Version 1.0, Effective 2026-06-26

1. Introduction and scope

Reeplayer, Inc. ("Reeplayer," "we," "us," or "our") is a Delaware corporation with its principal place of business at 4213 Jackson Avenue, Culver City, California 90232, USA. We make cameras, software, and AI features that record youth and amateur sports, then turn that footage into clips, highlights, and performance stats for players, families, coaches, and clubs.

This Privacy Policy explains how we collect, use, share, and protect personal information across everything we do: the Reeplayer camera hardware, the Reeplayer app and website, and the AI and computer-vision systems that process footage and produce stats. It applies to everyone whose personal information we handle, whether or not they ever created an account.

There is an unusual and honest fact at the center of how Reeplayer works, and we want to state it plainly at the top rather than bury it. Reeplayer films live sports. That footage routinely captures people who never signed up for Reeplayer and never agreed to anything with us: players on the field, players on the other team, children of any age as filmed subjects, parents and spectators in the stands, and bystanders who happen to be nearby. We collect and process information about these people because filming a game is impossible without it. This policy describes what that means for you, whether you are an account holder, a person who appears in footage, or the parent or guardian of a child who appears in footage.

The adult who sets up or controls a camera (a coach, a club administrator, or a parent) is responsible for having the rights and consents needed to record and share that footage, including any consent required for a child. We describe that responsibility here and in our Terms of Service.

This Privacy Policy is part of, and incorporated into, the Reeplayer Terms of Service. Capitalized terms we do not define here have the meaning given in the Terms of Service. The Terms of Service govern your use of the service, including content ownership, the license you grant us, acceptable use, disclaimers, and dispute resolution. Where this policy and the Terms of Service overlap, read them together. If you do not agree with this policy, do not use Reeplayer.

This is Version 1.0, Effective 2026-06-26. We may update it as described in Section 16.

2. The short version

This is a plain-English summary. It is not a substitute for the full policy below, but it covers the things people ask about most.

1. You keep your footage. You own the video you record. We take a license to host it, process it, make clips and highlights, and run the service, but we do not take ownership of your content.

2. We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising (showing you ads based on your activity across other sites and apps). "Sell" and "share" here have the specific meanings California law gives them under the CCPA and CPRA. We do not do either with your personal information.

3. We film kids and bystanders who never signed up. That is how recording a live game works. The adult who controls the camera is responsible for the consents and notices that recording requires. We explain this throughout.

4. We do not run face recognition. We identify players by jersey number, team roster, and account, never by face. We do not run biometric identification today.

5. We show contextual ads on, within, around, and burned into content and livestreams, and across our apps, websites, and products. They are brand placements, never an endorsement. We never make a child look like a spokesperson or the face of an ad. You are not entitled to any payment when we monetize content.

6. We train our own AI on footage and stats to improve Reeplayer, and we can train and sell general sports computer-vision models and de-identified or aggregated data. You can opt out of having your content used to train our features. We keep player identity on jersey, roster, and account, never on a learned face.

7. A named, identifiable child appears publicly by name on leaderboards, stats, and game film as part of Reeplayer's core public stats and film product. A parent or guardian opt-in is required only to expose an identified child to an outside buyer, sponsor, or scout, or to feature a named child in Reeplayer's own marketing, or to target ads at an identified child.

Here is who can see an identified child, and what it takes:

Who sees the identified child What it takes The child's own family Automatic The child's own team or club Automatic Anyone, but only as anonymous or aggregate data Automatic The public, by name, on leaderboards, stats, and game film Automatic (the public stats and film product, like MaxPreps and GameChanger) An outside buyer, sponsor, or scout Needs the family's opt-in Marketing that features the named child Needs the family's opt-in As the face of an ad or an endorser Never

3. Information we collect, and from whom

Notice at collection. We provide this notice at or before the point at which we collect personal information, and we make this Privacy Policy available at the point of collection. The categories we collect, the purposes for which we use them, and whether each is sold or shared (we do not sell or share any category) are described in this Section 3 and in Sections 4, 8, and 14, and the retention periods are in Section 11.

We collect the following categories of information. Some comes from you directly, some is generated automatically as you use the service, and some is about people who are filmed but never created an account.

