Effective Date: December 1, 2024
Last Updated: December 1, 2024

Surf Soccer, LLC and its affiliates or related entities (“Surf Soccer,” the “Company,” “we,” “us,” and “our”) are committed to maintaining privacy protections for users of its website, application, and other services (“you”) by adhering to this policy. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using and accessing our website https://surfsoccer.com and its associated web pages (the “Site”), services, register an account with us, sign up to receive our blog or newsletter, or otherwise provide us with your or your child’s Personal Data (together with the Site, our “Services”).

BY ACCESSING OUR SITE OR USING OUR SERVICES, YOU ACCEPT OUR PRIVACY POLICY AND CONSENT TO OUR COLLECTION, STORAGE, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND YOUR CHILD’S PERSONAL DATA AS DESCRIBED HEREIN.

If our information practices change at any time in the future, we will post the policy changes to the Site. Please check the Site and this Privacy Policy periodically if you are concerned about how your information is used.

  1. WHO WE ARE

Surf Soccer, LLC is responsible for the Personal Data you submit and serves as the controller of your data. We are a competitive youth soccer club in San Diego, California consisting of teams of youth athletes. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the information set out in the contacts details section below.

  1. INFORMATION WE COLLECT

a. Personal Data you disclose to us

We collect, use, store, and transfer Personal Data, meaning any information about an individual that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked directly or indirectly with a particular consumer or household, you directly provide to us. The Personal Data we collect may depend upon the context of your interactions with us, our Site, or our Services, and which may include the following for either you or your child:

    • Identifiers and identifying data, including your name, email, phone number, billing address, and username, which you may submit to us through the Site, our Services, or otherwise by contacting us. We also collect identifying information you submit about your child, including your child’s name, birthday, gender, player photo, and birth certificate or passport for age verification.
    • Financial and Payment Data and personal information listed in the California Customer Records statute, including bank account information, credit card number or other financial information to process your payment. Financial and Payment Data is collected and stored by our third-party payment processor.
    • Health and Medical Information, including medical conditions, allergies, and health insurance information.
    • Commercial information, including member organization or club name, tournaments played in, and eligibility factors, including your child’s age and records of prior tournaments and clubs your child may have participated in previously.
    • Technical Data related to internet and network activity, including browsing or search history and information about an individual’s interaction with our Website, our Services or other digital products.
    • Marketing and Communications Data, including your contact preferences and your preferences in receiving marketing from us or third parties.
    • Sensitive Data, including financial data and health and medical information as described above, and account login information.

Data of Managers and Coaches

If you are a manger or coach, we may collect, use, store, and transfer your Personal Data, including identifiers, technical data, marketing and communications data, and account login information.

Children’s Data

We will process your child’s data as described in this Policy. We will collect, use, store, and transfer your child’s Personal Data, including identifiers, health and medical information, commercial information, and sensitive data.

b. Information automatically collected via technology

In an effort to improve the quality of the Site and our Services, we track information provided to us by your browser or by our software application when you view or use the Site or our Services, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Site, the time and date of access, location data (whether precise or general), current location based on IP address, settings and information about your activity on the Site (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions and features you use), device event information (such as system activity, error reports, and hardware settings), and other information that does not personally identify you.

We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. You can find more information about the Company’s use of cookies and how you can control cookies at our Cookie Policy.

c. Information collected from other sources

We may obtain information about you from other sources to enhance our ability to provide our Services. This information may come from other clubs, organizations, or governing sports bodies. We may also obtain information from public databases, joint marketing partners, affiliate programs, data providers and other third parties.

  1. SUBMISSION OF PERSONAL DATA THROUGH OUR ONLINE SERVICES

The Site is not directed to or intended for use by anyone under the age of 18. The Site and any online services we offer are designed for parents or guardians only to submit Personal Data of minors for purposes of signing up for our Services. If you are under the age of 18, please have your parent or guardian sign up for the Service on your behalf. In the event that we learn that we have gathered Personal Data from anyone under the age of 18 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at privacy@surfsoccer.com.

  1. HOW WE USE YOUR INFORMATION

a. We rely on one or more of the following legal bases to process the Personal Data you submit to us:

    • Performance of a contract with you: We may use your or your child’s Personal Data where we need to perform the contract we are about to enter into or have entered into with you. For example, to facilitate account creation, allow registration for tryouts, allow participation on youth teams, allow participation in competitions against other teams and clubs, and otherwise provide the Services you request from us.
    • Legitimate interests: We may use your or your child’s Personal Data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give your child the best and most competitive player experience possible. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Data for our legitimate interests. We will also use your Personal Data to send you marketing and promotional communications in accordance with your marketing preferences. We do not actively communicate with minors and will only communicate with the parent or guardian as indicated.
    • Legal obligation: We may use Personal Data where it is necessary for compliance with a legal obligation that we are subject to. We may also use your Personal Data to send you information about changes to our terms, conditions, and policies for participation.
    • Consent: We rely on consent only where we have obtained your active agreement to use your or your child’s Personal Data for a specified purpose, for example when you sign your child up to participate on a team or in a tournament.

b. We may also use information we collect or receive:

    • To deliver advertising to you. We may use your information to develop and display content and advertising tailored to your interests and/or location and to measure its effectiveness.
    • To protect our Sites or Services. We may use information you submit as part of our efforts to keep our Sites or Services safe, secure, and competitive (for example, for fraud monitoring and prevention and to ensure age-appropriate participation).
    • To enforce our terms, conditions and policies and/or for legal reasons.
    • To respond to legal requests and prevent harm for legal reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
    • For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Services, products, and your or your child’s experience.
  1. HOW WE SHARE YOUR INFORMATION

a. We may disclose any of the Personal Data we collect about you in the following ways:

