Privacy Policy for Be A Sport

Effective Date: 23rd December 2024

Fursat Farms Private Limited, having its registered office at Dwarika Heights, Darjeeling, India - 734005 including its affiliates and subsidiaries ("we," "us," or "our"), respects your privacy and is committed to protecting it in accordance with the terms of this Privacy Policy ("Policy"). This Policy applies when a natural person accesses, downloads, browses, or uses our platform ("Platform") and/or any legal entity avails, accesses, or uses our cloud-hosted services that empower sports academies, players, and coaches with performance analysis and improvement tools ("Services") through its employees, representatives, or agents ("Personnel"). Collectively, natural persons and legal entities are referred to as "user," "you," or "your."

This Policy describes the types of information we may collect from you or that you may provide when you visit our websites (besaportai.com/beasport.ai) ("Website") or use the Platform and Services. It further explains our practices for collecting, using, maintaining, protecting, and disclosing that information.

1. Business Overview

Be A Sport, a product of Fursat Farms Private Limited, provides a multi-tenant web application and AI-powered solutions for the sports industry, specifically designed for academies, players, and coaches. Our platform offers tools to analyse performance and drive improvement across various sports. Our Services, accessible through our Websites (besaportai.com/beasport.ai), include:

• Performance Analytics: Providing in-depth analysis of player and team performance metrics, utilizing data visualization and reporting tools.
• Data-Driven Insights: Leveraging AI to identify performance patterns, strengths, and areas for improvement, offering actionable insights for coaches and players.
• Performance Tracking: Tools for athletes and coaches to track progress over time, monitor training effectiveness, and identify trends in performance data.
• Academy Management Features: Facilitating communication and data sharing between coaches, players, and academy administrators (features may vary based on subscription level and user roles).
• Secure Data Storage and Management: Providing a secure, cloud-based environment to store and manage performance data, ensuring data integrity and confidentiality.

Our platform is designed to be used by multiple sports academies and organizations ("tenants"), each with their own secure and isolated data environment within the Be A Sport Platform.

2. Legal and Regulatory Compliance

We comply with all applicable data protection laws and regulations in India, including:

• Information Technology Act, 2000 and Amendments: We adhere to provisions concerning data security, privacy, and electronic transactions, including data breach notification requirements and reasonable security practices.
• Digital Personal Data Protection Act, 2023: We follow the principles of lawful data processing, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability outlined in the Act. We also comply with user rights, including the right to access, correction, erasure, and data portability.

Where applicable, this Privacy Policy reflects principles from international standards, including the General Data Protection Regulation (GDPR). While Be A Sport is initially focused on the Indian market, we aim to adhere to global best practices in data protection.

3. Data Collection and Usage

3.1 Types of Data Collected

We collect the following types of data to provide and improve our Services, tailored for the sports performance analysis context:

• Personal Information: Name, contact details (email, phone number), date of birth, gender, sport(s) played, team/academy affiliation, role (player, coach, administrator), government-issued identifiers (if required for specific features and only when legally permissible and necessary), and other information provided during registration, profile creation, or service usage.
• Performance Data: Sport-specific performance metrics, training data, fitness data, competition results, match statistics, biometric data (if integrated with wearable devices and with explicit consent), video and audio recordings (e.g., training session footage for analysis, with consent and notification), and related analytical data derived from performance tracking. This may include data inputted directly by users or collected through integrations with third-party sports equipment or platforms.
• Academy/Team Data: Information related to sports academies, teams, and organizations using Be A Sport, including academy names, contact details, team rosters, training schedules, and related administrative information.
• Metadata: Device information, IP addresses, access times, location data, browser type, operating system, referring URLs, usage patterns within the Be A Sport platform, and diagnostic data for analytics, service optimization, and security purposes.
• Communication Data: Records of communication with us, including emails, chat logs, and support tickets, for customer support and service improvement.

3.2 How We Use Your Data

We utilize the data we collect for a variety of purposes aimed at providing, enhancing, and securing our Services, specifically within the context of sports performance analysis and improvement, while remaining committed to protecting user privacy. These purposes include:

• Service Provisioning and Operation: To provide the Be A Sport Platform and its features, including performance tracking, data analysis, reporting, and academy management tools. This includes user account management, access control, and platform maintenance.
• Personalized User Experience: To tailor the Be A Sport experience based on user roles (player, coach, administrator), sport disciplines, and individual preferences. This may include customized dashboards, reports, and recommendations.
• Performance Analysis and Improvement: To process and analyze performance data to generate insights, reports, and visualizations that help players and coaches understand performance trends, identify areas for improvement, and optimize training programs.
• Communication and User Engagement: To communicate with users regarding service updates, new features, training tips, performance reports, support inquiries, and other relevant information related to Be A Sport. This may include in-app notifications, emails, or other communication channels.
• Research and Development: To analyze aggregated and anonymized data to improve our algorithms, develop new features, and enhance the Be A Sport Platform for the benefit of all users. (See Section 3.3 Data Anonymization).
• Legal and Regulatory Adherence: To comply with applicable laws and regulations, respond to legal requests, and protect our legal rights.
• Security and Fraud Prevention: To monitor platform usage for security purposes, detect and prevent fraud, and protect the integrity of our systems and user data.

