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Privacy Policy

Locker23 Privacy Policy

Effective Date: [Insert Date]
Last Updated: [Insert Date]


1. Who We Are

Locker23 Ltd (“Locker23”, “we”, “us”, “our”) is a global soccer showcase platform that enables players to create profiles and allows coaches to view player profiles, create shortlists, and request contact information.

Locker23 is a tool only. We do not recruit, scout, endorse, represent, or act as an intermediary for players or coaches. We do not facilitate, host, monitor, or control communications between users. Any communication or engagement between players and coaches occurs off the Locker23 Platform and only after a player chooses to share their contact information.

Locker23 does not guarantee, arrange, or take responsibility for any scholarships, trials, contracts, offers, or opportunities, and is not responsible for the content, conduct, or outcomes of any off-platform interactions.

Locker23 is the data controller for personal data processed through the Platform.

Contact:
📧 contact@locker23.com


2. Eligibility, Age Requirement, and Profile Completion

Eligibility and Age Requirement

Locker23 is available only to individuals aged 16 or older.

The Platform is not directed to children and Locker23 does not knowingly collect or process personal data relating to individuals under the age of 16. If we become aware that personal data belonging to an individual under 16 has been collected, we will delete it promptly.

Profile Completion Requirement

Locker23 is a player–coach discovery platform. Certain profile information is required because search, discovery, and visibility features cannot function without player and coach data.

Users must complete the required portions of their profile before accessing core Platform features.


3. Personal Data We Collect

Identity Data

Name, date of birth, gender, nationality, and passport-holding country or countries.

Purpose of Passport Information

Locker23 asks players to indicate the country or countries whose passport(s) they hold. This information is collected solely to help coaches understand a player’s potential eligibility for travel, trials, training, or competition, and to support preliminary planning relating to immigration, visa, or work authorisation requirements.

Locker23 does not collect passport numbers, passport images, visa documents, or other government-issued identification documents, and does not provide immigration, visa, or legal advice.

Contact Data

Email address and phone number.

Educational and Soccer Background

Education history, school or academy information, soccer playing history, positions played, and competitive level.

Soccer Characteristics and Performance Data

Playing characteristics, strengths, statistics, awards, and other soccer-related performance information.

Optional Profile Content

At the player’s discretion, photos, soccer highlight videos, performance statistics, references, and school grades.

Academic information, references, statistics, and other profile content are provided voluntarily by players and are not independently verified by Locker23.

Subscription Data

Subscription status and related billing information (processed securely by third-party payment providers).

Technical Data

IP address, device type, browser type, operating system, cookies, log files, and similar technical information.

Usage Data

Profile views, shortlist activity, contact information requests, notification events, and support inquiries.

Marketing Preferences

Preferences regarding receipt of marketing or promotional communications.

Important: Locker23 does not request or require medical or health information. Players should not upload sensitive medical data to the Platform.


4. How We Collect Your Data

Information You Provide Directly

  • When you create an account

  • When you complete or update your profile

  • When you upload optional content

  • When you subscribe to premium features

  • When you contact customer support

Information Collected Automatically

  • Through cookies and analytics tools

  • When you interact with Platform features and notifications

Information from Third Parties

  • Service providers (such as hosting, analytics, and payment processors)

  • Other users may submit references only where you have chosen to allow this


5. How Information Is Shared on the Platform

Profile Visibility

Player profiles are visible to other users on the Platform in accordance with your visibility settings. Profile information may include athletic, educational, and performance-related data that you choose to make available.

Passport-holding information is displayed only as country-level information and only to other registered users in accordance with the player’s visibility settings.

Coach Information Display

When a coach submits a contact information request, players are shown basic identifying information, which may include:

  • Name

  • Professional title or role

  • Nationality

  • Country in which the coach operates

Contact Information Requests

  • Direct contact information is not shared by default

  • Players receive a Platform notification when a request is submitted

  • Players must actively approve any request

  • Once approved, communication takes place off the Platform

Locker23 does not participate in, monitor, or control off-platform communications.


