The purpose of the privacy policy for personal data processing (hereinafter – the Privacy Policy) carried out by SIA Digital Value 2B (hereinafter also – the Controller) is to provide a natural person (hereinafter – the Data Subject) with general information on the personal data processing carried out by the Controller, the purposes, scope, and protection of the processing, as well as to inform the Data Subject about their rights.
When processing personal data, the Controller complies with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter – the General Data Protection Regulation) and other legal acts in the field of privacy and data processing.
The Privacy Policy applies to every natural person whose personal data is processed by the Controller, and it is applicable to personal data processing regardless of the form in which You or any other natural person has provided the personal data.
Data Subject – any natural person whose personal data is processed by the Controller (for example, a registered platform user, a website visitor, or a person communicating with the Controller);
Platform or skillball app – a set of software solutions that includes the website www.skill-ball.com, software installable on the user’s device, and a mobile application (available in the “Google Play” and “Apple App Store” stores), through which the user is provided access to the services;
Service – the technical solutions provided by the Platform, including the upload, storage, and artificial intelligence processing of sports game video files to automatically identify players and create video fragments.
Other terms used in the Privacy Policy are interpreted within the meaning of the General Data Protection Regulation.
2. ControllerSIA Digital Value 2B
Registration No. 50203664291
Address: Krasta iela 1-5, Ozolnieki, Ozolnieku pag., Jelgavas nov.
E-mail address: info@skill-ball.com
3. Collection and processing of personal dataThe skillball app provides an innovative sports game video analysis and automated video fragment (“highlight”) generation service using artificial intelligence technologies.
The skillball app helps athletes, coaches, and parents easily process game video materials, saving time and creating high-quality content for personal or professional use.
The skillball app obtains the Data Subject’s data from the Data Subject themselves (for example, when registering an account) and processes them in electronic format to ensure the provision of the Service, the operation of the Platform, and customer support.
If you choose to register or log in to the Platform using third-party services (Google or Facebook), we will receive certain profile information about you (name, surname, and e-mail address) from these service providers. The scope of data we receive depends on your privacy settings on the respective platform. We will use this data solely for the creation, authorization, and maintenance of your account on our Platform. We do not control and are not responsible for how your data is processed by these third-party service providers.
The processing of personal data is carried out by the Controller’s employees who are authorized to do so, and by processors (for example, server hosting providers, payment processors) with whom the Controller has concluded a data processing agreement and who ensure appropriate security standards.
Processing of minors personal data
The Platform is intended for persons from 13 years of age. The Controller does not knowingly collect data and does not allow persons under the age of 13 to register. In cases where video materials featuring minor children are uploaded to the Platform, the responsibility for ensuring a legal basis for the processing of such data is assumed by the video uploader (the User), as stipulated in our Terms of Use.
Important information regarding roles in data processing!
Regarding Your account and billing data, SIA Digital Value 2B acts as the data Controller. However, regarding the persons visible in the game video materials uploaded by You (players, spectators, referees), You (the User) act as the data Controller, while SIA Digital Value 2B acts only as the data Processor, providing the operation of the Platform’s technical tools on Your behalf. The User bears full responsibility for whether they have a legal basis to film and upload third-party data to the Platform.
Since the Platform acts only as a Processor with respect to video content, we cannot fulfill requests from third parties (for example, parents of other children) regarding whether specific persons appear in the videos uploaded to the Platform. We do not have the technical and legal means to identify the persons visible in the videos, and granting access to third-party files would violate the privacy of other persons. Any requests regarding video content must be addressed directly to the specific video uploader, i.e., the Controller.
4. Personal data processing carried out by the ControllerIn order to provide the Service in the most effective manner, the Controller needs to collect, process, and use certain types of personal data about the Data Subject. Below is a summary of the data processing carried out by the Controller (purpose, processed data, and legal basis).
- Purpose – User account creation and administration
Ensuring the registration of the Data Subject on the Platform, user profile creation, and identification in the system.
Processed data: name, surname, e-mail address, profile picture (optional).
