky is for coaching children's football, so most of the people in it are children. How it is built to protect them:

Nothing about a player is shown to the player unless the coach chooses, note by note. There are no accounts for parents.
There are no rankings, leaderboards or public statistics about players, and nothing judges a child automatically.
The optional AI features are off for every club until they are switched on, and the coach sees the exact words before anything is sent.
Consent to film children, consent to share, and the club's own data protection policy are the club's to collect and keep. The platform does not collect consent for a club.
A child under 13 does not have a sign-in of their own. A coach must add them with a parent's or guardian's email address, and the parent or guardian signs in for them. The platform does not ask a player's age, so it cannot check this: it is a rule the club must follow.
There is no advertising, nothing about anyone is sold, and no information about a child is used to profile them or to decide anything about them.
One club can never see another club's information.

We use suppliers to run the platform, and they act on our instructions. We do not sell personal information, and we do not use it for advertising.

We have a written contract with each supplier that requires it to protect the information and use it only on our instructions. We may also have to share information where the law requires it, for example with a court, the police or a regulator.

A hosting provider runs the servers and stores the videos, in the United Kingdom and the European Union.
A content delivery and security provider sits in front of the platform and this website: it carries and protects the traffic.
Stripe takes card payments.
An email delivery provider sends our emails.
Google lets you sign in with your Google account (it tells us your name, email address and stable identifier), suggests places if switched on, and supplies the video player when a club adds a YouTube video.
An AI service provider provides the translation and summary service, if switched on.
The makers of your browser (such as Google, Mozilla, Apple and Microsoft) carry push messages, if you turn them on.

6. Outside the UK

Some of these suppliers handle information in the United States and in other countries outside the UK. When they do, a safeguard the law accepts is in place: the country is one the UK government treats as adequate, the supplier is covered by the UK-US data bridge, or we have the Information Commissioner's standard contract terms with it. You can ask us for a copy of the safeguard at [email protected].

7. How long we keep it

While a club's plan is active, everything the club has put in is kept.
If a plan ends, the club keeps working for 7 days after a payment is late. It is then locked: nobody in the club can open its information. If the plan is paid again within 60 days of the lock, everything comes back. After that the club's information is deleted: its events, notes, photos, voice notes, videos, players and their reviews, and the shared copies of its clips, and the sign-in of every person who is in no other club. We tell the club's head coach by email on the day of the lock, on the 30th day, on the 55th day and when it is done. Before it is deleted, the club's head coach can ask us in writing at [email protected] for a copy of the club's content in a common format, and we will send it.
Backups. A copy of the database is made each night and kept for 14 days, so information that has been deleted can stay in a backup for up to 14 days more.
Shared links to a clip or picture last 7, 14, 30 or 90 days, as the coach chooses, and the copy is deleted when the link ends or is stopped.
Photos and voice notes are deleted when the coach deletes them or the event they belong to.
Requests for an invitation are deleted 30 days after they are made, whatever became of them.
Counts of visits to the website are kept for 400 days. They say nothing about who visited.
Emails: records are kept for 30 days.
Payment records are kept while the club exists. When a club that paid is deleted, what is kept is the record of its payments: the club's name, when and why it was deleted, its Stripe customer and subscription numbers, its plan, seats and dates, the terms it accepted, and the head coach's email address. That record is deleted 6 years after the club's plan ended. Nothing about a player, an event or a note is kept. A club that never paid keeps no email address and no number.
An erased player. When the club's head coach erases a player, their place in teams and events, the tags that say a note is about them, the reviews and summaries written about them, and their sign-in (if it belongs to no other club) are deleted. If the club chooses, the notes, photos and voice notes that are about them alone are deleted too, and their name is taken out of the words of the club's notes. A record that a player was erased is kept, with who did it (a role, never a name) and how many notes were deleted: it holds nothing about the player.

8. Your rights

You can ask us to show you the personal information we hold about you, to correct it, to delete it, to limit how we use it, or to give it to you in a form you can take elsewhere, and you can object to how we use it. For a club's information, including a child's, ask the club first; we will help the club to answer. For our own information, write to [email protected]. We answer within the time the law allows, and may need to check who you are first. Anyone who signs in can download a copy of their own information from the app (My data on a computer, Download my data in the Account on a phone): a file of their account, their place in each club, what was sent to their email address and, for a player, the club's record of them and what their coach showed them, in a page to read and a form a program or another service can read. It holds nothing about other people, and not what a club's coaches wrote about a player that the app does not show to players: for that, ask the club. A club's head coach can erase a player from the club as described in section 7. Photos and video that show a player but are not tagged to them, and what is written about someone else, cannot be found automatically, so the club is asked to look for them. If you ask us to delete information that is part of a club's records, we pass your request to the club's head coach within 5 working days and tell you we have; the head coach's erasing you from the club is how it is deleted. We delete what we hold ourselves (your account, payment and enquiry records) when you ask, except where the law requires us to keep it. Nothing on the platform makes a decision about a person by computer alone. If you are not happy with how we have used your information, you can complain to the Information Commissioner's Office at https://ico.org.uk/make-a-complaint/ . We would like the chance to put it right first.

9. Keeping it safe

The platform is used over an encrypted connection (https).
The server keeps each club's information apart from every other club's on every request, not by what a page shows.
You sign in with Google, or with a one-time link sent to your email address that works once and lasts 15 minutes. The sign-in cookie is signed and cannot be read by scripts on the page.
Links to shared clips hold a long random code that cannot be guessed, and they end.
One named administrator at the company can open any club's information, to run, support and keep the platform secure, and for no other purpose. Changes to a club's plan are logged; the administrator's viewing of a club's information is not.

If personal information is lost or exposed, we follow the law: we tell the Information Commissioner within 72 hours where people are at risk, tell the club's head coach without undue delay, and tell the people affected directly when the risk to them is high.

10. Changes to this notice

We may change this notice. If a change affects how we use your information, we email the head coach 30 days before it takes effect, and the page shows the date of the version.

11. Contact

Egon Expert Ltd · registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom. [email protected].

Privacy notice