SCOUTME · LEGAL DOCUMENTS

Privacy Policy

How ScoutMe collects, uses, shares, protects, retains and deletes personal data, including specific rules for athletes, professionals, legal guardians and minors.

Version 1.0 Last updated: 11 August 2026 Applicable law: Brazil · LGPD

1. INTRODUCTION

ScoutMe values the privacy, security and protection of the personal data of all users of its platform.

This Privacy and Personal Data Protection Policy ("Policy") explains how ScoutMe collects, uses, stores, shares, protects and deletes personal data related to the use of its websites, web applications, Progressive Web App (PWA), applications, features, services and other digital environments ("Platform").

This Policy was prepared with particular consideration for Brazilian Law No. 13,709/2018 – the Brazilian General Data Protection Law ("LGPD"), the Brazilian Civil Rights Framework for the Internet, the Brazilian Child and Adolescent Statute ("ECA"), Brazilian legislation applicable to the protection of children and adolescents in digital environments and other applicable rules.

Because ScoutMe is a sports platform that may be used by children and adolescents, we adopt additional safeguards regarding the processing of these users' data.

By using ScoutMe, the user declares that they have had access to this Policy and may consult, at any time, information about how their personal data is processed.

2. WHO CONTROLS THE DATA

For purposes of the LGPD, the controller of personal data processed through the Platform will be:

[COMPANY LEGAL NAME]
Trade name: ScoutMe
CNPJ: [CNPJ]
Address: [ADDRESS]
Email for privacy matters: [privacy@scoutme.club]

While the corporate structure responsible for operating ScoutMe is being defined, this information must be updated before the Platform is made definitively available on a commercial basis.

3. ABOUT SCOUTME

ScoutMe is a technology platform focused on the sports ecosystem, designed to enable athletes to present their skills, history, videos, highlights, sports information, assessments and performance indicators.

The Platform may also enable interaction between different participants in the sports ecosystem, including, among others:

  • athletes;
  • minor athletes;
  • parents and legal guardians;
  • coaches;
  • technical staff;
  • scouts;
  • agents and intermediaries;
  • clubs;
  • academies and sports schools;
  • sports organisations;
  • recruiters;
  • sports professionals;
  • other authorised users.

ScoutMe may use data provided by users and information resulting from use of the Platform to generate indicators, statistics, classifications, profiles and sports analyses.

4. PERSONAL DATA WE MAY COLLECT

Depending on the user's profile and the features used, ScoutMe may collect different categories of data.

4.1. Identification data

We may collect:

  • full name;
  • display name;
  • date of birth;
  • age;
  • gender, where necessary and legally permitted;
  • country;
  • state;
  • city;
  • profile photograph;
  • language;
  • information required to identify the account.

4.2. Contact data

We may collect:

  • email address;
  • telephone number;
  • contact information for the legal guardian;
  • information necessary for communications related to the Platform.

5. ATHLETE DATA

Athlete profiles may contain specific information related to their sporting activity.

Depending on the features used, data processed may include:

  • sport;
  • position;
  • secondary position;
  • category;
  • current club;
  • previous clubs;
  • academy or sports school;
  • team;
  • sports history;
  • dominant foot or equivalent characteristic of the sport;
  • height;
  • weight, where provided;
  • sports statistics;
  • competitions played;
  • match information;
  • achievements;
  • titles;
  • sports experience;
  • videos;
  • highlights;
  • photographs;
  • sports test results;
  • technical assessments;
  • performance indicators;
  • sports attributes;
  • metrics produced by the Platform.

6. VIDEOS, IMAGES AND HIGHLIGHTS

One of ScoutMe's core features is the possibility of publishing and analysing sports content.

The user may upload, indicate, link or make available:

  • match videos;
  • training videos;
  • individual videos;
  • highlights;
  • photographs;
  • sports images;
  • video excerpts;
  • content related to the athlete's participation in sports activities.

This content may include the image, voice and other identifiable characteristics of participants.

The user responsible for the upload must hold the required authorisation or another valid legal basis for making the content available and must respect image rights, privacy, intellectual property and other third-party rights.

Where content involves children or adolescents, additional safeguards and the best interests of those data subjects must be observed.

7. SPORTS PERFORMANCE DATA

ScoutMe may process information related to the athlete's sports performance.

