Privacy Policy

This notice explains how HILLS Lab d.o.o., as controller, processes data in PLAYGRND accounts, football records, organizer tools, messaging, uploads and AI-assisted features.

1. Data, sources and provenance

Depending on your use, we process account/session identifiers, profile fields, verified phone or channel identity, public-contact choices, claims, competition and Termini records, messages and delivery metadata, uploads/photos, AI requests/outputs, security logs and basic aggregate analytics.

Data comes directly from you, organizers and other authorized submitters, teams, official match records, documented public sports sources and reviewed corrections. A public sports record about a person without an account may be created from these sources. Restricted record-level provenance supports verification, correction and rights handling; it does not mean PLAYGRND has permission from a third-party platform. This notice gives general Article 14 information. Where Article 14 applies, we provide the required information within a reasonable period and no later than one month after obtaining the data, or at the first communication or first disclosure where applicable. Any Article 14 exception requires a documented case assessment and the safeguards and public information required by law. For your record, request available information about the known source and whether it was publicly accessible, subject to necessary security and third-party redactions.

2. Purposes and legal bases

Required Terms acceptance records the service contract and notice presentation; it is not blanket GDPR consent. We do not sell personal data.

• Contract/requested steps: account access, profile completion, claims, Termini, organizer tools, support and intentionally requested AI.
• Legitimate interests: an accurate public amateur-football record, provenance, correction, security, abuse prevention, availability and proportionate cost control after balancing rights.
• Legal obligation: specific applicable duties and valid authority requests.
• Consent: separate optional public contact, promotion, non-essential storage or content reuse; off by default where applicable and withdrawable.

3. Phone, WhatsApp and Telegram

For WhatsApp sign-in or contact we may keep normalized phone, channel name, account link, message/time, attachments and delivery/error metadata for account protection, secure login, profile/claim linking, support, conversation continuity and requested operations. Meta also processes communication under its rules.

Telegram may provide a user ID and username without phone. We use that channel identity for delivery/linking; phone is best effort. Telegram also processes communication under its rules. Sign-in or messaging phone is not public by default. Public phone, or public Telegram contact if that option is enabled, requires separate opt-in and can be hidden; promotion requires separate channel choice.

4. Public records, organizers and minors

Names, teams, appearances, results, events and statistics may remain public as historical competition records. Credentials, private messages, claim evidence and admin notes are not public. You may request correction, object or ask for deletion assessment; we balance accuracy, evidence, other rights and the sports-record purpose.

HILLS Lab remains responsible for its own Article 14 assessment and notice timing even when an organizer supplies data. Organizers must have authority, lawful source, transparency and licences, minimize data and cooperate on rights. PLAYGRND does not publicly display full birth dates; when we identify a person under 18, we remove the full date from main records and prevent its return, using only a minimal eligibility result or age band where needed.

5. Uploads, photos and AI

Uploads may include profile photos, schedules and match sheets. Uploaders must be authorized and minimize data, especially about children. Private originals and extraction results may support review, correction and integrity.

When you intentionally use PLAYGRND AI, we process the request and limited needed context: linked profile/permissions, teams/organizations, up to four recent short turns, voice transcript, sports image and match/roster candidates. We do not intentionally add phone to model prompts. Audio is transcribed, not used for speaker identification. Do not submit sensitive data.

AI may search, explain, transcribe, classify, OCR and draft. It can be wrong, remains subject to rules/human review and does not make solely automated legal or similarly significant decisions. Requests may route to OpenAI, OpenRouter and selected downstream model providers; Gemini may be a selected model route, not necessarily a direct Google integration. Processing may occur in the US or elsewhere outside the EEA. Adequacy is used only when the exact recipient/service qualifies; otherwise applicable safeguards and assessment are required. Ask for the relevant safeguard. HILLS Lab does not use PLAYGRND content to train its own models. External providers process content only to deliver the requested feature under the documented provider configuration and contract. We do not claim zero retention or no provider training unless that control is verified for the exact route. A new training purpose requires a separate legal assessment and, where required, informed opt-in.

6. Recipients, analytics and security

Authorized HILLS Lab personnel and providers for hosting, object storage, messaging, email, analytics, operations and AI process data needed for their role. We do not claim a DPA, ZDR setting, certification or region without dated evidence. Necessary session tokens support sign-in and preferences. Cloudflare Web Analytics provides aggregate proxied-page measurements without PLAYGRND analytics cookies or browser local/session storage for analytics. We use restricted access, transport protection, backups and audit controls, but no system is risk-free.

7. Retention

Public records/provenance are retained while needed for historical accuracy and disputes, subject to rights assessment. Accounts remain while active and during valid deletion processing. Sessions are usable only until expiry/revocation; limited security records may remain.

Automatic deletion is not active for every message, attachment, profile claim, AI request or match sheet. Until reviewed retention periods and automatic deletion jobs are active, those categories are limited to their stated purposes and supported deletion or restriction requests are handled manually. Database backups follow a documented rotation. Some older backup objects are not yet covered by automatic deletion; access is restricted and they are subject to a documented cleanup review. Material period changes use a new notice version.

8. Rights and contact

Subject to law, request access, copy, correction, deletion, restriction, portability, object to legitimate-interest processing or withdraw optional consent at [email protected] or through data deletion instructions. We verify identity proportionately. We respond without undue delay and, in any event, within one month. Where legally permitted, we may extend by up to two further months and will explain the extension within the first month. You may complain to AZOP or your local authority.

You may contest AI output, request human review, correct a public record and ask for available actual-source and transfer-safeguard information.