Article 1: Subject and Scope of the Privacy Policy

PRIVACY POLICY Article 1: Subject and Scope of the Privacy Policy This Privacy Policy covers the storage, use, processing, and sharing of personal data in accordance with the provisions of the General Data Protection Regulation (GDPR) and the Personal Data Protection Law No. 6698 (“KVKK”) and other relevant legislation regarding the personal data of observer members/footballers/visitors using the online Scoutium application (“System”) operated by Scoutium Football Technologies Inc. (“Scoutium”) (including web applications, smartphone applications, and any other digital media without limitation), shared with Scoutium by the Data Subject or obtained/generated by Scoutium during the Data Subject’s use of the Site.

This Privacy Policy is an integral part of the Scoutium Footballer Agreement, Scoutium User Agreement, and Club Agreement.

Article 2: Scope of Personal Data

Unless expressly stated otherwise, the term “Personal Data” within the scope of this Privacy Policy shall include the following information:

1. Identity and Contact Information (name, surname, phone number, email, address, date of birth, club, identity front photograph)
2. Membership Information, Membership Transaction Information, and Financial Information (membership details, membership ID number, data related to the use of Scoutium services, invoice and payment information, balance information, shared analyses, ratings, data related to objections to analyses, )
3. Transaction Security Information (passwords)
4. Photograph on the front of the identity document requested during registration to the System, videos, and images of the member playing football
5. Cookie Records and any other personal data obtained/generated automatically or non-automatically due to the use of Scoutium platforms, including but not limited to Scoutium applications.

Article 3: Collection, Processing, and Sharing of Personal Data

Scoutium may collect your personal data through verbal, written, or electronic means via channels such as the System, our cooperation partners, online transactions, and call centers, directly from you or indirectly through institutions such as KKB (Credit Bureau), Risk Center, or directly or indirectly affiliated companies, shareholders, or third parties from whom Scoutium receives or provides services. The Personal Data shared with Scoutium by the Data Subject or generated by Scoutium within the scope of this Privacy Policy may be stored, processed, and shared for purposes such as the Data Subject’s utilization of the services provided by the System, registration to the System, updating membership records, performing services provided by Scoutium and through the System, improving services, introducing new services, providing necessary information to the Data Subject accordingly, verifying the accuracy of the information provided during membership transactions, ensuring System security, communicating with the Data Subject, improving user experiences on the System, conducting internal reporting and business development activities of Scoutium, various statistical evaluations, and creating a database.

Scoutium may process Personal Data and share it with third parties without obtaining separate consent from the Data Subject, in accordance with Articles 5/2 and 6/3 of the GDPR and other relevant legislation.

Article 4: Storage and Security of Personal Data

Personal Data shall be retained as long as the purpose of data processing is valid. If the purpose of processing Personal Data has ceased to exist, and if it is necessary to retain Personal Data for reporting to legal authorities and for informative purposes within the framework of legal periods, such retention shall comply with these limits.

When the purpose of processing Personal Data has ended, and if the relevant legal periods determined by legislation and the company have expired, Personal Data may only be retained for possible legal disputes, assertion of the relevant right related to Personal Data, or exercise of the defense right, and access to the relevant Personal Data is provided only when necessary for the relevant legal dispute. After the expiration of the mentioned period, the Personal Data is deleted, destroyed, or anonymized. Scoutium undertakes to take necessary technical and administrative measures to ensure the protection of Personal Data, prevent unlawful processing of Personal Data, unauthorized access to Personal Data, and maintain the security of Personal Data, in line with the requirements of the relevant legislation and the conditions expressed in this Privacy Policy.

Article 5: Declaration and Undertakings of the Data Subject

In addition to what is described in Article 1, Scoutium aims to provide valuable advertisements and other commercial or sponsored content for all users and advertisers. To assist in achieving this, the Data Subject agrees to the following:

Subject to compliance with the principles of the GDPR and the Scoutium principles established in this regard; you explicitly consent and authorize the use, processing, storage, preservation, analysis, classification, updating, transfer to domestic and/or international  destinations,  transfer  to  third-party  business  partners  and/or consultants, and sharing with third parties of your username, profile picture, content, photo, video, image, evaluations made by you or made on behalf of you, your information, and any other Personal Data automatically or non-automatically obtained or generated through the use of the System. This means that, for example, a business or other organization or individual may be permitted to display and share your name, photo, video, image, evaluations made by you or made on behalf of you, profile, and any and all Personal Data obtained or generated through the use of the System, with your content or information, without paying a fee. Additionally, activities within the application such as rank, point breakdown, badges, number of followers, names of users being followed, number of recommended footballers by users, Scoutium membership date, previously evaluated footballers, club supported, points received from evaluations, breakdown of points received, overall index of the footballer resulting from evaluations, number of tasks performed, number of clubs served, number of footballers served with club point stars, names and numbers of footballers transferred, and user photos, footballer videos taken and uploaded, comments, likes are also considered as Personal Data.

