Privacy Policy

Version: January 31, 2021 | You may contact us for previous versions of the Privacy Policy.

 

In a nutshell:

Leading football clubs and academies trust Track160 with capturing and analyzing highly accurate game data, video, and events. It’s our privilege and duty to protect our customers’ data and yours.

Track160 uses cutting-edge processes of deep learning to automatically track the movements of all players on the football field, producing game data and insights. Our tracking technology and quality is FIFA EPTS Quality certified. We process some personal data according to our customers’ directions and do not use any such personal data for our own purposes. If you have any question regarding your personal data processed by Track160 on behalf of a football club or academy that is a customer of ours - please approach our customer, who can assist you with any question and right you might have with respect to such data.

 

Like most businesses, we also collect and process personal information of our website visitors, business contacts, and customers.

 

We respect your rights regarding your personal information.

Have a question and can't find an answer? Contact us, we're here to help: info@track160.com

Now in more detail:

1) Introduction and Definitions

 

We are Track160 Ltd. - simply referenced here as “Track160”. You can find our contact details below.

Track160 is helping football clubs and academies (“Customers”) analyze game data to improve team and player performance and coaching effectiveness. Track160 uses cutting-edge processes of deep learning to automatically track all players on the field, producing game data and insights, usually for the coaching staff. We do so by providing our Customers with optical hardware (“Cameras”) capturing video footage (“Video(s)”) of the Customers’ premises - football stadiums and playing fields (“Pitch”), dedicated computers (“Computers”; Cameras and Computers will be referenced together as “Hardware”) that are installed in the Pitches, software installed on the Computers to process and analyze the Videos recorded by the Cameras (“Computer Software”), cloud-based software to access the Track160 platform that interacts remotely with the Computers and Computer Software (“Platform”), customer support, and other services (“Services”).

Our Customers decide the purposes for which they use Track160, our Platform, and our Services, as well as the means for collecting data (inc. their Cameras and Computers). Our Customers control the data processed on their behalf on Track160 systems and they are responsible under our mutual agreements for handling any data rights and data requests of end-users of the Platform, football players, referees, and other people (“Person”) as Data Controllers.

To make things clear with an example: if you played in a football club that licensed the Platform to analyze the games in its football field, then you are a Person, the football club is our Customer and has full control over your personal data, and we process your personal data on our Customer’s behalf and according to its instructions. If you’re a Person and have any issue regarding your personal information, please contact the Customer (the football club) first!

In addition, we also operate several Websites - such as track160.com - and collect personal data of Visitors. Some Visitors and other people who communicate with us, become our business Contacts or Customers. We collect and process various personal information regarding our Visitors, Contacts, and Customers, and we are the Data Controllers for such personal data.

If you are a Visitor, Contact or Customer of ours and have any issue regarding your personal information that we control, please contact us (details below).

2) How Do We Collect Personal Data?

 

If you’re a Contact or Customer of ours, there might be several ways in which we receive your personal data:

  • When you share it with us directly, through your communication with us on the Websites’ contact forms, by email, phone, or facsimile, in conferences, meetings, or via any other communication channel, or by using the Platform.

  • When other Customers, Contacts, business partners, or third parties share your information with us, based on their interaction with you, their purposes, their legal bases, and their privacy policies. In such cases, we take responsibility for controlling only the personal data that we have received.

  • We might augment the personal data we have about you with information you provided us directly, information others have provided us about you, and data we’ve collected about you from your use of our Websites (see below).

If you’re a Customer’s Person, we may have some personal information about you. There are two ways in which we receive such data about you:

  • Our Customer provides us with your personal data, for example when creating their Platform accounts, setting their team and player profiles on the Platform, or capturing Videos using Cameras.

  • You provide us personal data directly through your use of the Platform or your interaction with Track160’s Platform, Services, or support channels.

If you’re a Visitor to our Websites, we might receive some usage data and personal data through your device, operating system, and browser, and various hosting, tracking, analytics and advertising technologies used on our Websites, such as cookies (see below), analytics, and CRM services. Our Websites do not currently respond to “Do Not Track” signals sent by your browser or device.

3) What Personal Data Do We Process?

