What is the 433Pro-app?
433 Horizon B.V. has developed the 433Pro-app with the aim of providing insight into the development of talented football players in order to improve those in an optimal manner. The 433Pro-app is developed for football players, and makes it possible to map and improve the development of the football player. With the help of sensors, the results of the training sessions become transparent for the football players, who can then proceed to do new training sessions using the sensors. In this way, they work very specifically on the optimal development of the football player.
The system consists of a platform on which all data and the development of the players, the training sessions and the results of the training sessions are stored. In addition, there is an app with which the player can record his/her training sessions and where his/her development is also visible to them. Trainers are able to have access to the system allowing them to have the same insights as the football players.
Personal data is processed with the operation and use of the 433Pro-app. We care for the privacy of the users of the system. 433 Horizon B.V. has therefore taken the necessary measures to ensure that the requirements set by the General Data Protection Regulation (GDPR) are complied with by all parties. In this privacy statement we explain which data is processed, what the roles of the various parties are, and what measures we have taken to process the data safely.
Division of roles
A number of parties are involved in the exploitation and use of the 433Pro-app. Below is an overview of the parties involved, the tasks they perform and the way in which those parties deal with personal data.
433 Horizon B.V. is the developer of the 433Pro-app and aims to roll it out as widely as possible. 433 Horizon B.V. processes personal data with the use of the 433Pro-app. This is done in different ways:
- Establishing and maintaining contact with clubs and football players so that we can properly execute the agreement that we conclude or have concluded with them (GDPR: execution of agreement).
- Approaching, informing (potential) customers and users through newsletters and direct marketing (GDPR: legitimate interest).
- The collection of personal data necessary for the use of the 433Pro-app (GDPR: consent of the user).
- Processing anonymous, non-personally identifiable information, usage data for evaluating and improving the product, and for commercial purposes (GDPR: legitimate interest).
The users of the 433Pro-app or, in the case of persons under the age of 16, the parents, are always asked for consent before personal data will be processed.
A processor agreement is always concluded between 433 Horizon B.V. and the customers who enter personal data of their players/members in the 433Pro-app. 433 Horizon B.V. has also concluded processor agreements with the parties that develop, host, and manage the data, and that are seen as so-called sub-processors.
433 Horizon B.V. customers are, for example, sports clubs that administer the test and make it available to its members. Customers gain insight into the scores and development of the players and can thus monitor the effect of the training program. They fill in the personal data of the users. This information is shared within the organization. The customer has the role of controller, and as mentioned above, a processor agreement is always concluded between the customer and 433 Horizon.
Personal data of users of the 433Pro-app is processed through the use of the 433Pro-app. This is done on the basis of consent. We make it very clear which data is collected, for what purpose this is done, and for how long the data is stored. The users of the 433Pro-app can always exercise their rights to access, rectify and/or delete the data (see detailed below) or object against the processing.
To be able to use the 433Pro-app, the user will first have to register. The chosen password and that person's name are saved so that the system recognizes him/her which makes it possible to access the data. The user decides which data is entered. The same applies to the user who is sitting “on the other side” of the 433Pro-app on behalf of the customer (e.g. the football club) and who can send training drills and monitor the scores and development of the user.
Of course, the username, password and associated data will not be provided to third parties, unless this is necessary in the context of the provision of the service or if this is required by law. In case of suspicion of fraud or abuse of the 433Pro-app, we can hand over personal data to the competent authorities.
What information is requested?
433 Horizon B.V. collects and processes the following types of data with the exploitation and use of the 433Pro-app in the context of the performance of its functions:
- Name and address details and login details of the contractor (on behalf of the customer).
- Contact details of customer contact person (name, e-mail, and telephone number).
- Personal data entered by the users, such as first and last name, gender, date of birth users.
- Club and team users.
- Data arising from a test such as video images and scores of the exercises.
Provision/transfer to third parties
The personal data of the users are only shared with the relevant customer, and are explicitly not provided to third parties, without prior instruction from the user and/or customer.
The contact details of the contact persons of the clubs are only shared within 433 Horizon B.V..
The name, address details and login details of the contractor on behalf of the customer are only shared within 433 Horizon B.V.
We have taken the necessary security measures to prevent the possible misuse of the 433Pro-app. These include the following measures:
- Access to personal data only with a unique username and password.
- Processor access to personal data through 2 Factor Authentication.
- Passwords are stored encrypted.
- Secured communication with server (HTTPS/SSL).
- Access to the servers where the data is stored is limited to authorized persons.
- All changes to the software will be done via the DTAP development method.
In addition to the above-mentioned measures, SportTalentVision has taken technical measures to prevent videos with unwanted (explicit) content from being distributed via the application.
A detailed summary of the security measures is included in the various processor agreements.
Use of anonymized data
As described above, 433 Horizon B.V. has access to anonymous data of the results of the exercises and the development of the users, as well as the use of the website and app. 433 Horizon B.V. uses this to evaluate and improve the 433Pro-app, and from our commercial interest in being able to approach parties to use the 433Pro-app. The legal basis on which we do this is "legitimate interest".
Protecting and retaining data
433 Horizon B.V. makes every effort to adequately protect personal data against loss and unlawful use (such as a data breach). As already mentioned, 433 Horizon B.V. has concluded so-called processing agreements with the partners who take care of (part of) the implementation. These state, among other things, that they protect the personal data appropriately and that they observe the regulations of the GDPR.
If, despite the measures mentioned, there is a data breach, we will of course handle it in accordance with the rules. If you feel that there is a data breach, or if you suspect that this is the case, we ask you to report this to the club or via firstname.lastname@example.org as soon as possible.
Websites of third parties
This statement does not apply to websites or apps of third parties that are connected to the 433Pro-app by means of links. We cannot guarantee that these third parties will handle your personal data in a reliable or secure manner.
Access, change and removal of your personal data
The GDPR specifies a number of rights that the persons whose personal data are processed have:
- Access: you have the right to access your personal data.
- Correcting: if it appears that your personal data is incorrect, you can ask us to change your data.
- Delete: you can also request us to delete personal data and stop using it.
You can also withdraw your consent to the processing of your personal data at any time. If you have a question or a request about the processing of your personal data, you exercise these by sending an email to: email@example.com.
If you are not satisfied with the way in which we process your personal data, you can also submit a complaint to 433 Horizon B.V. (see the e-mail address above). If you are not satisfied with the way we have handled your complaint, you can submit a complaint to the Dutch Data Protection Authority via: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/gegevens-uw-privacyrechten/klacht-reken-at-the-ap
Changes to this privacy statement
We reserve the right to make changes to this statement from time to time, for example when the website or the 433Pro-app is renewed.