1. Account and profile information. When you create an account, we collect information such as your name, email address, password, the role you play (for example player, parent, coach, or club administrator), the team or club you belong to, and the jersey numbers and rosters you set up. A parent or guardian who consents on behalf of a minor provides information to establish that relationship.

2. Footage (video and audio). This is the heart of the service. We collect video and, where the camera captures it, audio of live sports. Footage can and routinely does include the faces, voices, bodies, movements, and jersey numbers of identifiable people. That includes minors as filmed subjects and bystanders who never created an account, such as other players, opposing teams, parents, spectators, and passers-by. Sideline audio can capture conversations of people near the camera.

3. Performance and game statistics. We generate and collect stats derived from footage, such as actions, events, positions, movement, pace, and play-by-play data, and we associate stats with players using jersey number, roster, and account.

4. Device, camera, and sensor data. We collect information from the Reeplayer camera and from the devices you use to access the app, such as device and camera identifiers, hardware and software versions, settings, sensor readings used for recording and tracking, diagnostic and crash logs, IP address, and connection information.

5. App usage and analytics. We collect information about how you use the app and website, such as features used, pages and screens viewed, clips watched, actions taken, timestamps, and similar usage and performance data.

6. Approximate location and region. We collect approximate location or region, for example derived from IP address or from the general location of a recording or a venue, to operate the service, group footage, apply the right legal rules, and prevent fraud. We do not need precise device GPS to run the core service.

7. Payment information. When you buy a subscription or hardware, payment is handled by a third-party payment processor. We receive limited information such as confirmation of payment, billing contact details, and the last digits and type of card. We do not store full payment card numbers ourselves.

8. Communications. When you contact us for support, respond to a survey, or otherwise communicate with us, we collect the content of those communications and related details.

We want to be explicit about one point that most policies leave vague. We collect information about people who are filmed but never created a Reeplayer account. If you appear in footage that an account holder records, we process information about you (such as your image, your jersey number, and stats tied to your play) even though you never signed up. Section 7 explains the special protections that apply when that person is a child, and Section 9 and Section 10 explain the choices and rights available to people who appear in footage.

4. How we use information

We use the information we collect for the following purposes.

1. To operate and deliver the service. We host and stream footage, store your content, run the camera and app, sync your data, and provide the features you sign up for.

2. To generate clips, highlights, and stats. We process footage to detect plays and events, cut clips and highlights, build game and player statistics, and assemble the views that players, families, coaches, and clubs use.

3. To identify and group players, never by face. We identify and group players using jersey number, team roster, and account. We do not identify players by face, and we do not fall back to face recognition when a jersey number is unreadable. We do not build a persistent body or gait signature that can re-identify a person on its own. Limb and pose tracking exists only to compute stats and analyze play, never to recognize who a person is. Section 5 covers this in more detail.

4. For safety, security, and fraud prevention. We use information to protect the service and its users, detect and prevent fraud and abuse, secure accounts, troubleshoot, debug, and enforce our Terms of Service and Acceptable Use Policy.

5. To improve our products and train our own AI features. We use footage, stats, and usage data to improve Reeplayer and to train and refine our own AI and computer-vision features. This use is on by default, you can opt out, and we de-identify where possible, with extra care for data relating to minors. Persistent identity stays on jersey, roster, account, and tracking, never on a learned face or appearance. Section 6 explains our AI and machine-learning practices, including the limits on what we train and sell.

6. For advertising that is never an endorsement. We display contextual ads on, within, around, and burned into content and livestreams, and across our apps, websites, and products. These are brand placements based on context, not on profiling an identified child, and they are never an endorsement. We never present a person, and never a minor, as a spokesperson or the face of an ad. We do not target ads at an identified child unless that child's parent or guardian has opted in as described in Section 7, and we do not sell or share personal information to advertisers as described in Section 8.

7. To communicate with you. We use your contact information to send service messages, respond to support requests, and, where permitted, send marketing about Reeplayer. You can opt out of marketing at any time.

8. For legal compliance and to protect rights. We use information to comply with applicable law, respond to lawful requests, establish, exercise, or defend legal claims, and protect the rights, property, and safety of Reeplayer, our users, and the public.

