Privacy Policy

FTC Sports Media LLC ("we," "our," or "us") respects your privacy.

This Privacy Policy describes how we collect, use, disclose, and protect your information when you access or use the From the Crease mobile application, website, and related online services (collectively, the "Platform"). This policy applies to all users, including those accessing from outside the United States. If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, this Policy is intended to meet our obligations under the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and the Swiss Federal Act on Data Protection, as applicable, and the additional disclosures below that refer specifically to the EEA, UK, or Switzerland apply to you.

We collect the following types of information when you use our platform and related Services:

● Account Information: Name, email address, age, password (hashed), and, for any user under 16 — a threshold we apply globally as a matter of company policy, regardless of any lower age threshold that might otherwise apply under local law — verified guardian contact information obtained through our parental verification process, and confirmed guardian consent (see Section 4).
● Usage Data: Information about your device, operating system, app version, IP address, and in-app activity (via Firebase Analytics, Google Analytics for Firebase, and similar tools).
● Payment Data: Managed securely through Apple and Google for in-app purchases. We do not store payment details.
● User Interaction Data: Feedback or inquiries submitted through in-app forms, email links, or chat tools, including feedback and messages exchanged between a coach and an athlete, which we moderate as described in Section 4A.
● Organization Information: If your account is provided through a hockey association, club, academy, school, or other organization, we may collect information necessary to administer your account, including organization name, administrator information, seat assignments, and subscription status.
● Cookies and Similar Tracking Technologies: see Section 6 below for the categories of cookies and SDKs we use and your consent choices.

We use your information to:

● Provide access to platform content and features.
● Improve functionality, usability, and performance of the platform.
● Respond to support inquiries, feedback, or service issues.
● Administer organization subscriptions, seat assignments, and user management where applicable.
● Ensure a safe, secure, and appropriate user experience across all Services, including by moderating coach-athlete communications and providing guardian transparency reports as described in Section 4A.
● Comply with legal obligations and enforce our Terms of Use.

For users in the EEA, United Kingdom, Switzerland, or other regions with similar regulations, our legal basis for processing your personal data depends on the specific purpose:

● Contract performance (Art. 6(1)(b) GDPR): to create and administer your account, provide platform features, and manage subscriptions.
● Consent (Art. 6(1)(a) GDPR): for non-essential cookies and analytics, any optional communications, and guardian consent for users under 16. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
● Legal obligation (Art. 6(1)(c) GDPR): to comply with applicable law and respond to lawful requests from public authorities.
● Legitimate interests (Art. 6(1)(f) GDPR): to maintain the security of the Services, prevent fraud, improve functionality, and protect the safety of minor athletes through communication moderation and guardian transparency reports (Section 4A), balanced against your rights and interests.

We will not use your personal data for a new purpose that is incompatible with these bases without notifying you and, where required, obtaining fresh consent.

This section supplements Section 9 (Your Rights) for users located in the EEA, United Kingdom, or Switzerland. Subject to applicable law, you have the right to:

● Access the personal data we hold about you and receive a copy of it;
● Rectify inaccurate or incomplete personal data;
● Erase your personal data ("right to be forgotten") in certain circumstances;
● Restrict or object to our processing of your personal data, including processing based on legitimate interests;
● Receive your personal data in a portable format and transmit it to another provider;
● Withdraw consent at any time where processing is based on consent;
● Not be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. Our automated moderation tools (see Section 4A) may take immediate automated action to contain a safety risk, but any suspension, termination, or other punitive action taken against your account is reviewed by a person before it is finalized; and
● Lodge a complaint with your local data protection supervisory authority (in Germany, the state (Land) data protection authority responsible for your place of residence, or the Federal Commissioner for Data Protection and Freedom of Information (BfDI), as applicable).

To exercise these rights, contact us at support@fromthecrease.com. We will respond within one month of a verified request, which we may extend by a further two months for complex or numerous requests, in which case we will explain the delay to you.