This information may include, for example:

  • events identified in highlights;
  • sports actions;
  • passes;
  • shots;
  • goals;
  • assists;
  • dribbles;
  • interceptions;
  • tackles;
  • saves;
  • attacking actions;
  • defensive actions;
  • movements;
  • field zones;
  • physical tests;
  • sports results;
  • technical indicators;
  • performance assessments.

This information may be used to produce derived metrics and indicators.

8. METRICS AND DATA DERIVED BY SCOUTME

Based on information recorded on the Platform, ScoutMe may generate new data and indicators related to the athlete.

Depending on the sport and available features, the following may be produced:

  • Overall;
  • Attribute Radar;
  • Heatmap;
  • technical indicators;
  • physical indicators;
  • performance indices;
  • comparative metrics;
  • statistics;
  • rankings;
  • classification of sports characteristics;
  • affinity with certain positions or profiles;
  • analysis confidence indicators;
  • other sports indicators.

This information constitutes computational analysis based on the data available on the Platform and does not represent a guarantee of future performance, recruitment, selection, call-up or professional success for the athlete.

9. SPORTS PROFILE AND AUTOMATED PROCESSING

Certain ScoutMe features may use algorithms and automated systems to process sports information.

These systems may take into account elements such as:

  • type of sports event;
  • situation of the play;
  • field region;
  • event frequency;
  • position characteristics;
  • attributes associated with events;
  • amount of information available;
  • other technical parameters defined by ScoutMe.

This data may be used to calculate indicators such as Overall, Radar, Heatmap and other sports indicators.

ScoutMe seeks to provide appropriate information about the general criteria used in these analyses, while respecting intellectual property rights and trade and industrial secrets.

Where applicable under the LGPD, the data subject may request information related to the criteria and procedures used in automated decisions that affect their interests and may exercise the rights guaranteed by law.

10. DATA OF CHILDREN AND ADOLESCENTS

ScoutMe recognises that athletes under 18 years of age require special protection.

The processing of children's and adolescents' personal data will be carried out in accordance with their best interests, as required by applicable law.

ScoutMe may establish different protection mechanisms according to the athlete's age.

For children, when processing is based on consent, specific and highlighted consent from at least one parent or legal guardian will be requested, as required by applicable law.

ScoutMe may adopt reasonable procedures to verify:

  • the age provided by the user;
  • the existence of the guardian;
  • the relationship between guardian and athlete;
  • the validity of required authorisations.

ScoutMe may restrict certain features for minor users.

11. LEGAL GUARDIAN ACCOUNT

Parents or legal guardians may have their own ScoutMe account or specific mechanisms to manage the account of minors under their responsibility.

Depending on the athlete's age and the features made available, the guardian may:

  • authorise creation of the account;
  • monitor the athlete's profile;
  • authorise certain features;
  • manage certain privacy settings;
  • request changes to information;
  • request deletion of information;
  • manage authorisations related to data processing.

ScoutMe may request additional information to verify the legitimacy of the guardian.

12. DATA OF SPORTS PROFESSIONALS AND ORGANISATIONS

Professionals and organisations may provide data such as:

  • name;
  • photograph;
  • email;
  • telephone;
  • organisation;
  • club;
  • job title;
  • role;
  • country;
  • city;
  • professional information;
  • professional history;
  • sports credentials;
  • areas of activity.

Information related to interactions carried out within the Platform may also be recorded.

13. TECHNICAL AND USAGE DATA

When a user uses ScoutMe, certain technical information may be collected automatically.

This may include:

  • IP address;
  • browser;
  • operating system;
  • device;
  • technical identifiers;
  • language;
  • date and time of access;
  • pages accessed;
  • features used;
  • authentication records;
  • logs;
  • security information;
  • cookies and similar technologies.

This data may be used for operation, security, fraud prevention, performance analysis and improvement of the Platform.

14. PURPOSES OF PROCESSING

ScoutMe may process personal data to:

  • create and manage accounts;
  • authenticate users;
  • create sports profiles;
  • allow publication of videos and highlights;
  • process sports information;
  • calculate indicators;
  • generate Radar, Heatmap and Overall;
  • enable athlete search;
  • enable talent discovery;
  • connect participants in the sports ecosystem;
  • personalise the experience;
  • provide support;
  • send operational communications;
  • prevent fraud;
  • protect users;
  • maintain Platform security;
  • comply with legal obligations;
  • exercise rights;
  • resolve disputes;
  • improve products and features;
  • develop new features;
  • generate aggregated and, where applicable, anonymised statistics.