We rely on a lawful basis for each use where the law (such as the GDPR or UK-GDPR) requires one. Section 10 lists those bases.

5. Biometric information

We want to be as clear and plain as we can be on this point, because it is the question careful parents and coaches ask first.

Reeplayer does not run face recognition. Reeplayer does not run biometric identification of any kind today. We do not create or use a faceprint, a voiceprint, or any other biometric identifier to figure out who a person is.

Here is how player identification actually works. We identify and group players by jersey number, team roster, and account. When a jersey number cannot be read, we do not fall back to a person's face. We do not maintain a persistent body or gait signature that could re-identify someone on its own. We track limbs and pose, but only to measure movement and produce statistics about play, never to recognize identity.

We reserve broad rights to use AI and computer vision to run and improve the service, as described in Section 6. None of those rights mean we are doing biometric identification today, and this statement is meant to be relied on.

If we ever decide to introduce a face-recognition or other biometric-identification feature, that is a separate decision that we will gate on its own. Any such feature would be off by default. Before we collect or use any biometric identifier, we would provide a separate, specific notice and obtain the consent that applies to you, consistent with the Illinois Biometric Information Privacy Act (BIPA) and other applicable biometric-privacy laws. We will not quietly switch this on inside a routine update.

6. AI and machine learning

Reeplayer is built on AI and computer vision. This section explains what we train on, why, and the limits we put on ourselves.

1. What we train on, and why. We use footage, performance and game stats, and usage data to train, test, and improve our own AI and computer-vision features, such as detecting plays, cutting clips and highlights, tracking the ball and the action, and producing better statistics. This makes Reeplayer work better for everyone who uses it.

2. General sports models and de-identified or aggregated data. We may train, build, use, license, and sell general sports computer-vision models, for example models that understand the ball, actions, tracking, and pose, and we may build, license, and sell de-identified or aggregated data products. General models and de-identified or aggregated data do not identify any individual, so we may train on, use, license, and sell them freely.

3. Identity is never built on faces. The way Reeplayer keeps track of who is who stays on jersey number, roster, account, and movement tracking. We do not build identity on a learned face or on an appearance embedding that recognizes a specific person. A face-recognition or appearance re-identification model is the line we do not cross without separate, gated consent, consistent with Section 5 and with the Illinois BIPA.

4. The separable opt-out. Training our own features on your content is on by default, and you can turn it off. The opt-out is separable, meaning you can decline AI training without having to stop using Reeplayer. We de-identify where possible, with extra care for data relating to minors. Section 9 explains how to use this control.

5. The carve-out for an identified minor. This is the bright line. We will not sell or release any AI model or data product that is trained on, or that contains, an identified minor unless that child's parent or legal guardian has opted in. General models and de-identified or aggregated data are fine without that opt-in, because they do not identify a child. A model or data product that carries the identity of a specific child does not leave Reeplayer to an outside buyer without the family's affirmative opt-in.

6. Sub-processors and outside AI services are bound tightly. We may use outside AI services and other sub-processors to help us run and improve Reeplayer. When we do, each one is contractually bound so that it may process the data only to provide services to Reeplayer, may not reuse the data for its own purposes, and may not train its own models on the data. Every such provider operates under a written data processing agreement, and we maintain a published list of our sub-processors. The terms that govern this processing, and our current list of sub-processors, are set out in our Data Processing Addendum and Sub-processor List. We apply extra care to data relating to minors. Section 8 describes how we share information with these providers.

7. Children's privacy

This is the section that matters most, and it is the one most privacy policies get wrong, because they only think about children as account holders. At Reeplayer, children mostly appear as recorded subjects: kids on the field, kids on the other team, kids of any age caught in footage. We built this section around that reality.

1. Children appear as recorded subjects. Reeplayer films youth sports. Children of any age appear in footage as filmed subjects. They do not need an account to appear, and most never have one. We collect information about these children (their image, their jersey number, and stats tied to their play) because that is what recording a game produces.

2. The floor to hold an account is 13, and a guardian must consent for any minor. A person must be at least 13 to hold a Reeplayer account. For anyone under 18, a verifiable parent or legal guardian must consent to and is contractually responsible for that minor's use. Whoever sets up or controls a camera (a coach, a club, or a parent) is the responsible adult, and that adult must have the authority and consents required to record and share footage of the children in it. We do not knowingly let a child under 13 create an account.