6. Player-Controlled External Sharing

Players may choose to share their Locker23 profile or profile content externally, including by sharing links or exporting profile materials.

Locker23 is not responsible for how information is used by third parties once shared outside the Platform.


7. How We Use Your Personal Data

We use personal data to:

  • Operate and maintain the Platform

  • Display player profiles to other users

  • Enable shortlisting and contact information requests

  • Process subscriptions and payments

  • Provide customer support

  • Improve security and platform functionality

  • Send essential service communications

  • Send marketing communications (where consent is given)

  • Comply with legal and regulatory obligations

Automated System Notifications

Locker23 uses automated system notifications to support account functionality, platform security, and user awareness. These may include alerts relating to logins, profile views, shortlist activity, and contact information requests.

These notifications are essential to the operation of your account.

Premium Features

Players may choose to subscribe to optional premium features. Where a player subscribes, Locker23 may process additional usage and notification data to enable premium functionality, including expanded profile customisation, additional uploads, advanced filters, and enhanced notifications.

Subscription status does not guarantee visibility, contact, recruitment outcomes, scholarships, trials, or contracts.


8. Legal Bases for Processing

We process personal data under the following lawful bases:

  • Contractual necessity

  • Legitimate interests (security, fraud prevention, service improvement)

  • Consent (marketing communications)

  • Legal obligations


9. Sharing Your Personal Data

We may share personal data with:

  • Other users on the Platform, as described in this Policy

  • Trusted service providers acting on our behalf

  • Legal or regulatory authorities where required

We do not sell, rent, or trade personal data.

Business Transfers

If Locker23 is involved in a merger, acquisition, financing, reorganisation, or sale of assets, personal data may be transferred subject to appropriate safeguards and applicable law.


10. International Data Transfers

As a global platform, personal data may be transferred outside the UK or EEA. Where this occurs, we implement appropriate safeguards, including:

  • UK-approved Standard Contractual Clauses

  • Adequacy decisions

  • Technical and organisational security measures


11. Data Security

We implement appropriate technical and organisational measures to protect personal data, including encryption and access controls.

You are responsible for keeping your account credentials confidential.


12. Data Retention

We retain personal data only for as long as necessary:

  • While your account remains active

  • Up to 24 months after your last activity, unless legally required

Users may delete their account at any time. Personal data will be deleted or anonymised in accordance with this Policy, subject to legal retention requirements.


13. Your Data Protection Rights

You have the right to:

  • Access your personal data

  • Correct inaccurate or incomplete data

  • Request deletion or restriction of processing

  • Object to processing

  • Withdraw consent (where applicable)

  • Request data portability

You may lodge a complaint with the UK Information Commissioner’s Office (ICO):
🌐 www.ico.org.uk

To exercise your rights, contact:
📧 contact@locker23.com


14. Cookies

We use cookies to:

  • Ensure core Platform functionality

  • Analyse usage

  • Improve performance

Locker23 does not engage in cross-app tracking for advertising purposes without consent. Where required by law, we obtain consent for non-essential cookies.

See our Cookie Policy for more information.


15. Third-Party Links

The Platform may contain links to third-party websites. We are not responsible for their content or privacy practices.


16. US State Privacy Rights

If you are a resident of certain US states, you may have rights under applicable state privacy laws, including the right to access, correct, delete, or obtain a copy of your personal data, and to opt out of certain processing activities.

To exercise your rights, contact:
📧 contact@locker23.com

Notice for California Residents

Locker23 does not sell personal information and does not share personal information for cross-context behavioural advertising as defined under the CCPA.

Requests to exercise California privacy rights may be submitted by contacting:
📧 contact@locker23.com


17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The most current version will always be available at:

🌐 www.locker23.com/privacy-policy

If changes are material, we will notify users via email and/or prominent Platform notifications.