15. LEGAL BASES

ScoutMe may process personal data on the legal bases provided for under the LGPD, depending on the nature of the processing.

These may include:

  • consent;
  • performance of a contract or preliminary procedures;
  • compliance with a legal or regulatory obligation;
  • regular exercise of rights;
  • protection of life or physical safety;
  • legitimate interest, where legally applicable;
  • other legal bases provided for by law.

The applicable legal basis will be determined according to the purpose, data category, data subject and specific context of the processing.

Where sensitive personal data is involved, the specific legal bases provided for by the LGPD for that category of data will be observed.

16. SENSITIVE PERSONAL DATA

Data relating exclusively to sports performance is not necessarily classified as sensitive personal data under the LGPD.

However, certain information eventually processed by ScoutMe may fall into that category, including, where applicable:

  • biometric data linked to a person;
  • certain health-related information;
  • genetic data;
  • other data expressly classified as sensitive by law.

If ScoutMe implements features that use these categories, the specific legal bases and safeguards required by the LGPD will be adopted.

17. PROFILE VISIBILITY

ScoutMe may provide different privacy and visibility settings.

Depending on the features available, a profile may have settings such as:

Public: certain information may be viewed by other users or visitors.

Restricted: certain information is available only to authenticated users or specific categories.

Private: access is limited to the user, guardian or authorised persons.

For minor athletes, additional visibility restrictions may apply regardless of the settings available to adults.

ScoutMe may restrict exposure of information considered inappropriate or unnecessary for the sports purpose of the Platform.

18. ATHLETE SEARCH AND DISCOVERY

Certain profiles may appear in the Platform's search mechanisms.

Authorised professionals may search for athletes using filters related, for example, to:

  • sport;
  • position;
  • category;
  • age or age range;
  • country;
  • region;
  • sports characteristics;
  • technical indicators;
  • attributes;
  • Overall;
  • Radar;
  • other sports criteria.

ScoutMe may establish specific restrictions for searches involving minors.

19. DATA SHARING

ScoutMe does not commercialise personal data as a standalone product.

Data may be shared, where necessary, with service providers responsible for services such as:

  • cloud infrastructure;
  • hosting;
  • database;
  • CDN;
  • authentication;
  • storage;
  • payment processing;
  • email delivery;
  • monitoring;
  • analytics;
  • security;
  • support;
  • video processing;
  • technology services.

These providers must process the data according to their roles, applicable contracts and data protection law.

20. SHARING WITHIN THE SPORTS ECOSYSTEM

Depending on account settings and features used, certain profile information may be made available to other ScoutMe participants, including:

  • clubs;
  • scouts;
  • coaches;
  • agents;
  • academies;
  • sports organisations;
  • recruiters;
  • other authorised professionals.

Making this information available is intended to enable interaction, analysis, discovery and opportunities within the sports ecosystem.

21. THIRD-PARTY SERVICES

ScoutMe may use services provided by third parties.

These services may have their own privacy and data protection policies.

Where content is hosted or processed by external platforms, the terms and policies of those platforms may also apply.

ScoutMe will seek to select providers that offer appropriate security and data protection measures.

22. INTERNATIONAL DATA TRANSFERS

Some technology providers used by ScoutMe may have infrastructure located outside Brazil.

As a result, personal data may be transferred internationally.

Where this occurs, ScoutMe will adopt the mechanisms provided for by the LGPD and applicable regulation for international transfers of personal data.

23. DATA RETENTION

Personal data will be retained for the period necessary to fulfil the purposes for which it was collected.

The criteria may take into account:

  • duration of the account;
  • operational need;
  • legal obligations;
  • fraud prevention;
  • security;
  • regular exercise of rights;
  • dispute resolution.

Once the purpose has ended, data may be deleted or anonymised, except where retention is permitted or required by law.

24. ACCOUNT DELETION

The user may request deletion of their account through the features provided by ScoutMe or through the support channels indicated in this Policy.

Deletion may result in removal or anonymisation of associated data, subject to legal grounds that authorise or require retention.

For minors, certain requests may require validation by the legal guardian.

25. DATA SUBJECT RIGHTS

Under the LGPD, data subjects may exercise, where applicable, rights relating to their personal data, including:

  • confirmation that processing exists;
  • access;
  • correction;
  • anonymisation;
  • blocking;
  • deletion;
  • portability, where regulated and applicable;
  • information about sharing;
  • information about the possibility of refusing consent;
  • withdrawal of consent;
  • objection to processing in cases provided by law;
  • petitioning the competent authority;
  • rights related to automated decisions provided for by law.

