Privacy Policy

This privacy notice explains how we, Sports-Snaps.com and Icarus Now LLC (the company behind Sports-Snaps), process personal data in our business as per the General Data Protection Regulation (GDPR) and other relevant data protection and privacy laws applicable to our business.

What changed in this version: we now name the service providers we rely on (Brevo for email, PostHog and Google Analytics for website analytics, Cloudflare Turnstile for form protection, and Google Firebase for hosting), we describe how analytics works for visitors versus signed-in users, and we cover newsletter and early access signups. We also added an effective date and a link to the previous version at the top of this page.

Sports-Snaps is a privacy-first sports software company. We make money from licensing our products for use on other websites and in-house advertising plans. So there's no need or reason to sell, rent or give away any of your personal data.

We are not owned by any conglomerate parent companies or report to any board of directors. We run an ethical business that hopes to provide value to fans to further enjoy the games we love.

We hope to provide you with clear and transparent information on how we process your personal data (as a controller) and your data protection rights. If you feel that any information is unclear or missing, please do not hesitate to contact us.

We start this policy by describing our processing as the controller of your personal data. We also use a small number of service providers who process personal data on our behalf, as data processors, described in section 6.

• Access and rectification: you may request a copy of the information we process about you and ask us to rectify any incorrect data.
• Erasure or restriction: in some circumstances, you may ask us to delete or restrict our processing of your data, but we cannot delete any data we are legally required to process.
• Object to processing: in some circumstances, you may ask us to stop processing your data.
• Data portability: in some circumstances, you may ask us to transfer your data to you or another organization.
• Withdraw consent: where we rely on your consent (for example, marketing emails), you can withdraw it at any time. Withdrawing consent does not affect processing that happened before you withdrew it.

If you're unhappy about how we process your data, you have a right to complain to a national data authority. We hope, however, that you will contact us first so that we can try to resolve the matter for you in a satisfactory way.

Please get in touch with us if you have any questions about how we handle your data or want to exercise one of your rights. You are entitled to a reply within 30 days.

We typically process personal data on existing customers, website visitors and vendors and collaboration partners.

We may process personal data when you:

• Contact/communicate with us online (email, video calls, social media, etc.) or on the phone
• Sign up for our newsletter, apply for early access, or register for an account
• Are invited to Sports-Snaps.com by a registered user (we receive your email address from the person who invited you)
• Use our services/software (Sports-Snaps.com)
• Deliver products/services to or enter into a collaboration with us

It is voluntary to provide us with personal data, but we cannot provide you with our services if you choose not to.

We do not rent, buy or sell personal data from or to others, use automated decisions or profiling in the processing of your personal data, or process any special category data as per the GDPR Article 9.

We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on are:

• a) Your consent
• b) We have a contractual obligation (contract)
• c) We have a legal obligation
• f) We have a legitimate interest

As a rule, we do not process personal data for longer than necessary to fulfill the purpose for processing.

We will only retain data for as long as we are required to as per applicable legal obligations such as accounting, tax, labour laws or any other relevant rules and regulations.

This section describes when and how we process your data, for what purposes and our legal grounds to do so (lawful bases). We also specify the retention periods for the processing.

We process personal data when:

5.1. You communicate with us

Regardless of your relationship with us, as a potential or existing customer, vendor or other, we process your personal data whenever you communicate with us. This could be when you contact us through email or social media. Depending on where and how you contact us, this may include your name, contact details, IP address and other information you choose to send to us. We use a customer support system to manage personal data on potential and existing customers.

The purpose is to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. The lawful basis is f), where our legitimate interest is to respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.

5.2. You sign up for the newsletter, apply for early access, or register for a Sports-Snaps.com account

When you sign up for our newsletter, you share your email address. When you apply for early access, you share your name and email address. When you create a free account to access game recaps, you share your email address and name. Registration is by invitation or early access only, so we check your email address against our list of invitations and early access grants, and we keep a record of who invited you.

Other demographic information you choose to share with us is optional when you register. Demographic information sharing is optional, and it is used only in an aggregate (not identifiable) form to better understand the general demographic profile of our users.

We also record which version of our Terms and Conditions and this Privacy Policy you accepted, and when, so that we can show you exactly what you agreed to.

The purpose is to create and manage your account or request and to send you the emails you asked for. The lawful basis is b) contract for accounts, and a) consent for the newsletter and early access list. We keep account data for as long as you have an account with us. If you ask us to delete your account, we delete your personal data unless we are legally required to keep it.

5.3. You receive emails from us

We send two kinds of emails. Account emails are the ones we need to send to run the service: sign-in links, invitation notices, early access confirmations, and notices about changes to our Terms or this Privacy Policy. Marketing emails are optional. If you opt in, we will occasionally send you emails containing a promotional element or news about the site.

We use Brevo to send both kinds of email and to manage our contact lists. Brevo receives your name, email address, the list(s) you belong to (newsletter, early access, registered, invited) and, if applicable, the name of the person who invited you. Brevo also reports back to us whether an email was delivered, bounced, or unsubscribed from, and we store your current marketing status in our own database.

The purpose is to run the service and, for marketing emails, to provide you with news and offers related to your account. The lawful basis for account emails is b) contract. The lawful basis for marketing emails is a) consent.

You can opt-out of marketing emails at any time by clicking the unsubscribe link in any such email. When you do, your account will be flagged as "unsubscribed from marketing" in our internal database and in Brevo, and you won't receive any further marketing emails from us. You will still receive account emails for as long as you have an account. We are still required to process data for accountancy, tax and other business purposes if you are our customer.