 

If you’re a Contact or Customer of ours, we may collect and process these types/categories of personal data about you:

  • Identification and Account information, such as full name, identification number, gender, profile photo, username and password

  • Contact details, such as country/time zone, work and home addresses, phone numbers, and email address

  • Social networking information you’ve shared with us

  • Work-related information, such as company/organization, division, department, role, and title information

  • Payment information, such as bank account number, or other billing information

  • Any personal data contained in any photos, media, and other files sent to us

  • Any other personal data you provide us on any communication channel, such as email correspondence, customer support, and product feedback.

On the Customer’s Computers and the Platform, various types of personally identifiable information might be collected. Our Customers decide what data to collect, by what means, and what data to send Track160 in order to analyze their games and practices.

These are the types/categories of personal data about Persons that we may process on Customers’ behalf:

  • Identification and Account information, such as full name, identification number (e.g. jersey number, club registration number, league ID) gender, profile photo, username and password)

  • Contact details of the Person, his/her family members, and agents, such as country/time zone, work and home addresses, phone numbers, and email address

  • Work-related information, such as company, affiliation, division, department, role, and title information

  • Club-related information, such as team, affiliation, role (e.g. Goalkeeper, Center Forward, etc.), match/practice data

  • Videos from Cameras in the Pitches - used to identify and analyze: 

    • on identification according to Customer data, jersey number, location and other data

    • Exact location and movement information throughout the Video, such as Pitch location, coordinates of the Person on the Pitch

    • Interactions with other Persons on the Pitch and with the ball

    • Gender and approximate age can also be inferred from the videos

  • Inferred player analytics, such as speed, acceleration, distance ran/walked, performance scores, metabolic load, and other player and play characteristics.

  • Any other personal data our Customers share with Track160

Please be aware that the Cameras, Computer Software, and Platform automatically record and process Videos taken in the Pitch, when turned on by the Customer. They capture the Pitch’s surroundings, which might include Videos of unidentified people in the Pitch (“Other People”), such as spectators or lawn mowers. Track 160 makes no attempt to identify Other People. Any conduct within the Pitch, whether appropriate or not, legitimate or illegal (such as fouls, tackles, violent behaviors, etc.), might be captured and recorded by the Cameras, stored on the Computers, and become available to the Customer, its permitted end-users, and others at the Customer’s discretion (See “Who is Your Information Shared With?” below).

 

If you’re a Customer, do not place Cameras in private areas, publicly inaccessible locations, or no photo zones. Make people in the Pitches aware of the Cameras and the processing of their personal data. Please don't record, process, transfer, or publish photos or videos in which people are identifiable without their permission, unless you have another legally justifiable reason to do so. When you have control over data in the Trach160 Platform, along with this control comes responsibility. Consider your use of the data in your control carefully, and consult with your managers, lawyers, or privacy professionals when in doubt.

We also collect and process these types/categories of non-identifiable personal data about anyone using our Websites and Platform:

  • Usage, logs, analytics, and other device and technical data collected when you use our Websites or Platform, including device information and identification numbers, operating system information, IP address, browser and session information, browsing history and referrals, cookies information, web beacons, advertising identification numbers, language information, connectivity information, configuration information, metadata of files, and usage information (such as screen views, clicks, and usage time).

4) What About Personal Data of Children?

 

Track160 Services and Platform are not intended for children. We do not knowingly collect or process information about children.

Our Customers or their end-users (e.g. coaches) might use the Platform and Services to track football matches and practices of underage Persons, and they do so based on their own legal bases (e.g. explicit written consent from a parent or legal guardian) and on their own responsibility. Track160 is not liable for obtaining such consent on behalf of a Customer. If you’re a Customer, we recommend that you do not use Track160 technology with respect to matches and practices of children under 16 years old, and if you nevertheless choose to do so, that you attain in advance the explicit written consent of both players and their parents or legal guardians for such use.

Please contact us (contact details below) if you have any concern with respect to Children’s personal data on the Track160 Platform.

5)  What About Cookies? 

 

A cookie is a small data file that your browser saves on your computer or mobile device. We use cookies to collect information and provide our services. We may use cookies to enable certain features, understand how you interact with us, monitor your usage of our Websites, products and services, and personalize your experience and advertising displayed to you. You can set your browser to prevent the use of cookies. If you don’t accept cookies, our Websites and Platform might not function properly.