ScoutMe may request information necessary to confirm the identity of the requester before responding to certain requests.

26. DATA SECURITY

ScoutMe will adopt technical and administrative measures intended to protect personal data against:

  • unauthorised access;
  • destruction;
  • loss;
  • alteration;
  • improper communication;
  • disclosure;
  • improper or unlawful processing.

Measures may include, as appropriate:

  • encryption;
  • access control;
  • authentication;
  • logging;
  • backups;
  • monitoring;
  • environment segregation;
  • internal policies;
  • permission management;
  • attack prevention mechanisms.

No system is completely immune to risk, but ScoutMe will seek to apply measures compatible with the nature and risks of the processing carried out.

27. SECURITY INCIDENTS

If a security incident involving personal data occurs that may cause relevant risk or harm to data subjects, ScoutMe will take the measures required by applicable law and regulation.

This may include investigation, containment, correction and, where legally required, notification to the Brazilian National Data Protection Authority and affected data subjects.

28. COOKIES

ScoutMe may use cookies and similar technologies for:

  • authentication;
  • security;
  • session maintenance;
  • preferences;
  • Platform operation;
  • usage analysis;
  • performance measurement.

Where required by law, appropriate mechanisms will be made available to manage preferences related to non-essential cookies.

29. ANONYMISED DATA AND STATISTICS

ScoutMe may use anonymised data or aggregated statistical information for:

  • analysis;
  • research;
  • improvement of algorithms;
  • development of features;
  • production of sports statistics;
  • studies related to sport;
  • improvement of the Platform.

Where effectively anonymised so that it cannot reasonably be associated with a person using available means, such data is no longer considered personal data for purposes of the LGPD, subject to the exceptions provided by law.

30. ARTIFICIAL INTELLIGENCE AND EVOLUTION OF ALGORITHMS

ScoutMe may use artificial intelligence techniques, machine learning, statistical models or other computational methods to develop or improve features related to sports analysis.

Where personal data is used in these processes, its processing must have an appropriate purpose and legal basis.

Whenever possible and appropriate, ScoutMe may use anonymised or aggregated data to develop and improve its systems.

31. PROTECTION AGAINST DISCRIMINATION

Data and indicators produced by ScoutMe must not be used for discriminatory, unlawful or purposes incompatible with the sports purpose of the Platform.

ScoutMe may establish mechanisms intended to prevent abusive uses of personal and sports information.

32. EXTERNAL LINKS AND PLATFORMS

ScoutMe may contain links or integrations with third-party websites, platforms and services.

Data processing carried out directly by these third parties will be governed by their respective privacy policies.

We recommend that users review those policies before using external services.

33. CHANGES TO THIS POLICY

This Policy may be updated periodically to reflect:

  • legal changes;
  • regulatory changes;
  • new features;
  • technological changes;
  • changes to ScoutMe internal processes.

The current version will be available on the Platform with the date of the last update.

Where material changes require renewed communication or consent, ScoutMe will take the appropriate measures.

34. CONTACT AND EXERCISE OF RIGHTS

For questions related to privacy, data protection or exercise of rights provided for under the LGPD, the user may contact:

ScoutMe – Privacy and Data Protection

Email: [privacy@scoutme.club]

Data Protection Officer (DPO):

[NAME OF DPO OR DPO CHANNEL]

Final information will be made available once the legal entity responsible for operating the Platform has been formalised.

35. APPLICABLE LAW

This Policy will be interpreted in accordance with the laws of the Federative Republic of Brazil, especially Law No. 13,709/2018 – Brazilian General Data Protection Law (LGPD), the Brazilian Child and Adolescent Statute, the Brazilian Civil Rights Framework for the Internet and other applicable rules.

36. FINAL PROVISIONS

This Policy must be interpreted together with the ScoutMe Terms of Use and other specific policies made available by the Platform.

If a specific feature requires data processing that is not adequately addressed in this Policy, ScoutMe may provide additional information before the relevant feature is used.

When developing features involving children and adolescents, ScoutMe must consider, from the design stage, the principles of data protection, privacy, security, necessity, transparency and the best interests of these data subjects.

SCOUTME
Privacy and Personal Data Protection Policy – Version 1.0
11 August 2026