Legal basis:
- Conclusion and performance of a contract (Article 6(1)(b) of the General Data Protection Regulation).
- Purpose – Provision of the Service and functionality
Ensuring the upload of video files, processing with artificial intelligence, and generation of “highlights”, as well as saving the created content in the user’s profile.
Processed data: technical metadata about the uploaded files, file processing history, Platform usage habits.
Legal basis:
- Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation).
- Purpose – Payment processing and performance of accounting functions Administration of subscription payments, processing of settlements, and preparation of accounting documents.
Processed data: billing information (last digits of the credit/debit card received from the payment processor), payment history, invoice details.
Legal basis:
- Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation);
- Compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation), the Accounting Law.
- Purpose – Provision of customer support
Processed data: name, surname (if provided), e-mail address, phone number (if provided), content of the request, and communication history.
Legal basis:
- Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation);
- Legitimate interests, the Controller’s right to answer customer questions and provide the necessary support (Article 6(1)(f) of the General Data Protection Regulation).
- Purpose – Development of the Service and technologies, including the training, testing, and calibration of artificial intelligence models and computer vision algorithms
Processed data: Uploaded video materials and the personal data contained therein.
Legal basis:
- The Controller’s legitimate interest (Article 6(1)(f) of the GDPR) – to improve the technological accuracy of the platform and provide innovative, high-quality services to all users.
For the training of artificial intelligence models, we use the video materials uploaded to the platform to improve the selection of “highlights” and player number recognition algorithms. The processing of biometric data is not performed in this process.
- Purpose – Ensuring Platform security, analytics, and improvement Prevention of fraud, maintenance of the Platform’s technical security, and compilation of anonymized statistics.
Processed data: IP address, device and browser information, connection times (log files), as well as information obtained using technical and analytical cookies. Detailed information on the use of cookies, their types, and management can be found in our separate Cookie Policy.
Legal basis:
- Legitimate interests, the Controller’s right to ensure system security and service development (Article 6(1)(f) of the General Data Protection Regulation);
- Consent, regarding analytical and marketing cookies (Article 6(1)(a) of the General Data Protection Regulation).
The Controller does not use automated decision-making or profiling in its operations that would produce legal effects concerning the Data Subject or similarly significantly affect the Data Subject within the meaning of Article 22 of the General Data Protection Regulation. Artificial intelligence algorithms are used solely as a technical aid for identifying and processing video fragments at the User’s request.
5. Processing, protection, and storage of personal dataTo protect your personal data, the Controller uses modern technical and organizational security measures. Your personal data is stored securely on servers physically located in the European Union or the European Economic Area (EEA), and it is accessible only to a strictly limited number of people – the Controller’s authorized employees and specialists who need this access to perform their work duties.
Recipients of personal data:
We do not sell or transfer your personal data to third parties, except when it is necessary for the provision of the Service. The recipients of your personal data may be:
- The Controller and its authorized employees;
- Data processors engaged by the Controller (for example, cloud computing server providers, payment processing systems (e.g., Stripe)).
Duration of data storage:
The period for which personal data will be stored is determined using the following criteria:
- as long as You have an active registered user account on the Platform;
- as long as data storage is required by external regulatory enactments (for example, the Accounting Law);
- as long as there is a legal need for the Controller or the Data Subject to realize their legitimate interests (for example, preservation of evidence in the event of a possible dispute).
In accordance with these criteria, we apply the following main retention periods:
- User profile data:
- active user accounts (the user makes payments or continues to use the Service by regularly logging into the account) – data is stored for the entire time until you decide to close the user account. After closing the user account, the profile data and the created highlight videos will be permanently deleted within 30 days;
- inactive user accounts – an account is considered inactive if two conditions are met simultaneously: the account does not have an active paid subscription, and no successful login has occurred in the account for more than 12 (twelve) months. When both criteria are met, the user account (including profile data and all video materials) is automatically and permanently deleted.
- Video processing data (uploaded) videos – are automatically deleted after the processing is completed to optimize data storage;
- Video processing data (created “highlight” videos) – are stored in the User’s profile for the entire duration of the account’s operation (provision of the Service);
- Payment and billing information – is stored for 5 years;
- Support communication and email history – is stored for 2 years after the issue is resolved to ensure quality control and protect the Controller’s legitimate interests;
- Technical and security data – 6 months.