Our Services are designed for goaltenders of all ages, including minors, often accessed through a hockey Organization such as a club, school, or association. As a matter of global company policy, if you are under the age of 16 — regardless of your location, and regardless of any lower age threshold that might otherwise apply under local law, including the 13-year threshold under COPPA in the United States — you must have the verified consent of a parent or legal guardian before creating an account or otherwise providing personal information to us. We use a parental verification process, described to you at sign-up, to confirm that a parent or legal guardian has provided that consent before we grant account access to a user under 16.

Where your access is provided through an Organization, that Organization is responsible for obtaining and documenting the required verified guardian consent before enrolling you, consistent with our Organization Subscription Agreement. We do not knowingly collect personal information from a child below 16 without such consent, and we will delete any such information we learn we have collected without valid consent. See Section 4A for additional safety features that apply to communications involving athletes under 16.

To help protect the safety of goaltenders using the App, feedback and other communications exchanged between a coach and an athlete within the App are automatically moderated using automated tools designed to help identify unsafe, abusive, or otherwise inappropriate content.

Where our moderation tools identify an immediate safety risk, we may take automated action right away to contain the risk. Any suspension, termination, or other punitive action taken against a user's account as a result of moderation is reviewed by a person before it is finalized; moderation alone does not result in that kind of action.

If the athlete is under 16, the athlete's verified parent or guardian will receive a weekly transcript or summary of the feedback exchanged between the coach and the athlete, to support transparency, accountability, and safety. By exchanging messages with an athlete a coach knows or should know is under 16, the coach acknowledges and agrees that this communication will be shared with that athlete's verified parent or guardian on this basis.

Either a coach or an athlete may block the other party at any time, which immediately ends further communication between them. Blocking does not retract a transcript already delivered to a guardian, and does not itself cause us to delete the underlying moderation records for that connection early; those records remain subject to the retention period described in Section 5, since they may be needed for a safety review even after a block occurs.

We process this information on the basis of our legitimate interest in providing a safe environment for minor athletes (Art. 6(1)(f) GDPR) and, where applicable, the guardian consent described in Section 4.

We retain personal information only as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law, consistent with the storage-limitation principle under Art. 5(1)(e) GDPR. As a general matter: (a) account information is retained for as long as your account remains active and for a limited period thereafter to allow reactivation and to meet legal, accounting, or dispute-resolution needs; (b) Organization-related account and seat information is retained for the duration of the applicable Organization subscription and a reasonable period afterward for administrative and audit purposes; (c) moderation logs and guardian transparency transcripts described in Section 4A are retained for the duration of the coach-athlete connection and afterward, to support safety reviews and accountability, investigation, dispute, or legal obligation; and (d) usage and analytics data is retained according to the standard retention settings of our analytics providers, described in Section 6. Where we cannot state a precise retention period because it depends on business, legal, or regulatory need, we determine an appropriate period using these criteria.

We and our service providers use cookies, mobile SDKs, and similar tracking technologies to collect usage data, remember preferences, and improve the Services. These fall into two categories:

● Strictly necessary technologies required for the Platform to function (e.g., session management, security) — these do not require consent.
● Analytics and performance technologies, such as Firebase Analytics and Google Analytics for Firebase, which help us understand how the Platform is used.

For users in the EEA, United Kingdom, and Switzerland, we obtain your opt-in consent before activating any non-essential analytics or tracking technology, consistent with Section 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG) and the ePrivacy Directive as implemented in your jurisdiction. You will be presented with a consent prompt on first use of the App that lets you accept or reject non-essential tracking with equal ease, and non-essential technologies will not run before you respond. You may withdraw consent at any time through in-app privacy settings. Declining non-essential tracking will not restrict your access to core App features. You can also manage data collection preferences through your device settings. This section covers analytics and performance cookies/SDKs; it does not apply to the safety-related moderation of coach-athlete communications described in Section 4A, which is not a tracking technology and is not optional for the reasons explained there.