5.4. You complete one of our surveys

We sometimes send surveys to our customers to improve our product. Responding to our surveys is completely voluntary. We process personal data such as your name, contact details and other information you choose to share with us. We do not process any personal data if a survey is anonymous.

The purpose is to gather your feedback to continuously improve our products and services and provide you with better customer service in the future. The lawful basis is a) consent. We review this data at our regular GDPR audits and delete personal data as appropriate; however, no later than two years after responding to the survey.

5.5. You supply services to or collaborate with us

When you enter into an agreement with us either as a vendor, partner or data processor, we process personal data such as your name, contact details and correspondence. The purpose is to enter into this agreement and communicate with you before, during and after our formal business relationship.

The lawful bases are b) contract, c) legal obligation related to accounting, tax and other business laws we are required to abide by, and f) where our legitimate interests are to be able to communicate with you before, during and after our formal business relationship (described under the paragraph "You communicate with us" above). We store personal data for as long as we have a formal business relationship and then for up to 6 years after, in accordance with our legal obligations for accounting, tax and other business purposes.

5.6. You use our website

Visitors who are not signed in. If you browse our website without signing in, we use PostHog in cookieless mode. PostHog does not store cookies or similar technology in your browser for this traffic, and we do not identify you as an individual. PostHog may count visits using a privacy-preserving hash calculated on PostHog's servers from your IP address and browser details, and that hash is not kept beyond the day it was created. We do not load Google Analytics for visitors who are not signed in. This approach is intended to comply with the ePrivacy Directive (Directive 2009/136/EC) for unauthenticated visitors without requiring a cookie banner.

Signed-in users. Website analytics consent is a condition of having an account, and you give it when you register or apply for early access. When you are signed in and have given that consent, we use:

• PostHog (full mode): cookies and local storage, user identification (your email address, name and subscription tier), page views, clicks and scroll depth, error tracking, and session replay. Session replay records how you move through our pages; text you type into password fields is never captured.
• Google Analytics: cookies and aggregate statistics on how registered users interact with our website.

Analytics traffic to PostHog is routed through our own domain before it reaches PostHog's servers in the United States. We use the information from these analytics services to understand which features are used and to fix bugs. The lawful basis is a) consent. We process the data for as long as you have an account with us and then for up to 6 years after, in accordance with our legal obligations for accounting, tax and other business purposes.

Forms. Our newsletter, early access and registration forms are protected by Cloudflare Turnstile, which checks that a submission comes from a person rather than a bot. Turnstile processes your IP address and technical information about your browser to make that decision; it does not track you across other websites. The lawful basis is f), where our legitimate interest is to keep spam and abuse out of our systems.

Hosting. Sports-Snaps.com is hosted on Google Firebase. Like any web host, Firebase processes your IP address and request details in server logs in order to serve the pages you ask for and to keep the site secure. The lawful basis is f), where our legitimate interest is to operate and secure the website.

To run our business efficiently and securely, we sometimes will have to share your personal data with other (trusted) parties such as:

• Data processors: providers of various services that process your personal data on our behalf
• Our accountant
• Professional advisors from other industries, such as law and finance
• IT support, when necessary
• Public authorities: when we are obliged to report to them

We require that all such recipients secure data in accordance with good information security and as per the requirements of this Privacy notice. We review and quality assure all vendors and data processors and enter into a data processing agreement/addendum whenever necessary.

6.1 We use the following data processors:

• Google Firebase (Google LLC): website hosting, our user database, and sign-in links
• Brevo (Sendinblue SAS): account and marketing emails, contact lists, and unsubscribe tracking
• PostHog (PostHog Inc.): website analytics, error tracking, and session replay
• Google Analytics (Google LLC): website analytics for signed-in users
• Cloudflare Turnstile (Cloudflare, Inc.): bot protection on our forms
• Providers of email, calendar and digital meetings, accounting/bookkeeping, and our support ticket system

We do not share your personal data with advertisers, data brokers, or any other third party for their own purposes.

6.2 Transfer of personal data outside the EU/EEA

In some cases, your personal data will be transferred to a "third country", i.e. outside the EU/EEA. Icarus Now LLC is based in the United States, and our hosting (Google Firebase), analytics (PostHog, Google Analytics) and form protection (Cloudflare) providers process data in the United States. Brevo is headquartered in France and processes data in the EU; its US affiliate may provide support. We only use data processors we trust that are well known, reputable, and have a data processing agreement/addendum, and where required we rely on the EU Standard Contractual Clauses or the provider's participation in the EU-U.S. Data Privacy Framework.

We take information security as seriously as privacy, and we will always do our utmost to safeguard your personal data in the best possible way. For example, we do not store passwords (you sign in with a one-time email link), we use data encryption, and several other measures to secure our data and prevent unauthorized persons from accessing, altering, deleting, or in any way affecting the data we store, including your personal data.

We only allow others to access or process your personal data in accordance with our instructions and only when strictly necessary (e.g. in the unlikely event that we require IT support).

You have a right to access your personal data and request a correction if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please get in touch with us using the contact information provided below.

We may update this Privacy Policy periodically to reflect changes in our services or policies. When we do, we will post the new version here with a new effective date at the top of this page, and we will email registered users at the address on their account. Continued use of the Platform after the effective date constitutes acceptance of the revised policy.

We keep every previous version so you can always see the policy that was in effect when you shared your data with us. Links to archived versions are listed at the top of this page.

Questions? Contact us