    • With vendors, consultants, or other third-party service providers. We may share your or your child’s Personal Data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. For example, we use a third party that hosts an App that facilitates team management, participation, and communications with clubs, leagues, coaches and tournaments. We may also use vendors for payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts.
    • With our partners. We may share your or your child’s data with other team managers, coaches, leagues, referee organizations, U.S. Soccer, or other partners that support the leagues and tournament play.
    • With our affiliates or related entities. We may share your Personal Data with our affiliates or related entities, which are controlled or under common control with the Company. Any such affiliate or related entity will also adhere to the terms of this Privacy Policy.
    • To comply with laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
    • To protect vital interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
    • With your consent. We may disclose your or your child’s Personal Data for any purpose with your informed consent.
    • Through a business transaction. In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your or your child’s Personal Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy.

b. Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your or your child’s Personal Data with third parties without your consent.

c. We also do not “sell” or “share” Personal Data as those terms are defined under applicable U.S. privacy laws for cross-context behavioral (targeted) advertising.

  1. HOW WE PROTECT INFORMATION

We implement security measures designed to protect your information from unauthorized access and from potential security breaches by implementing certain technological security measures. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed. By accessing our Site and using our Services, you acknowledge that you understand and agree to assume these risks on behalf of you and your child.

  1. YOUR RIGHTS REGARDING PERSONAL DATA

a. Depending upon where you live, you may have certain rights under data privacy or protection laws related to your or your child’s Personal Data. You may have the right to:

    • Request access to your or your child’s Personal Data (commonly known as a “subject access request” or the “right to know”). This enables you to receive a copy of the Personal Data we hold about you or your child and to check that we are lawfully processing it.
    • Request correction of the Personal Data that we hold about you or your child. This enables you to have any incomplete or inaccurate data we hold about you or your child corrected, though we may need to verify the accuracy of the new data you provide to us.
    • Request deletion of your Personal Data in certain circumstances. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it or no legal basis for us continuing to process it, subject to certain exceptions.
    • You also have the right to opt out of direct marketing. When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional email. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out, we may continue to send you administrative emails including, for example, notices about your account or updates with respect to our policies or term you may be subject to.

b. If you wish to exercise any of the rights set out above, please contact us at privacy@surfsoccer.com or by U.S. mail at 2683 Via De La Valle, Suite G425, Del Mar, CA 92014. You may also log into your account at any time to review or change information in your account.

c. You may have the right to appeal a refusal to take action on your request. To make such a request, please follow the instructions above for submitting an access, deletion, or correction request.

d. You may also have the right to request that we provide a list of third parties to which we have disclosed personal data. To make such a request, please follow the instructions above for submitting an access, deletion, or correction request.

d. We may need to verify your identity before processing your request. Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. To designate an authorized agent to make a request on your behalf, please provide us with a power of attorney or other legally binding written document signed by you and identifying your agent. We may also verify the identity of your designated agent.

f. We will not discriminate against you for exercising any of your rights.

g. Certain data elements we collect and use to provide our Services may be deemed sensitive personal information under certain privacy laws, including minor’s data, health and medical information, and your username and password to access your account. We do not use or disclose such sensitive personal information to “infer” characteristics as defined under the California Consumer Privacy Act (CCPA), or for any purpose other than that which is necessary to provide the Services as specified in the CCPA.

  1. Opting Out of the “Sale” or “Sharing” of Personal Data for Targeted Advertising

We do not currently use cookies and similar tracking technologies to conduct cross-context behavioral or targeted advertising. Thus, we do not “sell” or “share” your Personal Data (as these terms are defined under the CCPA or other applicable US state privacy laws)

  1. CALIFORNIA’S SHINE THE LIGHT LAW

In addition to the rights described above, California’s “Shine the Light” law (Civil Code Section §1798.83) permits California residents that have an established business relationship with us to request certain information regarding our disclosure of certain types of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.

To make such a request, please send an email to privacy@surfsoccer.com.

  1. LINKS TO OTHER WEBSITES

As part of the Site, we may provide links to other websites, online services, or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain, nor does the inclusion of a link imply any endorsement by us. This Privacy Policy applies solely to information collected by us through the Site. This Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or to any data collected by such third parties. We encourage our users to read the privacy statements of the third party websites before proceeding to use them.

  1. INTERNATIONAL TRANSFERS

The Company’s servers are located in the United States and we provide our Services in the United States. If you access our Site from outside of the United States, please be aware that your personal data may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where we or our service providers maintain offices and where privacy laws may not be as protective as those in your jurisdiction. By using our Site or signing up for our Services, you consent to such transfer to, storage in and processing within the United States.

  1. DATA RETENTION

The Company will generally retain information about you for so long as we have a legal or business purpose for it or a legal requirement to maintain it. The criteria used to determine our retention periods include:

    • The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you maintain an account with us or keep using our Services) and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise;
    • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); or
    • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
  1. CHANGES TO OUR PRIVACY POLICY

The Company reserves the right to change this Privacy Policy at any time. Any changes will be reflected as of the date written above. We encourage our users to review this Privacy Policy frequently to be informed of the latest processes with respect to your information.

  1. CONTACT US

If you have any questions regarding this Privacy Policy, please reach out to us below. Additionally, you may contact us if you would like to request access to your Personal Data, change or update your Personal Data, or delete it in some cases, based upon the applicable laws and regulations of your jurisdiction.

Surf Soccer, LLC
2683 Via De La Valle Suite G425
Del Mar, CA 92014
privacy@surfsoccer.com