We do not sell your personal data. We may share limited data with trusted service providers (such as Firebase, SendGrid, RevenueCat, and Google Analytics) solely for the purposes of operating and maintaining our platform and Services. These service providers act as our data processors and are contractually bound to use your information only as we instruct and to implement appropriate security measures. Where a service provider processes personal data outside the EEA, UK, or Switzerland (including in the United States), we rely on the safeguards described in Section 11 (International Data Transfers) to ensure your data receives an equivalent level of protection.

If your account is managed through an organization, we may share limited account information, subscription status, and seat assignment information with authorized administrators of that organization solely for the purpose of administering your account and subscription. If you are an athlete under 16, we also share a weekly transcript or summary of your coach-athlete communications with your verified parent or guardian, as described in Section 4A.

We do not share your information with third parties for their marketing purposes.

We use industry-standard security measures to protect your information. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify affected users and, where legally required, the competent supervisory authority, without undue delay.

You may request access to, correction of, or deletion of your personal information by contacting support. If your account is managed by an organization, certain requests regarding your account may need to be directed through your organization administrator. We will respond to such requests within one month of receipt (which we may extend by a further two months for complex or numerous requests, in which case we will explain why), free of charge in most cases, where required by law.

If you are a California resident, you may have certain rights under the California Consumer Privacy Act (CCPA), including the right to know what personal data we collect, the right to delete it, and the right to opt out of its sale (which we do not do). You may exercise your rights by contacting us at support.

We are based in the United States, and personal information we collect will generally be processed and stored there. Where we or our service providers transfer personal information of users located in the EEA, United Kingdom, or Switzerland to the United States or another country not recognized as providing an adequate level of data protection, we do so on the basis of appropriate safeguards, which may include the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions, for certified recipients) or Standard Contractual Clauses approved by the European Commission, together with supplementary measures where necessary. You may request further information about these safeguards by contacting us at support@fromthecrease.com.

We may update this Privacy Policy at any time. Any changes will be posted within the platform with an updated effective date. For material changes affecting users in the EEA, UK, or Switzerland, where required by law we will provide additional notice or seek renewed consent before the changes take effect.

Subscription Purchases

When you purchase a subscription within the app, we collect certain information required to process your payment. This may include your name, email address, device information, and transaction details. All payments are handled securely through third-party payment processors such as Google Play Billing, Apple In-App Purchases, or other authorized payment gateways. We do not store or have access to your full payment card information. This information is processed on the basis of contract performance (Art. 6(1)(b) GDPR).

Auto-Renewal

Some subscriptions may renew automatically unless you cancel them before the renewal date. Auto-renewal settings can be managed directly through your Google Play or Apple App Store account settings. We do not have the ability to modify, cancel, or refund subscriptions on your behalf.

Subscription Status Verification

To provide paid features, the app may check your subscription status through Google Play or Apple APIs. This requires us to store or validate certain identifiers such as order IDs, purchase tokens, or subscription validity timestamps. This information is used only to confirm whether your subscription is active and to unlock the appropriate features.

Refunds & Cancellations

Refunds are processed according to Google Play or Apple App Store refund policies. Users must request refunds directly from the respective store. We do not manage refunds internally.

How We Use Subscription Data

Subscription-related data is used for:

● Managing access to premium or paid features
● Verifying subscription validity
● Providing customer support
● Preventing fraudulent transactions

We do not sell, rent, or share your subscription or billing information with third parties except payment processors and service providers required for subscription management.

Third-Party Payment Processors

Your financial information is securely processed by trusted third-party providers. Their use of your personal information is governed by their own Privacy Policies.

FTC Sports Media LLC is the data controller responsible for your personal information under this Policy. Where required by Art. 27 of the GDPR or the equivalent provision of the UK GDPR, we will appoint a representative in the European Union and/or United Kingdom for data protection purposes and will publish that representative's contact details here.

FTC Sports Media LLC

support@fromthecrease.com