   How a guardian gives this consent. A parent or legal guardian gives the media-consent for their child by accepting the Terms of Service on the child's behalf, as described in the guardian media-consent in our Terms of Service. We capture that consent at signup or at camera purchase.

3. The responsible-adult and verifiable-guardian model under COPPA. Because children appear as recorded subjects, the Children's Online Privacy Protection Act (COPPA) and its rule at 16 CFR Part 312 shape how we operate. Children under 13 do not hold Reeplayer accounts, but they routinely appear as filmed subjects, and the adult who controls the camera provides any parental consent that recording and sharing a child's footage requires, and that adult represents to us that they have it. In the limited situations where Reeplayer itself collects a child's personal information directly through an account, we first obtain verifiable parental consent, consistent with COPPA and its rule at 16 CFR Part 312. We collect a child's information to provide the service (clips, highlights, stats, and team film) and we apply the limits described in this policy. We do not condition a child's participation in normal team coverage on giving us more information than we need.

4. What a parent or guardian can do. A parent or legal guardian can, for their child:

   • Access the personal information we hold about the child.

   • Correct that information.

   • Delete the child's personal information that we hold, including the child's account data if any and, on request, footage-derived personal information about the child.

   • Refuse to permit our further collection or use of the child's information, understanding that this may mean the child can no longer use account features.

   • Control the identified-minor opt-in described below, and turn it off at any time.
     To make a request, use the contact details in Section 17. We will verify that you are the child's parent or guardian before we act.

5. The identified-minor opt-in is its own separate, affirmative toggle. Showing a public, named child on leaderboards, stats, and game film is part of Reeplayer's core public stats and film product, like MaxPreps and GameChanger, and is automatic. A parent's or guardian's opt-in is required only to show a specific, identified child to an outside buyer, sponsor, or scout, to feature a named child in Reeplayer's own marketing, or to target ads at an identified child. That opt-in is its own specific, affirmative parental toggle, for example "make my child discoverable to scouts." It is never bundled into the general terms acceptance, and accepting our Terms of Service never by itself opts a child into any of this. Showing a player's own highlights and stats to that player's own team and its audience, and showing identified players publicly by name on leaderboards, stats, and game film, is automatic editorial game coverage, not something that needs this opt-in.

6. The under-13 and under-16 sale-and-share rules. We do not sell or "share" personal information as the CCPA and CPRA define those terms, for anyone, including children. Independently, the law sets opt-in floors that we honor: under the CPRA we do not sell or share the personal information of a consumer we know to be under 16 without opt-in (a parent or guardian opts in for a child under 13, and a consumer at least 13 and under 16 may opt in for themselves), consistent with California Civil Code section 1798.120(c), and under COPPA, where we collect personal information directly from a child under 13 through an account, we obtain verifiable parental consent as that law requires, and for footage of children captured as filmed subjects we rely on the responsible adult who controls the camera to provide any required parental consent.

7. The California minor eraser right. If a minor in California is a registered user of Reeplayer, that minor can request that we remove content or information the minor posted, consistent with California Business and Professions Code section 22581. Removal may not be complete or instantaneous in every case, as the law allows, but we will honor the right as the statute provides. Parents and guardians can also request deletion as described above.

8. Extra care throughout. Everywhere this policy describes de-identification, training limits, sub-processor limits, and security, we apply extra care to data relating to children.

8. How we share information

We share personal information only in the limited ways described here. We do not sell it, and we do not "share" it for cross-context behavioral advertising.

1. Service providers and sub-processors. We share information with vendors that help us run Reeplayer, such as cloud hosting and storage, content delivery, AI and computer-vision processing, analytics, customer support, communications, and payment processing. Each operates under a written data processing agreement that limits the provider to processing the data only for Reeplayer, prohibits reusing the data for its own purposes, and prohibits training its own models on the data. We maintain a published list of our sub-processors, set out together with the terms that govern this processing in our Data Processing Addendum and Sub-processor List, and we apply extra care to data relating to minors.