3.3 Data Anonymization and Aggregation

We apply robust anonymization and aggregation techniques to de-identify performance and usage data for model training, research, and benchmarking purposes. This ensures personal information is removed or masked, and data is aggregated to prevent individual identification. This includes methods such as pseudonymization, data aggregation, and differential privacy to protect your identity while utilizing data to improve Be A Sport and contribute to sports performance knowledge. Individual academy or team data will not be shared with other tenants in identifiable form.

3.4 Children's Data

We recognize the importance of protecting children's privacy, especially in the context of youth sports. If Be A Sport is used by academies or coaches to track the performance of athletes under the age of 18, we require verifiable parental or guardian consent before knowingly collecting and processing their personal data. Academies and coaches using our Services are responsible for:

• Obtaining and maintaining verifiable parental or guardian consent for athletes under 18 as required by applicable laws, including the Digital Personal Data Protection Act, 2023.
• Ensuring that the collection and processing of children's data through Be A Sport is compliant with all applicable laws and regulations regarding children's privacy.
• Providing clear and transparent information to parents and guardians about the data being collected, how it will be used, and their rights regarding their child's data.

Be A Sport provides tools to assist academies and coaches in managing consent and complying with child privacy regulations, but the ultimate responsibility for compliance rests with the academies and coaches using the platform.

4. Consent Mechanisms

4.1 General Consent

By using our Services, and for academies using the platform on behalf of their players, you consent to the collection and use of data as described in this Privacy Policy. For individual users (players, coaches) directly registering, we provide clear and concise information about our data practices during the registration process and throughout your use of our Services. For academies subscribing to Be A Sport, it is their responsibility to ensure they have the appropriate consent to input and manage player data within the platform, in accordance with applicable laws and this policy.

4.2 Explicit Consent for Specific Data Processing

For certain types of data processing activities that are considered more sensitive (e.g., processing biometric data, using performance data for research beyond service improvement, using video/audio recordings for purposes beyond immediate analysis), we will obtain your explicit consent. You will have the right to choose whether or not to provide this consent.

4.3 Withdrawal of Consent

You may withdraw your consent for any processing activity at any time by contacting us through the methods provided in Section 10. Withdrawing consent may affect access to certain features or the availability of personalized services. We will clearly explain the implications of withdrawing consent and provide alternative options where possible. For data where consent withdrawal impacts service functionality, we will work with you to find a suitable solution.

5. Security Measures

We implement comprehensive security practices to protect your data from unauthorized access, use, disclosure, alteration, or destruction:

• Encryption: Data is encrypted during transmission and storage using industry-standard protocols, such as TLS/SSL and AES-256, to safeguard your information from unauthorized interception and access.
• Access Control: Access to personal and performance data is strictly limited to authorized personnel based on the principle of least privilege, ensuring that only those who need access to your data for legitimate business purposes (e.g., providing support, platform maintenance) can access it. We use role-based access control, strong password policies, multi-factor authentication (where feasible), and other security measures to enforce access restrictions.
• Secure Storage: Data is stored on secure, cloud-based servers with advanced physical and technical safeguards, including firewalls, intrusion detection systems, and regular security assessments. We partner with reputable data center providers that comply with industry security standards (e.g., ISO 27001, SOC 2).
• Regular Audits and Vulnerability Assessments: Periodic security audits and vulnerability assessments are conducted by independent third-party security experts to identify and address potential weaknesses in our systems and processes. We also perform regular internal security reviews.
• Pseudonymization and Data Minimization: Where feasible and appropriate, data is pseudonymized to limit direct identification. We also strive to collect and retain only the minimum data necessary to provide our Services effectively.
• Data Backup and Disaster Recovery: We maintain regular data backups and have disaster recovery procedures in place to ensure business continuity and data availability in case of system failures or unforeseen events.

6. Data Sharing

6.1 Third-Party Integrations and Service Providers

We may share data with third-party vendors and service providers who assist us in providing and improving our Services ("Service Providers"). These may include:

• Cloud Hosting Providers: For secure data storage and platform infrastructure.
• Analytics Providers: To help us understand platform usage and improve our Services (using anonymized and aggregated data where possible).
• Customer Support Platforms: To manage and respond to user support requests.
• Payment Processors: To process subscription payments (if applicable).
• Integrations with Sports Technology Partners: To enable data import and export with other sports performance tools or wearable devices (with user consent and as applicable).

These Service Providers are bound by confidentiality agreements and data processing agreements that restrict the use of your data for any purpose other than providing the services we have contracted them for. We carefully select our partners and ensure they have appropriate security measures in place to protect your data, aligned with our own security standards.

