This notice has been prepared by Sporsoft Teknoloji Yazılım ve Ticaret Limited Şirketi (“Sporsoft”) in its capacity as data controller, pursuant to Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform. It covers all natural persons who use the www.sporsoft.com website and the Sporsoft mobile application.
1. Data Controller
| Legal name | Sporsoft Teknoloji Yazılım ve Ticaret Limited Şirketi |
| Address | Cuma Mah. Semih Zade Sk. No: 4 İç Kapı No: 2, İnegöl / Bursa, Türkiye |
| MERSİS No. | 0781116124100001 |
| Trade Registry No. | 15455 (İnegöl Trade Registry Office) |
| Tax Office / No. | İnegöl Tax Office / 7811161241 |
| Registered e-mail (KEP) | sporsoftteknoloji@hs01.kep.tr |
| destek@sporsoft.com | |
| Telephone | 0224 334 07 64 |
| Website | www.sporsoft.com |
2. Data Processed by Service Tier
Sporsoft offers a two-tier service, and data processing differs by tier.
| Tier | Data processed | Shared with clubs |
| Free membership | Identity (first name, surname, date of birth, Turkish ID number, for verification only), contact details (e-mail, telephone), in-app interactive (cognitive/character) test results, self-declared physical measurements, field test records and test videos not yet submitted for verification | None. For a free member the profile is closed to clubs; no data is transferred to the club panel. |
| Verified Profile | In addition to the above: verified field test results, verified test videos, overall score (TBS), position fit and ranking, Showcase participation data, in-app purchase transaction records (store transaction ID and purchase date; payment instrument details are not processed) | Yes. Once verification is complete, the verified test data, profile and videos are made available to member clubs through the Scouting Panel. |
Accounts belonging to athletes under 18 may only be opened and managed by a parent; in that case the above data of both the parent and the athlete is processed.
3. Purposes of Processing
- Creating the membership account and verifying identity (Turkish ID number, e-mail, SMS),
- Providing the in-app tests and the field test flow, uploading test videos and building the profile on the free tier,
- Verifying test videos, scoring and ranking the results under the Verified Profile,
- Under the Verified Profile, making verified data available to member clubs through the club panel and running Showcase events,
- Managing in-app purchase transaction records and meeting invoicing and accounting obligations,
- Calibrating the norm tables and improving the service (using anonymised data wherever possible),
- Meeting legal obligations,
- Where you give explicit consent, commercial electronic messages and measurement through advertising/marketing cookies.
4. Legal Grounds
| Legal ground | Scope |
| Conclusion/performance of a contract (Art. 5/2-c) | Membership, tests, video upload, verification, scoring; under the Verified Profile, presentation in the club panel, Showcase, purchases and management of transaction records |
| Legal obligation (Art. 5/2-ç) | Invoice/accounting records, traffic records under Law No. 5651, requests from competent authorities |
| Legitimate interest (Art. 5/2-f) | Platform security, prevention of manipulation, strictly necessary cookies |
| Explicit consent (Art. 5/1) | Commercial electronic messages, advertising/marketing cookies, use of images for promotional purposes |
5. Transfers
- Member clubs (Verified Profile only): Verified test results, profile and performance data and the related videos are made available to member clubs through the club panel. Clubs are obliged to use this data solely for talent assessment. Clubs' use of the data in accordance with the processing conditions and the confidentiality of the data are further secured through the agreements concluded with the clubs. For free members no personal data is transferred to clubs.
- Service providers: Hosting (Google Cloud, Europe region), app store purchase infrastructure (Apple, Google), SMS/e-mail providers.
- Competent public authorities: Within the scope of legal obligations, upon request.
6. International Transfers
Data is hosted on Google Cloud servers in the Europe region. Since purchases are made solely through the App Store and Google Play in-app purchase infrastructure, purchase transaction data is transmitted to Apple or Google as the operator of the relevant store. Your payment instrument details (card number, etc.) are processed directly by the store operator and are never transferred to Sporsoft. These transfers rely on the standard contractual safeguard announced by the Turkish Data Protection Board under Article 9 of the KVKK.
7. Method of Collection
Data is collected wholly or partly by automated means, through registration, profile and test forms, the video upload interface, the purchase confirmation screen, app store purchase flows, cookies and communication channels.
8. Retention Periods
| Data / Record | Period |
| Membership and contract records | 10 years from the end of membership |
| Invoice and accounting records | 10 years (Turkish Commercial Code / Tax Procedure Law) |
| Test videos not submitted for verification | 7 days from upload; deleted automatically at the end of that period |
| Verified test videos | 12 months from the date of verification; in the event of an objection, until the objection is resolved. The video is deleted at the end of the period; the verified numerical results and profile visibility remain |
| Records in breach of the contract (videos containing images of third parties) | Deleted upon detection; not retained |
| Traffic and log records | 2 years (Law No. 5651) |
| Consent record for commercial electronic messages | 3 years from the end of the consent |
| Cookie data | Up to 13 months, depending on the cookie |
At the end of the period the data is deleted, destroyed or anonymised.
9. Your Rights (KVKK Art. 11)
You have the right to learn whether your data is processed, to request information, to learn whether it is used for its intended purpose, to know the third parties to whom it has been transferred, to request its correction or erasure, and to request that these operations be notified to third parties. You may send your requests to the postal address above, to the registered e-mail address sporsoftteknoloji@hs01.kep.tr, or to destek@sporsoft.com from your registered e-mail address; requests are concluded free of charge within 30 days at the latest. Your right to complain to the Board is reserved.
10. Changes
Sporsoft may update this notice; the current text is published at www.sporsoft.com and material changes are notified to members via their registered e-mail address.