6) What Are The Purposes for Processing Personal Data? How Is Your Personal Data Used?

Track160 Platform

The purposes for the processing of personal data on the Platform are determined by our Customers. Each Customer might use the Platform for different purposes. Such purposes might include analyzing matches, team and player performance, composing teams, team and player coaching, preparation for matches, video production for broadcast or social sharing, and more.

If you’re a Person, we collect and use your personal data to provide our services to our Customers, according to their instructions and settings, so they can achieve their respective purposes. We do not sell personal information of our Customers’ Persons to third parties.

Our purpose in processing data on Track160 is to provide our Services to the Customers according to our agreements with them and applicable law.

We also use of the data collected on the Platform and through our Services to ensure our products and services are working as intended; to analyze, measure and understand how our services are used; to improve our products and services; to develop new features, products, and services; to protect our company, staff, and Customers; and to comply with any applicable law and assist law enforcement agencies under any applicable law.

We may use anonymous, statistical or aggregated information collected on the Platform, in a form that does not enable the identification of a specific person, by posting, disseminating, transmitting or otherwise communicating or making available such information to customers, vendors, partners and any other third party.

We also process usage and analytics information, as well as some statistical and aggregate data derived from personal data, for the improvement and further development of the Platform, Track160 technology or for research purposes.

Websites, Customers, Contacts and Visitors

If you’re a Customer, Contact, or Visitor on our Websites, we may process your personal data for our own business purposes, including:

  1. Delivering our products and services, improving them, and developing new features, products, and services

  2. Providing information about our company, products, and services

  3. Providing customer support, billing, and invoicing

  4. Contacting you via any communication channel, including email, phone, SMS, and other messaging platforms

  5. Analyzing and optimizing traffic and usage of our Websites and the Platform

  6. Protecting our company, staff, Customers, and systems

  7. Online advertising in all forms and channels, including targeting you and others who share similar characteristics as you (lookalikes) online on search engines, websites, apps, messaging platforms, social networking platforms, and offline

  8. Direct Marketing in all forms and channels, including email, SMS, messaging, postal service, and more; you can always opt-out from Direct Marketing by unsubscribing yourself through links on any communication or by contacting us and notifying us accordingly.

7) What Is The Legal Basis For The Processing of Data?

Track160 Platform

As Data Controllers, our Customers usually process personal data on Track160 Platform (and we process such data as a Data Processor on behalf of our Customers and according to their instructions) based on any or some of the following legal bases:

  1. Processing is necessary for the performance of a contract to which the data subject is party (for example, employment agreements between players and a football club) or in order to take steps at the request of the data subject prior to entering into a contract;

  2. Processing is necessary in order to protect the vital interests of the data subject (such as a Person), for example the right to personal safety when playing or training, and the right to defend themselves in legal or sport-related proceedings with relevant evidence;

  3. Processing is necessary for the performance of a task carried out in the public interest, such as providing match data and analytics for public matches;

  4. Processing is necessary for the purposes of the legitimate interests pursued by our Customer or by a third party, for example: conducting their business; providing their products and services; improving their coaching capacity; providing statistics about public mathes to TV broadcasters; using Videos for video assistant referee (VAR), etc.

  5. The data subject (Person), or an authorized party on his/her behalf (club, guardian, agent, etc.), has given consent (for example, upon signing up to the club) to the processing of his or her personal data for specific purposes communicated by the Customer in its respective Privacy Policy.

As Data Processors, we process personal data on the Platform based on the following legal bases:

  1. Processing is necessary for the performance of our contracts with our Customers or our partners;

  2. Processing is necessary for compliance with a legal obligation to which we are subject as data processors, for example data protection and privacy regulation;

  3. Processing is necessary for the purposes of the legitimate interests pursued by us, such as the conduct of our business and the purposes for which we process personal data as detailed in this Privacy Policy;

  4. The data subject has given us consent, through the Customer’s Computer Software, the Platform, or otherwise, to the processing of his or her personal data for the specific purposes communicated in this policy.