6.2 Cross-Border Data Transfers

Your data may be transferred to and processed in jurisdictions outside India where our cloud service providers or technology partners operate. We will ensure that any such transfers comply with applicable Indian data protection laws, including obtaining your explicit consent where required and implementing appropriate safeguards, such as:

• Standard Contractual Clauses: Using data transfer agreements based on standard contractual clauses approved by the relevant authorities, ensuring adequate data protection in the recipient country.
• Binding Corporate Rules: If applicable, relying on Binding Corporate Rules established within our corporate group.
• Adequacy Decisions: Transferring data to countries recognized by Indian law as having adequate data protection regimes.

We are committed to protecting your data regardless of where it is processed and will take steps to ensure your data receives an adequate level of protection in these jurisdictions.

7. User Rights

You have the following rights regarding your data under the Digital Personal Data Protection Act, 2023:

• Right to Access Information: You have the right to request access to your personal data that we hold, and information about how we process it, including the categories of data, the purposes of processing, and recipients of the data.
• Right to Correction of Inaccurate or Incomplete Personal Data: You can request that we correct any errors or outdated information in your personal data.
• Right to Erasure of Personal Data: You can request that we delete your personal data under certain circumstances, such as when it is no longer needed for the original purpose, when you withdraw consent (if processing is based on consent), or when the data has been unlawfully processed. Please note that we may have legal obligations or legitimate business interests to retain certain data even after a deletion request.
• Right to Data Portability: You can request a copy of your data in a commonly used electronic format (e.g., CSV, JSON) so you can transfer it to another service provider, where technically feasible.
• Right to Grievance Redressal: You have the right to register a grievance with us regarding the processing of your personal data. (See Section 10 for Grievance Redressal).
• Right to Nominate: You have the right to nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, please contact our Grievance Officer as detailed in Section 10. We will respond to your request within the timeframes stipulated by applicable law. We may require you to verify your identity before processing your request.

8. Data Breach Notification

In the event of a data breach that is likely to result in harm to you, we will notify you and the relevant authorities (as required by law) in accordance with legal requirements. Our incident response plan outlines procedures for identifying, assessing, and containing data breaches. This includes prompt notification of affected users and relevant authorities, as per legal requirements, and implementing remedial measures to prevent future occurrences. We will provide you with timely information about the breach, the nature of the data compromised, the steps we are taking to address the breach, and steps you can take to protect yourself.

9. Data Retention

We retain personal data only as long as necessary to fulfil the purposes outlined in this Policy, including providing you with the Be A Sport Services, complying with legal obligations, resolving disputes, and enforcing our agreements. Specific retention periods are determined based on the type of data, the nature of the services provided, the applicable sport regulations (if any), and legal requirements, including limitation periods under applicable laws and accounting standards.

For example, performance data may be retained for longer periods to allow for longitudinal analysis and athlete development tracking, while account information may be retained for as long as your account is active and for a reasonable period thereafter to manage account closure and potential reactivation. After the retention period expires, data will be securely deleted or anonymized using appropriate methods, such as secure data wiping or irreversible pseudonymization, in accordance with our data retention policy and applicable laws.

10. Grievance Redressal

If you have any questions, concerns, or grievances regarding this Privacy Policy or our data processing practices, please contact our Grievance Officer:

Name: Yogesh Bansal

Email: hi@beasport.ai

Address: Dwarika Heights, Eastern By-Pass, Darjeeling, India

We have designated Mr. Yogesh Bansal as our Grievance Officer to address any concerns or complaints related to data privacy. Please contact him via email or postal mail at the address provided above. We will acknowledge receipt of your grievance within [Insert timeframe, e.g., 48 hours] and will endeavour to resolve your grievance in a timely and efficient manner, typically within [Insert timeframe, e.g., 30 days] as per applicable law. We will provide you with a clear explanation of our decision and any actions taken.

If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority, which in India is currently the Data Protection Board of India (once established under the Digital Personal Data Protection Act, 2023).

11. International Compliance Considerations

While our primary focus is compliance with Indian data protection laws, we are mindful of global data protection standards such as GDPR and other relevant regulations, anticipating potential international expansion of Be A Sport in the future. We are committed to aligning with global best practices in data privacy and will ensure that our data practices comply with the relevant data protection laws in any jurisdiction where we offer our Services. This may involve updating this Privacy Policy to reflect specific requirements of international regulations as we expand our global presence.

12. Policy Updates

This Privacy Policy may be updated periodically to reflect changes in our Services, data processing practices, legal requirements, or industry best practices. We will notify users of material changes through prominent notices on our Websites (besaportai.com/beasport.ai), through email communications (where appropriate), or through in-app notifications. We encourage you to review this Privacy Policy regularly, especially when you see notifications of updates, to stay informed about our data practices. The "Effective Date" at the top of this Policy indicates when it was last revised. Continued use of Be A Sport Services after the effective date of an updated Privacy Policy constitutes your acceptance of the revised policy.

13. Contact Us

For any questions about this Privacy Policy, our data practices, or to exercise your rights, please contact us at:

Email: hi@beasport.ai

By using Be A Sport Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.