2. Within your team and club. Footage, clips, highlights, and stats are shared with the people who are meant to see them, such as your team, your club, and their audience, as part of normal game coverage. A player's own highlights and stats appearing for that player's own team is automatic editorial coverage.

3. Sponsors and advertisers. Sponsors and advertisers receive aggregate and contextual placement only. They receive ad placements based on context and de-identified or aggregated information. They do not receive an identified child, and we do not target ads at an identified child, unless the child's parent or guardian has opted in as described in Section 7. We never present any person, and never a minor, as an endorser or the face of an ad.

4. Legal and safety disclosures. We may disclose information when we believe in good faith it is necessary to comply with applicable law or a lawful request, enforce our Terms of Service and Acceptable Use Policy, detect or prevent fraud, security, or technical issues, or protect the rights, property, or safety of Reeplayer, our users, or the public.

5. Business transfers. If Reeplayer is involved in a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, information may be transferred as part of that transaction. We will require the successor to honor this policy, or we will give you notice and choices consistent with applicable law. The protections for an identified minor described in this policy continue to apply.

6. With your direction or consent. We share information when you direct us to, or with consent you provide, including through the identified-minor opt-in.

We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising, using the specific meanings the CCPA and CPRA give those words. We do not trade it for money or anything else of value, and we do not hand it over to power ads that follow you across other sites and apps.

9. Your choices and controls

You have meaningful controls over what Reeplayer does with information it actually controls. Some things, like footage of a shared game that belongs to the account holder who recorded it, the public display of identified players by name on leaderboards, stats, and game film (Reeplayer's core public stats and film product, like MaxPreps and GameChanger), contextual ads, footage-level training to improve our features (subject to the opt-out below), and other users resharing, are part of how a shared sports platform works and are not subject to an individual opt-out. The controls below are the ones we offer, and they are real.

1. AI training opt-out. Training our own features on your content is on by default, and you can turn it off. This control is separable, so you can decline training and keep using Reeplayer. See Section 6.

2. Marketing opt-out. You can opt out of marketing communications at any time, using the unsubscribe link in our emails or the contact details in Section 17.

3. Account deletion. You can delete your account and ask us to delete your account data. See Section 11 for how deletion interacts with retention, backups, and de-identified data.

4. The identified-minor opt-in toggle. A parent or guardian controls whether a specific, identified child is exposed to an outside buyer, sponsor, or scout, featured in Reeplayer's own marketing, or targeted with ads, as described in Section 7, and can turn that toggle off at any time. This opt-in is never bundled into terms acceptance.

To use any of these controls, adjust the settings in your account where available, or contact us using the details in Section 17. Section 10 describes additional rights that may apply to you under California, EEA, and UK law.

10. Your privacy rights

Depending on where you live, you have privacy rights described below. We honor these rights for the people the relevant law protects, including, where applicable, people who appear in footage but never created an account. To exercise a right, contact us as described at the end of this section.

California residents (CCPA and CPRA)

If you are a California resident, you have the right to:

1. Know and access. Request the categories and specific pieces of personal information we have collected about you, the sources, the purposes for collecting it, and the categories of third parties to whom we disclose it.

2. Delete. Request deletion of personal information we collected from you, subject to legal exceptions.

3. Correct. Request correction of inaccurate personal information.

4. Opt out of sale or sharing. We do not sell or "share" personal information as those terms are defined, so there is nothing to opt out of, but you retain the right. Because we do not sell or share personal information, there is no sale or sharing for an opt-out preference signal such as the Global Privacy Control to stop. If we ever sell or share personal information, we will treat a Global Privacy Control or other recognized opt-out preference signal as a valid request to opt out for that browser or device, and we will update this policy.

5. Limit the use of sensitive personal information. Request that we limit the use and disclosure of sensitive personal information to what is necessary to provide the service. We do not use sensitive personal information to infer characteristics or for purposes that would trigger this right beyond providing and improving the service.

6. Non-discrimination. We will not discriminate against you for exercising your rights.

7. Authorized agent. Use an authorized agent to submit a request on your behalf, with proof of authorization.

8. Appeal. If we deny your request, you may appeal by contacting us using the details in Section 17.

We do not use your personal information for decisions that produce legal or similarly significant effects through solely automated processing in a way that triggers additional rights, and we will update this policy if that changes.