After the data retention period has expired and the criteria mentioned in this clause are no longer applicable, Your personal data is permanently deleted or destroyed in a secure manner. The Controller informs that to the extent that data processing is necessary to fulfill a legal obligation (e.g., storage of accounting documents and payment information), the Controller will not be able to fulfill the Data Subject’s request to delete such data before the end of the term specified in the regulatory enactments.
Data transfer outside the EU/EEA
In certain cases, to ensure specific functions of the Service (for example, payment processing or cloud computing server infrastructure), data may be transferred to recipients in countries outside the European Economic Area (EEA), including the USA. In such cases, the Controller ensures that there is an appropriate legal basis for the data transfer and appropriate safeguards are applied, which include:
- An adequacy decision, such as the EU-U.S. Data Privacy Framework, under which our cooperation partners (for example, the payment processor Stripe) are certified;
- Standard Contractual Clauses (SCC) approved by the European Commission, if the data recipient is located in a country for which an adequacy decision has not been adopted.
Before obtaining personal data or at the moment it is obtained (for example, when registering on the Platform), the Controller will invite the Data Subject to confirm that the Data Subject has familiarized themselves with this Privacy Policy.
The Controller ensures and strictly observes all rights of the Data Subject set out in Chapter III of the General Data Protection Regulation (GDPR). The Data Subject has the following rights:
- Right to access data – to request information about what personal data of yours we process and to receive a copy of it (please note the limitations described in Section 3 of the Privacy Policy regarding access to video files uploaded by third parties);
- Right to rectification – to request the correction of your inaccurate or incomplete personal data, however, you can independently correct most of your data in your user profile settings;
- Right to be forgotten – to request the deletion of your personal data if it is no longer necessary for the processing purpose or if you withdraw your consent (except in cases where the Controller has a legal obligation to retain the data, for example, for accounting purposes);
- Right to restrict processing and to object – to request the restriction of data processing or to object to its processing in cases specified in regulatory enactments (especially if the processing is based on the legitimate interest of the Controller). This right specifically includes the possibility to object at any time to the further use of your uploaded video materials for the training of our artificial intelligence models. To exercise this right to opt-out, please send a free-form request to the e-mail info@skill-ball.com, using the same e-mail address with which you registered on the Platform;
- Right to data portability – to receive your personal data in a structured, commonly used, and machine-readable format, as well as to request its transmission to another controller if technically feasible;
- Right to withdraw consent – to withdraw your previously given consent to data processing at any time (for example, for analytical cookies), which does not affect the lawfulness of processing based on consent before its withdrawal.
How to exercise your rights?
To exercise the aforementioned rights, please send a written request to our e-mail address: info@skill-ball.com. The Controller will review your request and provide a response in accordance with the procedures specified in regulatory enactments (usually within one month).
Right to lodge a complaint
If you believe that the processing of your personal data violates data protection regulatory enactments, you have the right to lodge a complaint with the Data State Inspectorate of the Republic of Latvia (address: Elijas iela 17, Riga, LV-1050; e-mail: pasts@dvi.gov.lv) or with the data protection supervisory authority of your country of residence.
7. Final provisions and changes to the Privacy PolicyIn case of any questions, uncertainties, or requests regarding the processing of personal data carried out by the Controller or the exercise of Your rights, we invite you to contact us by writing to the e-mail address: info@skill-ball.com.
The Controller has the right to unilaterally make amendments and additions to this Privacy Policy to reflect changes in our data processing processes or regulatory enactments.
The current version of the Privacy Policy will always be published on the Platform’s website {website address} in the “Privacy Policy” section, indicating the date of the last update.
If material changes are made to the Privacy Policy (for example, new data processing purposes or changes to Your rights), the Controller will inform the registered Data Subjects in advance by sending a notification to the e-mail address provided during registration or by placing an informative notice on the Platform itself before these changes enter into force.