Websites, Customers, Contacts, and Visitors

As Data Controllers for our Customers, Contacts and Visitors’ personal data, we process personal data based on any or some of the following legal bases:

  1. The data subject has given us consent to the processing of his or her personal data for specific purposes communicated in this policy;

  2. Processing is necessary for the performance of a contract to which the data subject is party - for example, a service agreement with us or the Terms of Service of the Websites - or in order to take steps at the request of the data subject prior to entering into a contract;

  3. Processing is necessary in order to protect the vital interests of the data subject or of another natural person, for example protecting our Customers’ management and our staff; or for the establishment, exercise, or defense of legal claims;

  4. Processing is necessary for compliance with a legal obligation to which we are subject, for example the need to maintain billing records for transactions;

  5. Processing is necessary for the purposes of the legitimate interests pursued by us, or our Customers, for example the conduct of our business, the development and delivery of our products and services, and the promotion and sales of such products and services.
     

8) Who Is Your Information Shared With?

 

Our Computer Software, Platform, and Services enable our Customers and their end-users to share information, including personal data, based on your consent or other legal bases, as referenced above. Our Customers decide about the sharing of Videos and other data from the Platform, the identity of the recipients, and the distribution of the information. For example, the Customer may use the Platform to share Videos of matches or a Person’s player statistics captured by the Cameras on the social media channels of the football club.

This section deals with information we share about you with others.

Track160 Platform

For the delivery of our services, we share all data on the Platform with the Customer who is the Data Controller with respect to such data. Our Customers may select to share the information with others, as stated in their respective Privacy Policies.

Customers, Contacts, and Visitors

We process your details on our servers, computers, and systems; cloud hosting services; CRM and support systems; team collaboration services; billing systems; email and SMS communication services; and backup systems. We may share some of your details with our staff, subsidiaries, affiliates, contractors, consultants, resellers, and other third-party business partners for research and analysis, cooperation opportunities, joint promotions, sales, and events.

Everybody

We may share data with our staff, subsidiaries, affiliates, and contractors for the provision of our Services and our operations.

We use additional processors around the world for various processing activities needed for the performance of our Websites, the Platform, our Services, our operations, and our business, and share information with such processors on a need basis. Such processors include hosting and backup providers (such as Amazon and Dropbox), analytics providers (such as Google and Prometheus), website technology (such as Wix and Cloudflare), advertising technology (such as Google, Facebook, LinkedIn), communication services (such as Mandrill and Anydesk), team collaboration tools (such as Atlassian and Slack), CRM and support services (such as Zoho), telecommunication services, security technology, and more. We limit the information we share with each processor based on the business need in using such a processor, to protect your information while still effectively benefiting from the services of such processor.

We may also share non-personally identifiable information and aggregate information for any purpose. Such data is not personal data, and its sharing cannot be used to identify you.

We may need to share your information with law enforcement agencies, courts of law, and other governmental organizations, if ordered to do so by competent bodies and according to applicable law.

Mergers and Acquisitions

If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.

9) How Do We Safeguard Your Personal Data?

 

We take information security very seriously.

Most personal data is stored and processed by the Customers on their Computers and Computer Software installed in the Pitches. Customers have full control and responsibility over their premises and any Hardware and Computer Software in the Pitches, and can turn off their Cameras or delete any data from their Computers. Some information - including Videos and Platform data - is processed over the cloud. Remote access to Customer data on Computers or to the Platform on the cloud is limited to authorized end-users and personnel, secured by username and password, or authenticated APIs, and transmitted over secure connections (HTTPS/SSL).

We implement the state of the art security standards to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information. We encrypt all major data communication transmissions to avoid interception and securely backup the information on the Platform to avoid data loss. We also implement appropriate organizational measures to protect your information.

We apply our security standards also when working with business and technology partners. We only select and contract with processors and third parties who use appropriate security measures and provide sufficient guarantees, including technical and organizational measures, to ensure the appropriate protection of the data we entrust with them. Unfortunately, although we make every effort to keep your data safe, we cannot fully ensure or warrant the security of your personal information.

 

10) Do We Transfer Personal Data Internationally?

 

Most Customer data is saved locally on the Computers.