EEA and UK residents (GDPR and UK-GDPR)

If you are in the European Economic Area or the United Kingdom, you have the right to:

1. Access the personal data we hold about you.

2. Rectification of inaccurate or incomplete personal data.

3. Erasure of your personal data in the circumstances the law provides.

4. Restriction of processing in the circumstances the law provides.

5. Data portability, to receive certain data in a portable format and, where feasible, have it transmitted to another controller.

6. Object to processing based on our legitimate interests, and to object to direct marketing at any time.

7. Withdraw consent at any time where we rely on consent, without affecting processing done before withdrawal.

8. Not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. Reeplayer's automated processing produces clips, highlights, and statistics and groups players by jersey, roster, and account; it does not make solely automated decisions that have legal or similarly significant effects on you. If that ever changes, we will update this policy and provide the safeguards the law requires.

9. Lodge a complaint with your local data protection supervisory authority. We would appreciate the chance to address your concern first.

Lawful bases we rely on. Where the GDPR or UK-GDPR applies, we process personal data on these bases:

• Performance of a contract, to provide the service you or your team signed up for.

• Our legitimate interests, such as operating, securing, and improving Reeplayer, providing contextual advertising, and training and improving our own AI and computer-vision features, subject to your right to object and the opt-out described in Section 9, balanced against your rights.

• Consent, where we ask for it, such as the identified-minor opt-in described in Section 7 and any future biometric feature. You can withdraw consent at any time.

• Compliance with a legal obligation, where the law requires us to process data.

For people who are filmed but never created an account, including bystanders, opposing players, and children appearing as filmed subjects, we cannot and do not rely on your consent, because we are not the party that records you. We rely on our legitimate interests, and on those of the account holder and team, in capturing and producing game footage, balanced against your rights, and the account holder is responsible under our Terms of Service for obtaining any consent or providing any notice that local law requires. Where the law that applies to you does not permit us to rely on legitimate interests for this processing, you have the rights described in this Section 10, including the right to object and the right to request removal and deletion as described in Sections 7 and 9.

How to submit a request, and how we verify it

Submit a request using the contact details in Section 17. To protect you, we will take reasonable steps to verify your identity before we act, which may mean matching information you give us against what we hold, or asking for confirmation through your account. For a request about a child, we will verify that you are the child's parent or legal guardian. For an authorized-agent request, we will ask for proof of authorization. We will respond within the timeframes the applicable law requires.

11. Data retention

We keep personal information only as long as we need it, on the following framework.

1. While your account is active. We keep your footage and the data tied to your account while your account is active and as needed to provide the service.

2. After your account closes. We delete or de-identify the personal data tied to your account within about 90 days after your account is closed, except where we need to keep specific information longer to comply with law, resolve disputes, prevent fraud or abuse, or enforce our agreements.

3. Backups. Personal data can persist in routine backups for a short window after deletion from active systems. We purge personal data from backups within about 180 days.

4. De-identified or aggregated data. We may keep de-identified or aggregated data indefinitely, because it does not identify any individual. We do not attempt to re-identify it.

5. Content license survival. As described in our Terms of Service, the content license can survive deletion only for the limited windows in this Section 11. In practice this means a copy of footage may persist in routine backups until they are purged within about 180 days, and any clip or highlight we already distributed within the service is removed from active Reeplayer surfaces on deletion and ages out of caches and downstream copies within about 90 days, with backups purged within about 180 days.

6. Legal hold. If we are required to preserve information for a legal, regulatory, or litigation reason, a legal hold suspends these deletion timelines for the affected data until the hold is lifted.

7. Footage and data about people who never held an account. We retain footage and the data derived from it (including footage and stats of children who appear as recorded subjects) only as long as reasonably necessary to provide and support the service, after which we delete or de-identify it, and a parent or guardian can ask us to delete a child's personal information sooner as described in Section 7. We apply extra care to data relating to children, consistent with COPPA's requirement to keep a child's information only as long as reasonably necessary.

Specific operational tier sizes, such as how many hours or how much storage a given plan includes, may appear on our pricing page, and those numbers can change. The retention periods that govern your personal information are the ones in this Section, not the pricing page.