Even if the information and content are deleted by you, Scoutium may process, share with its business partners, store, categorize, analyze, update, transfer to domestic and/or international destinations, transfer to third-party business partners and/or consultants, and share with third parties the information entered into the System under the scope of the GDPR.

By accepting this statement or continuing to use the System or other services without accepting the statement, every person who shares their data or data obtained or generated automatically or non-automatically through the use of the System within the limits of this statement expressly consents to the processing,storage, and retention during membership or any legal period specified, or the period declared by Scoutium and retention, preservation, analysis, classification, updating, transfer to domestic and/or international destinations, transfer to third-party business partners and/or consultants, and sharing with third parties of Personal Data.

Article 6: Transfer of Personal Data Processed by Scoutium Abroad

Personal data processed by Scoutium may be transferred abroad to individuals and organizations residing abroad, provided that they comply with the rules specified in Article 9 of the GDPR and after foreign countries with adequate protection for personal data have been declared by the Personal Data Protection Board. For countries where adequate protection is not available, transfer is limited to cases where data controllers in Turkey and the relevant foreign country provide written assurance of adequate protection and the permission of the Board is obtained for the transfer.

Article 7: Obligations of Scoutium

As a Data Subject, you may apply to Scoutium in accordance with Article 11 of the GDPR to:

1. Learn whether your personal data is being processed,
2. Request information if your personal data has been processed,
3. Learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
4. Know the third parties to whom your personal data are transferred domestically or abroad,
5. Request correction of your personal data if it is incomplete or incorrectly processed and request notification of the operations performed in this regard to third parties to whom your personal data have been transferred,
6. Request deletion or destruction of your personal data in case the reasons requiring processing disappear despite being processed in accordance with the GDPR and other relevant laws and request notification of the operations performed in this regard to third parties to whom your personal data have been transferred,
7. Object to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
8. Request compensation if you suffer damage due to the unlawful processing of your personal data.

You can notify Scoutium of your requests regarding your rights through the GDPR Application Form, which has been shared with the public on the website www.scoutium.com.

Scoutium will conclude your requests within the shortest time possible and no later than 30 (thirty) days for free, depending on the nature of the request. However, if the process requires a cost, Scoutium reserves the right to charge a fee according to the tariff determined by the Board.

Article 8: Principles of Data Privacy and Amendments

The provisions of this Privacy Policy may be revised and updated as legislation changes or new features are added to digital platforms or new suggestions are received from our users. However, in such cases, we will inform you by publishing the changes on our website. In some significant cases, we may also notify you of these changes through additional notifications, such as via email or through another method designed reasonably to attract attention. If you do not accept the terms of this Privacy Policy, you have the right to close your account at any time. The terms of this Privacy Policy may change, and when they do, they will take effect on the date of publication. Therefore, we recommend that you review the Privacy Policy every time you visit Scoutium. By continuing to use the services after the changes, you will be deemed to have accepted the changes.

Scoutium has no obligation other than to inform the data subject and the relevant administrative authorities in case of unauthorized access to the system containing your Personal Data, disruption, or modification of the system operation, or obtaining, modifying, or deleting your information by any means. When you visit the System, your IP address, operating system, browser used (chrome, explorer, etc.), connection time and duration information, and similar information are automatically recorded and, without your permission, may be associated with your Personal Data by Scoutium or used anonymously.

Article 9: Cookies

Cookies are small text files stored on your device or network server by websites you visit through browsers.

During your presence on the Site, platforms, or Application, cookies or javascript codes for analyzing site usage data, also known as “cookies,” may be placed on your computer. Cookies are simple text files that do not contain identity or other private information. However, they contain session information and similar data and can be used to recognize you again. We provide personalized services to you by using cookies, verify your identity when you visit our platforms, and improve and enhance our services.

Scoutium may use cookies and process data to a limited extent required for analysis services provided by third parties and may transmit it to third parties within the scope of processing for analysis services. If you prefer, you can delete or block cookies from your browser settings. Unless you change your cookie settings in your browser, we will assume that you accept the use of cookies on our System.

Article 10: Applicable Law, Competent Court, and Enforcement Offices

This Privacy Policy is subject to the laws of the Republic of Turkey, and Istanbul Central (Çağlayan) Courts and Execution Offices are authorized to resolve any disputes that may arise from its implementation.