Some information - including Videos and Platform data - is stored over the cloud on Amazon Web Services in Frankfurt, Germany. Amazon takes extreme measures with respect to privacy and data security. Read more about Amazon’s measures here. Our R&D and customer support center are located in Israel.

At the same time, our business is international - we serve Customers around the world and make use of the Platform and Services worldwide, and we utilize additional processors and service providers in various countries. Therefore, we transfer, store or otherwise process your personal information in other countries. We take appropriate safeguards in the selection of our processing vendors around the world to require that your personal information is well protected. Despite our efforts, it may be the case that a country where your personal information is processed has different, or less protective, data protection and privacy regulation than the country you live in.

11) For How Long Do We Keep Personal Data?

We keep personal information we collect for different periods, depending on the type of information, for example: the period of our contract with our Customers (including a post-termination period as agreed with our Customers), legal requirements regarding certain types of data, and other factors. Generally speaking, we will retain your personal information for a period reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain your personal information for as long as necessary to resolve disputes, enforce our rights and agreements, and protect our staff and Customers.

If we no longer need your information for the purposes mentioned in this Privacy Policy, we will delete or anonymize it. On certain occasions we might not be able to fully delete or anonymize your personal information due to technical or operational reasons, for example deleting from backup storage and archives. In such cases, we shall take reasonable measures to secure any information still maintained by us according to our standard data security practices.

Please be aware that our Customers may also retain on their own systems and computers copies of personal data collected through Track 160, Cameras, and the Platform, even after we completed the provision of our Services, ended our contractual relationships, and deleted or anonymized any data related to Customers’ accounts on the Platform. Such data retention by Customers is subject to their Privacy Policies, purposes, legal bases, agreements with data subjects, and any applicable law. We take no responsibility over Customers’ use of personal data outside of the Platform.

12) What Are Your Rights With Respect to Your Personal Data?

If you’re a Person whose data is processed by a Customer, please approach such Customer to exercise any rights you may have, as they are the Data Controllers of your personal information. Otherwise, please contact us (details below).

According to the data protection and privacy regulation where you live, you may have certain rights with respect to your personal information.

Your rights may include, under certain terms and conditions set in the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), or other applicable law:

  • Right of Access to your personal data processed by us;

  • Right to Rectification of inaccurate or incomplete personal data;

  • Right to Erasure of your personal data (“Right to be Forgotten”);

  • Right to Restriction of Processing for a certain period or under certain conditions;

  • Right to Data Portability of your personal data to another data controller in a structured format;

  • Right to Object the processing of your personal data. Specifically, you have the right to object further processing of your personal data for direct marketing purposes;

  • Right to Opt-Out from the Sale of your personal data - to opt-out, please contact us;

  • Right Not To Be Subject to a Decision Based Solely on Automated Decision-Making. We do not make any decisions with legal effect based on automated decision-making;

  • Right Not To Be Discriminated Against for exercising privacy rights;

  • Right to File a Complaint with the applicable data protection authority in your country.

After deletion or anonymization of your personal data following its retention period, the rights to access, erasure, rectification, and data portability cannot be enforced.

Your personal information is processed based on several legal bases, sometimes including your consent. You can withdraw your consent at any time. Other legal bases, including statutory or contractual requirements that apply to you or our Customer might remain intact even following the withdrawal of your consent.

13) Do We Ever Change Our Privacy Policy?

 

Occasionally, we change this Privacy Policy to accommodate product and service development, industry standards, or new regulation. If we have your contact details, we will let you know personally if such changes are material, and seek consent for the updated Privacy Policy where required and as needed.

Please read the latest Privacy Policy available here from time to time. Note that we may require your consent to our up-to-date Terms of Service and Privacy Policy whenever you use our Websites or the Platform. If you do not agree to these terms and policy, please do not use our services.

14) Who Can You Contact Regarding Your Personal Data?

 

If you’re a Person, please contact our Customer first with any issue, as they are the Data Controllers of your personal information.

When you contact us to exercise your rights, we will verify your request and identity. Depending on your residence, you might be able to designate an authorized agent to exercise these rights on your behalf, but we will require proof that the agent is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

You can contact us with any question or concern you have at:

Track160 Ltd.
Habarzel 38, Tel Aviv, Israel
Email: info@track160.com

 

THE TEAM