12. Security and breach notification

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, and destruction. These include measures such as access controls, encryption in transit, monitoring, and contractual protections with our service providers. No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security.

If we become aware of a breach of security that compromises personal information, we will notify affected individuals and any regulators as required, without unreasonable delay, consistent with California Civil Code section 1798.82 and other applicable breach-notification laws. We apply extra care where a breach could affect data relating to children.

13. International users and data transfers

Reeplayer is based in the United States, and we and our service providers process and store information in the United States. If you use Reeplayer from outside the United States, including from the EEA or the United Kingdom, you understand that your information will be transferred to and processed in the United States and other countries where we or our service providers operate, which may have different data-protection laws than your own.

For transfers of personal data from the EEA or the United Kingdom to the United States, we rely on appropriate safeguards as required by law, such as the Standard Contractual Clauses approved by the European Commission and the UK addendum or equivalent mechanism, together with additional measures where appropriate. You may contact us using the details in Section 17 to ask about these safeguards.

We apply one governing-law choice, California, across this policy and our Terms of Service, together with savings clauses. Those savings clauses mean that nothing in this policy or the Terms of Service takes away any non-waivable right that the mandatory law of your own country, state, or region gives you. Where local law grants you a right that we cannot lawfully override, that right applies to you. This mirrors the savings clause in our Terms of Service, and the two are intended to be read consistently.

Reeplayer is based in the United States and does not currently direct its services to, or monitor individuals in, the European Economic Area or the United Kingdom. If and when Reeplayer offers services to or monitors individuals in the EEA or the UK, it will designate representatives under Article 27 of the GDPR and the UK-GDPR and update this policy.

14. Region-specific disclosures

California (CCPA and CPRA)

This section provides the disclosures the CCPA and CPRA require for California residents, in addition to the rights described in Section 10.

Categories of personal information we collect. In the past 12 months, we have collected the following categories of personal information, as defined by the CCPA and CPRA:

• Identifiers, such as name, email address, account identifiers, device identifiers, and IP address.

• Customer records information, such as billing contact details and limited payment information held by our processor.

• Commercial information, such as subscription and purchase records.

• Internet or other electronic network activity information, such as app and website usage and analytics.

• Geolocation data, in the form of approximate location or region.

• Audio, visual, and similar information, namely the footage (video and audio) at the center of the service, which can include images and voices of account holders, minors, and bystanders.

• Professional or sports-performance information in the form of game and player statistics.

• Inferences drawn to provide stats and operate the service.
  Some of this information, such as footage that captures a person's image and voice and information relating to a known child under 13, can be sensitive. We use sensitive personal information only to provide and improve the service and for the purposes described in this policy, not to infer characteristics about you for unrelated purposes.

Purposes. We collect these categories for the purposes described in Section 4, including operating the service, generating clips, highlights, and stats, identifying players by jersey, roster, and account, safety and security, improving our products and training our own AI features (with the opt-out in Section 9), contextual advertising, and legal compliance.

Sources. We collect information from you, automatically from the camera, app, and your devices, and from people who are filmed but never created an account, as described in Section 3.

Disclosures. We disclose the categories above to the types of recipients described in Section 8, namely service providers and sub-processors under a data processing agreement, the user's own team and club, sponsors and advertisers (aggregate and contextual only, and never an identified minor without the family's opt-in), legal and safety recipients, and parties to a business transfer.

No sale, no share. We do not sell personal information, and we do not "share" personal information for cross-context behavioral advertising, as the CCPA and CPRA define "sell" and "share." We do not exchange personal information for money or other valuable consideration in a way that meets the legal definition of a sale, and we do not disclose personal information for cross-context behavioral advertising in a way that meets the legal definition of a share. We have not done so in the past 12 months. Because we do not sell or share personal information as those laws define those terms, there is no sale or sharing for an opt-out preference signal such as the Global Privacy Control to stop. If we ever sell or share personal information, we will treat a Global Privacy Control or other recognized opt-out preference signal as a valid request to opt out for that browser or device, and we will update this policy.

