Privacy Policy

The Service is operated by [FULL NAME], a sole trader registered in Portugal under tax number (NIF) [NIF], with a principal place of business at [ADDRESS]. We are the controller of the personal data processed through the Service. You can reach us at hello@sowlscouting.com for any questions about this policy.

Account data. When you sign up, our authentication provider (Supabase) collects the email address and password you use to create your account. We receive a stable user identifier from Supabase and store your email and any name you choose to provide so we can identify your account inside the Service.

Billing data. Subscriptions are processed by our payment partner, Freemius. When you start a paid plan, Freemius collects the billing details required to take payment (name, billing address and payment method) directly from you — we do not receive or store your card or banking details. We store a Freemius user identifier, a license identifier, and your plan and status so we can grant the corresponding access in the Service.

Scout work product. As you use the Service, you create records about football clubs, leagues, matches, players, agents, scouting reports, shortlists and shadow teams. These records can include personal data about players (such as name, date of birth, nationality, contract and salary details) and agents (such as name, email and phone). Each scout’s records are stored separately and are only visible to that scout. See “Personal data you record about others” below for the specific responsibilities that come with this.

Technical data. Our servers automatically receive certain technical information when you use the Service, including your IP address, user-agent string and basic request logs. We use this for security, debugging and to keep the Service running reliably. We do not currently use third-party analytics or tracking on the Service.

Under the GDPR, we rely on the following legal bases to process your personal data:

• Contract (Art. 6(1)(b)) — to provide the Service, manage your account and process your subscription.
• Legitimate interests (Art. 6(1)(f)) — to keep the Service secure, prevent fraud and abuse, debug issues and improve the product. Where we rely on legitimate interests we have weighed the relevant factors and concluded that your rights and freedoms are not overridden.
• Legal obligation (Art. 6(1)(c)) — to comply with tax, accounting and other duties that apply to us as a Portuguese business.
• Consent (Art. 6(1)(a)) — where we ask you to consent to a specific use of your data, you can withdraw that consent at any time without affecting earlier processing.

We use the personal data described above to:

• Provide, operate and support the Service, including the features you actively use (creating reports, managing players, organising shortlists);
• Authenticate you and protect your account from unauthorised access;
• Process your subscription, send billing notifications and provide receipts and invoices;
• Respond to your support requests and other communications;
• Detect, investigate and prevent abuse, fraud, or breaches of our terms;
• Comply with our legal obligations.

We do not sell your personal data, and we do not use it to train machine-learning models.

We rely on a small number of trusted third parties to deliver the Service. Each acts as a processor on our instructions and is bound by appropriate data protection terms.

• Supabase, Inc. (United States) — authentication and database hosting. Stores your email, password hash and the records you create in the Service.
• Freemius, Inc. (United States) — subscription billing. Collects and stores your billing details and provides us with subscription status.
• [HOSTING PROVIDER] ([REGION]) — application hosting. Processes requests on our behalf.

We will update this list when we add or change sub-processors. If you would like to be notified, email hello@sowlscouting.com.

Some of our sub-processors are located outside the European Economic Area, in particular in the United States. Where this is the case we rely on the European Commission’s Standard Contractual Clauses (SCCs) and any additional safeguards required to ensure that your data continues to be protected to an equivalent standard.

We keep your personal data for as long as you maintain an active Sowl account. When you close your account we delete your scout work product within 30 days, except where we are required by law to retain certain information for longer — billing and tax records, for example, are kept for ten years as required by Portuguese law.

You can ask us to delete your data sooner; see “Your rights” below.

You have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erase your data (“right to be forgotten”), subject to legal exceptions;
• Restrict processing in certain circumstances;
• Port your data to another service in a structured, commonly-used format;
• Object to processing carried out on the basis of our legitimate interests;
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, email hello@sowlscouting.com. We will respond within one month. If you believe we have not handled your data properly, you can lodge a complaint with the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD), at cnpd.pt.

Sowl is a tool for scouts. When you use it, you typically record personal data about people who are not Sowl users themselves — most often footballers and football agents.

For that data, you are the controller and Sowl is the processor acting on your instructions. In practice that means:

• You must have a lawful basis under the GDPR for recording each person’s data — for professional scouting this is typically your legitimate interest in evaluating players and agents.
• You must respect data minimisation — only record what you genuinely need for your scouting work.
• You must be prepared to respond to requests from those individuals if they ask what you hold about them.
• If a player or agent contacts Sowl directly about data you hold, we will refer them to you.

We provide tooling to delete records on request, and we recommend you periodically review and prune player and agent records you no longer need.

We use essential cookies only — specifically those required to keep you signed in (Supabase session cookies) and to remember your interface preferences (such as your theme choice). Because these cookies are strictly necessary to operate the Service you have requested, we do not display a cookie banner. We do not currently use analytics, advertising or tracking cookies.

We protect your data with reasonable technical and organisational measures, including encrypted transport (HTTPS), encrypted database storage, access controls on our infrastructure and short-lived authentication tokens. No system is perfectly secure; if we ever become aware of a personal data breach that is likely to result in a risk to your rights, we will notify both you and the CNPD as required by law.

Sowl is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.

We may update this Privacy Policy from time to time. When we make material changes we will notify you by email and update the “Last updated” date at the top of this page. Continued use of the Service after the changes take effect indicates your acceptance of the updated policy.

For any questions about this policy or about your personal data, email hello@sowlscouting.com.