Your privacy is critically important to us. At Tonsser, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason to keep it.
- We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
- We help protect you from overreaching government demands for your personal information.
- We aim for full transparency on how we gather, use, and share your personal information.
“Club(s)” means a football body consisting of various teams that play in recognised leagues, that is able to form a partnership with Tonsser.
“Partner(s)” means an association, league, brand, or similar body who has entered into an agreement with Tonsser and who offers its content, experiences, and brand affiliation to benefit players, coaches or the football landscape through the Tonsser Service.
“Person” / “you” means any User, Supporter, Partner and Club or any other person or entity using the Tonsser Services.
“Supporter” means any parent, guardian, person in custody or other trusted person (being a User) authorised by a football player (being a User) to administrate the football player’s User and User Content.
“Tonsser” / “we” / “us” means the Danish limited liability company Tonsser ApS with its registered address at Godthåbsvej 34 B, 2nd 2000 Frederiksberg, Copenhagen, Denmark, company registration (CVR) no. 35472088 for Users/Partners registered in any location.
“Tonsser App” means any digital application called Tonsser provided by Tonsser for natural and legal persons to create a football profile or presence by uploading content, results, and performance inputs either as a User or Partner.
“Tonsser Service” / “Services” means both the Tonsser App (across various platforms and available in different app stores) and Tonsser website [tonsser.com] and Tonsser Discover and other additional locations as mentioned at [tonsser.com].
“User” means a natural or legal person using the Tonsser Service, as either a player, coach, club, scout, Supporter or similar entity.
“User Content” anything posted by a User (save for Supporters) or made available through the Tonsser Service by the User.
2. Who We Are and What This Policy Covers
2.1. We are the folks behind a variety of products and services designed to allow Tonsser to act as intermediary between the User and the Partners and provides a platform on which the User can upload football performance results, content, and feedback as well as interact with the community of Users, Partners and Clubs.
(i) Our websites (including tonsser.com);
(ii) Our mobile applications (including the mobile app for Android and iOS); and
(iii) Our other Tonsser products, services, and features that are available on or through our websites (for example, discover.tonsser.com).
2.5. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
3. Information We Collect
3.1. We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.
3.2. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
3.3. Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:
(i) Basic account information: We ask for basic information from you in order to set up your account. For example, we may request individuals who sign up for a Tonsser App account to provide an email address, phone number and password, along with a username, first name, last name, football team information— and that’s it. You may provide us with more information — like your gender and age and other information you want to share — but we don’t require that information to create a User/Supporter account.
(ii) Partner/Club account information: We also ask for basic information from you in order to set up your account. For example, we require individuals and companies who sign up as Partners/Clubs to provide an email address, phone number and password, company name, details and address, along with a username, first name, last name, football team information (if any) and contact information — and that’s it. You may provide us with more information — like your address and other information you want to share — but we don’t require that information to create a Partner/Club account.
(iii) Public profile information: If you have a User with us, we collect the information that you provide for your public profile. For example, if you have a User, your name is part of that public profile, along with any other information you put into your public profile, like a photo or video and “Biography” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
(iv) User Content: You might provide us with information about you in draft and published content (a blog post, picture, video or comment that includes biographic information about you, or any media or files you upload).
(v) Communications with us: You may also provide us with information when you respond to surveys, communicate with us about a support question, post a question in our public forums, or sign up for a newsletter like the one we send through MailChimp. When you communicate with us via form, email, phone, [tonsser.com], comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
(vi) Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
3.4. Information We Collect Automatically
We also collect some information automatically:
(i) Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your account on the Tonsser App.
(ii) Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that Users perform on our site — in other words, who did what and when (e.g., ”[Tonsser App username]” deleted “[title of post]” at ”[time/date]”). Our tool Amplitude also tracks information like your email address, browser / app settings. We also collect information about what happens when you use our Services (e.g., page views, features enabled for Users, interactions with our support team and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
(iii) Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via the Services (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
(iv) Stored information: We may access information stored on your mobile device via our Services. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs and videos on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the perfect goal or match celebration to your account.
(v) Interactions with other Persons: We collect some information about your interactions with other Persons while you are logged in to your account with us, such as your “Likes”, so that we can, for example, recommend posts we think may interest you.
3.5. Information We Collect from Other Sources
We may also get information about you from other sources. For example, if you create or log in to your account through another service (like Google) or if you connect your account to a social media service (like Facebook) through our integration feature, we’ll receive information from that service (e.g., your username, basic profile information, friends list) via the authorization procedures for that service. The information we receive depends on which services you use or authorize and what options are available.
Third-party services may also give us information, like mailing addresses for individuals who are not yet our Users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.
4. How and Why We Use Information
4.1. Purposes for Using Information
We use information about you for the purposes listed below:
(i) To provide our Services. For example, to set up and maintain your account, host your account, provide customer service and verify user information.
(ii) To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how Persons interact with our Services so we can create new features that we think our Users will enjoy and that will help them create and manage our Services more efficiently or make our Services easier to use.