Retention. For each category of personal information listed above, we retain it for the period described in Section 11. In summary: account-tied personal data is deleted or de-identified within about 90 days after account closure; backups purge within about 180 days; and de-identified or aggregated data may be kept indefinitely. Where a fixed period is not possible for a category, we keep it for as long as reasonably necessary for the purpose for which it was collected and to meet our legal, security, and dispute-resolution needs. Operational tier sizes, such as how much storage or how many hours a given plan includes, may appear on our pricing page, but that page is not the source of these retention periods.

EEA and UK (GDPR and UK-GDPR)

Controller. The data controller for personal data covered by this policy is Reeplayer, Inc., 4213 Jackson Avenue, Culver City, California 90232, USA. Contact details are in Section 17.

Lawful bases. We process personal data on the lawful bases listed in Section 10: performance of a contract, our legitimate interests (which include training and improving our own AI and computer-vision features, subject to your right to object and the opt-out in Section 9), consent (such as the identified-minor opt-in and any future biometric feature), and compliance with a legal obligation. For people who are filmed but never created an account, we rely on legitimate interests as described in Section 10, not on your consent.

Special-category data. We do not process footage for the purpose of uniquely identifying anyone, so we do not use it as biometric data under Article 9 of the GDPR or UK-GDPR. Where footage incidentally reveals information that those laws treat as special category, we do not use it for any special-category purpose; we process it only as strictly necessary to provide the service, we apply the extra-care measures described in this policy, and the account holder is responsible under our Terms of Service for any consent that local law requires. We do not rely on incidental special-category content to make decisions about you. To the extent any processing of special-category data nonetheless occurs, we rely, as applicable, on your or the responsible adult's explicit consent under Article 9(2)(a), and on the establishment, exercise, or defense of legal claims under Article 9(2)(f); and the account holder is responsible under our Terms of Service for obtaining any consent local law requires. This area is one we have flagged for a one-time licensed-counsel review before go-live.

Your rights and complaints. Your GDPR and UK-GDPR rights are listed in Section 10, including the right to lodge a complaint with your supervisory authority. International transfers are described in Section 13.

EU and UK representatives. Reeplayer is based in the United States and does not currently direct its services to, or monitor individuals in, the EEA or the UK. If and when Reeplayer offers services to or monitors individuals in the EEA or the UK, it will designate representatives under Article 27 of the GDPR and the UK-GDPR and update this policy.

Other regions

If you are in another region with applicable data-protection law, we honor the rights and protections that law grants you, read together with the savings-clause approach described in Section 13. Contact us using the details in Section 17 to exercise a right.

15. Cookies and similar technologies

We and our service providers use cookies and similar technologies, such as local storage, software development kits, and device identifiers, to run the service, remember your settings, keep you signed in, measure usage and performance, and improve Reeplayer. We do not use these technologies for cross-context behavioral advertising in a way that constitutes a "sale" or "share" under California law. You can control some of these technologies through your browser or device settings, though turning them off may affect how the service works. We may publish a separate Cookie Notice with more detail, which would be incorporated into this policy by reference.

16. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will change the version and effective date at the top, and we will post the updated policy. For material changes, we will provide more prominent notice, such as an in-app notice or an email, before the change takes effect, consistent with applicable law.

For a material change to how we collect, use, or share data relating to children, we will obtain affirmative re-consent from the responsible parent or guardian where the law requires it, rather than relying on continued use alone. Your continued use of Reeplayer after an update takes effect means you accept the updated policy, except where we are required to obtain your consent.

17. How to contact us

If you have a question about this Privacy Policy, or you want to exercise a privacy right, contact us:

Reeplayer, Inc.
Attn: Privacy
4213 Jackson Avenue
Culver City, California 90232
USA

Privacy contact email: legal@reeplayer.com. Privacy questions and requests go to legal@reeplayer.com.

Data protection officer. Reeplayer is not required to appoint a Data Protection Officer and has not appointed one. Send privacy questions and requests to legal@reeplayer.com.

EEA and UK representatives. Reeplayer is based in the United States and does not currently direct its services to, or monitor individuals in, the EEA or the UK. If and when Reeplayer offers services to or monitors individuals in the EEA or the UK, it will designate representatives under Article 27 of the GDPR and the UK-GDPR and update this policy.

For requests about a child, please tell us you are contacting us as a parent or legal guardian so we can verify the relationship and help you with access, correction, deletion, and the identified-minor opt-in described in Section 7.