Welcome to Grassroots Genius, a mobile application developed by Grassroots Genius, a company registered in the United Kingdom (“we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you use Grassroots Genius (the “App”), which enables users to create and share sports tactics.

We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, EU General Data Protection Regulation (EU GDPR), California Consumer Privacy Act (CCPA), and Children’s Online Privacy Protection Act (COPPA). This policy applies to all users of the App, regardless of location.

By using the App, you agree to the practices described in this Privacy Policy. If you do not agree, please do not use the App.

We collect personal data to provide and improve the App’s functionality. The types of data we collect include:

We use your personal data for the following purposes, based on legal grounds under UK GDPR:

• To Provide Services (Contract): Manage your account, save and display your tactics, and enable App functionality.
• To Improve the App (Legitimate Interests): Analyze usage data and crash reports to enhance performance and user experience.
• To Communicate (Consent or Legitimate Interests): Send service updates, respond to inquiries, or provide support.
• To Ensure Security (Legitimate Interests): Prevent fraud, abuse, or unauthorized access.
• To Comply with Legal Obligations: Respond to lawful requests or meet regulatory requirements.

We do not sell your personal data. We may share your data as follows:

• Service Providers: With third-party vendors who help us operate the App (e.g., cloud storage, analytics, or email services), under strict data processing agreements compliant with UK GDPR.
• User-Generated Content: Tactics you share in the App may be visible to other users, depending on your settings.
• Legal Compliance: If required by law, such as in response to a court order or request from authorities (e.g., UK Information Commissioner’s Office).
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity, with safeguards in place.

You have rights regarding your personal data, subject to applicable law:

• Access and Update: View or update your account information in the App’s settings.
• Delete: Request deletion of your account by emailing [email protected]. Anonymized data or legally required records may be retained.
• Opt-Out: Opt out of non-essential communications (e.g., promotional emails) via unsubscribe links.
• UK/EU GDPR Rights: If you’re in the UK or EU, you have the right to:
• Access your data.
• Rectify inaccurate data.
• Erase your data (“right to be forgotten”).
• Restrict processing.
• Data portability.
• Object to processing (e.g., for analytics).
• CCPA Rights (California Residents): You have the right to know what data we collect, request deletion, and opt out of data sales (we do not sell data).

To exercise these rights, email [email protected]. We will respond within one month (UK/EU GDPR) or 45 days (CCPA), extendable where permitted. If you’re unsatisfied, you can lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk or your local EU data protection authority.

• Storage: Your tickerdata is stored on secure servers in the South East Region - UK, by cloud resources Digital Ocean.
• International Transfers: If data is transferred outside the UK or EU (e.g., to U.S.-based servers), we use safeguards like Standard Contractual Clauses or UK International Data Transfer Agreements to ensure UK GDPR compliance.
• Security: We implement industry-standard measures (e.g., encryption, access controls) to protect your data. However, no system is completely secure, and we cannot guarantee absolute security.
• Retention: We retain data only as long as necessary for the purposes outlined (e.g., while your account is active). Deleted accounts are removed within 30 days, except for anonymized data or legally required records.

The App may use third-party services (e.g., analytics or cloud storage). These services have their own privacy policies, and we are not responsible for their practices. Review their policies before use.

We use cookies or similar technologies (e.g., device identifiers) for analytics and functionality. You can manage these via device settings, though disabling them may affect App performance. For UK/EU users, we obtain consent for non-essential cookies per UK GDPR.

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via the App or email. Continued use of the App after updates constitutes acceptance.

For questions or to exercise your rights, contact our Data Protection Officer:

Grassroots Genius DPO

Email: [email protected]

Website: grassrootsgenius.com

• UK/EU GDPR: Our legal bases for processing include consent (e.g., account creation), contract (e.g., providing the App), legitimate interests (e.g., analytics), and legal obligations. You can contact the ICO at www.ico.org.uk for complaints.
• CCPA (California): We do not sell personal information. Contact us for a “Do Not Sell My Personal Information” request, though it’s not applicable.
• COPPA (U.S.): We do not target children under 16. Parents can contact us to review or delete their child’s data.