(iii) To place and manage ads in our advertising program. For example, to place ads on our Services as part of our advertising program, and understand ad performance.
(iv) To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of Persons (like those who have a particular plan with us or have been Users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many Persons updated their account after receiving a marketing message), and understanding and forecasting user retention.
(v) To protect our Services, our Users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Tonsser and others, which may result in us, for example, declining a transaction or terminating Services.
(vi) To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
(vii) To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through our suggestions, and providing new player profiles and football stories for your reading pleasure.
(viii) To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Tonsser. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account and Services.)
(ix) To recruit and hire new Tonsser’s. For example, by evaluating job applicants and communicating with them.
4.2. Legal Basis for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
- The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our Services on your device; or
- The use is necessary for compliance with a legal obligation; or
- The use is necessary in order to protect your vital interests or those of another person; or
- We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or
5. Sharing Information
5.1 How We Share Information
We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in Section 12.2 called ’Ads and Analytics Services Provided by Others’:
- Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Tonsser, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you connected your site to a social media service through our integration feature.
- Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
- Interaction between Persons: If you interact with another Person using our Services, your information may be shared with the other Person and their representatives.
- Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other Users.
We have a long-standing policy that we do not sell our Users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.
We show ads on our Services, and the revenue they generate lets us offer free access to some of our Persons and Services so that money doesn’t become an obstacle.
Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online and on our services might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address, as part of our advertising program.
5.2. Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
That means information like your public profile, posts, other content that you make public on your account, and your interactions and comments are all available to others — and we hope they get a lot of views and interactions!
For example, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, is your ’Globally Recognized Avatar’, or Gravatar — get it? :) Your Gravatar, along with other public profile information, displays alongside the comments and interactions that you make on other Persons profiles while logged in to your account.
Please keep all of this in mind when deciding what you would like to share publicly.
6. How Long We Keep Information
We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the Section 4 above on ’How and Why We Use Information’ — and we’re not legally required to keep it.
For example, we keep the web server logs that record information about a visitors of Tonsser websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to our websites and investigate issues if something goes wrong on one of our websites.
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.
You have several choices available when it comes to information about you:
- Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information and profile information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, premium access, insights etc. that carry an additional charge — may not be accessible.
- Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our Tonsser App. If you choose to limit this, you may not be able to use certain features, like geotagging for captures.
- Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
- Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Close your account via the in Tonsser App support found in your profile. Please keep in mind that we may continue to retain your information after closing your account, as described in Section 6 ’How Long We Keep Information’ above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
9. Your Rights
If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.
9.1. European General Data Protection Regulation (GDPR)
If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
- Request access to your personal data;
- Request correction or deletion of your personal data;
- Object to our use and processing of your personal data;
- Request that we limit our use and processing of your personal data; and
- Request portability of your personal data.
You also have the right to make a complaint to a government supervisory authority.
9.2. California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it.
The CCPA also requires us to provide a list of the ’categories’ of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:
- Identifiers (like your name, contact information, and device and online identifiers);
- Characteristics protected by law (for example, you might provide your gender as part of setting up your account);
- Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an account administrator);
- Geolocation data (such as your location based on your IP address);
- Audio, electronic, visual or similar information (such as your profile picture or other picture/videos, if you uploaded one);
- Professional or employment-related information (for example, your company and team information, or information you provide in a job application); and
- Inferences we make (such as likelihood of retention or attrition).
You can find more information about what we collect and sources of that information in the ’Information We Collect’ Section 3 above.
We collect personal information for the business and commercial purposes described in the ’How and Why We Use Information’, Section 4. And we share this information with the categories of third parties described in the ’Sharing Information’, Section 5.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
- Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
- Request deletion of personal information we collect or maintain;
- Opt out of any sale of personal information; and
- Not receive discriminatory treatment for exercising your rights under the CCPA.
9.3. The CCPA & Personalized Advertising in Our Ads Program
The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a ’sale’ of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don’t knowingly sell personal information of those under 16.
9.4.Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to Section 11 ’How to Reach Us’ to, well, find out how to reach us.
When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a User, we will need you to contact us from the email address associated with your User account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may however still require you to verify your identity with us.
10. Controllers and Responsible Companies
Tonsser’s Services are worldwide and Tonsser ApS (our Danish-based company) is considered ‘controller’ of your personal data. Different Tonsser companies may be co-controller of personal information, which means that they are the company co-responsible for processing that information, based on the particular service and the location of the individual using our Services.
Depending on the Services you use, more than one company may be the co-controller of your personal data. Generally, the ‘controller’ is Tonsser ApS as noted above, alternatively, the Tonsser company that entered into the contract with you under the Terms of Service for the Services you use. In addition, Tonsser ApS, our Danish-based company, is the controller for some of the processing activities across all of our Services worldwide.
11. How to Reach Us
12. Other Things You Should Know (Keep Reading!)
12.1. Transferring Information
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
12.2. Ads and Analytics Services Provided by Others
12.3. Third-Party Software and Services
That’s it! Thanks for reading.
15. Change log