ARCADEMY

Privacy Policy

Last updated: September 8, 2025.

Purpose of the Privacy Policy

This privacy policy (the “Privacy Policy”) explains how Arcademy S.A.S. ("Arcademy") respects the privacy of anyone who visits, registers, or contracts the service, and how it protects that privacy (the "User").

For the purposes of applicable data privacy legislation, the Arcademy affiliate responsible for collecting and/or processing personal data will be the affiliate with which the User enters into a contract, or the affiliate located in the country where the User resides, as the case may be. If you wish to confirm the responsible entity, you may contact us using the methods provided in Section 13 of this Policy.

This Privacy Policy applies to all processing of personal data carried out by Arcademy. It describes the types of information Arcademy collects from the User, or that the User may provide to Arcademy when using its mobile applications and/or browsing its website https://arcademyteam.com/ (the “Site”).

The main function of the Site is to offer Users software services for process optimization, designed to meet the specific needs of sports organizations, including talent management for clubs, monitoring results and statistics, all of which are detailed on the Site (the “Service”). If necessary, Arcademy may supplement this Policy with information and/or specific terms and conditions related to the Service.

Our Service may involve the processing of personal data of minors, as much of the sports and talent management activity includes children and adolescents. In such cases, Arcademy applies enhanced protection measures, recognizing the special sensitivity of this data and acting in accordance with applicable legislation on the protection of minors’ data (Personal Data Protection Law No. 25.326 of República Argentina).

This Privacy Policy also details Arcademy’s policies and procedures regarding the collection, use, and disclosure of information collected from the User when accessing or using the Services. Users will find information about their privacy rights and how the law protects them.

By using the Services, the User accepts the collection and use of information in accordance with this Privacy Policy.
Data Collection – How does Arcademy collect personal data?
Arcademy informs Users that, in compliance with applicable regulations on personal data protection, it collects User information:
1. Automatically when the User navigates the Site.
2. Directly when the User completes a form on the Site, exchanges emails, text messages, or other electronic messages with Arcademy; and/or
3. Interacts with advertisements and applications on the Site.
Personal Data Collected – What personal data does Arcademy collect?
Arcademy collects information when the User visits the Site. In addition to the contact details of responsible adults (parents or guardians), Arcademy may collect and process minors’ data related to their sports activities, such as:
1. Information that may personally identify the User: full name, email address, company where the User works or represents, sports club or institution the User belongs to, results, statistics, and/or sports performance.
2. Other information not directly identifying the User: date of birth and/or IP address of the device used to access the Services.
Arcademy declares that it will not collect sensitive data from minors (e.g., health information) without the express written authorization of their parents or legal guardians, either granted directly to Arcademy or obtained by the data controller, and only when strictly necessary for providing the Service.

As a general rule, when personal data is requested to use a service or access certain content, providing such data will not be mandatory, except where it is specifically indicated as required for the provision of the service. In such cases, the User may freely choose not to register and/or not to contract the services.

The User declares and guarantees that all data provided is true and correct, and undertakes to keep it updated.

Changes may be made through any of the means indicated in Section 13 of the Privacy Policy.

Any false or inaccurate statement, and any damages such information may cause, will be the User’s sole responsibility.
Purpose – For what purpose does Arcademy use personal data?
Personal data collected from the User will be used for the following purposes:
1. To respond to inquiries regarding the services offered and/or advertised through the Site, to establish and maintain communication with the User, and provide complete information about Arcademy’s services.
2. For commercial and/or institutional communications, promotions, and/or advertising of Arcademy, whether occasionally or periodically. In this regard, the User’s email address may be used to send information and updates about service requests, as well as news, updates, product or service information, etc. This processing is based on our legitimate interest in promoting our products and services.
3. To personalize the User experience, enhancing the ability to meet their needs.
4. To improve the Site and Arcademy’s service offerings, based on Arcademy’s legitimate interest in continuously improving its products and services.
5. To process transactions and comply with Arcademy’s legal obligations, such as tax obligations.
6. In the case of minors, data will be processed to manage and optimize sports activities of clubs and organizations using Arcademy’s Services, always in coordination with their legal representatives. Specific technical and organizational measures are adopted to ensure that the use of minors' data is strictly limited to these purposes
Personal data will not be processed for purposes incompatible with those for which it was collected or subsequently authorized by the User. No personal data is collected that is not necessary for the aforementioned purposes and that the User has expressly authorized.

Without prejudice to the foregoing, it is noted that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of compiling statistics, managing incidents, or conducting market research.

If personal data is processed for a purpose other than that initially specified when collecting such data, Arcademy will conduct a compatibility analysis in accordance with applicable regulations. Processing will only be authorized if the original purpose is compatible with the new purpose or permitted under an independent legal basis. In these cases, the User will be informed of any changes to the purpose or legal justification for processing their data.

Arcademy reminds Users that they can object to receiving commercial communications (unsubscribe) and stop receiving Arcademy’s emails by notifying Arcademy through the means indicated in Section 13, or by following the unsubscribe instructions at the end of each Arcademy email.
User Consent to Data Processing by Arcademy
By providing personal data to Arcademy, the User fully and unreservedly accepts the processing of such data by Arcademy in accordance with this Privacy Policy.

The User hereby grants his or her free, express, and informed consent for Arcademy to use the data collected for the purposes indicated in Section 4 hereof, as well as for its incorporation into an Arcademy database.

When it concerns minors, Arcademy verifies the express consent of parents or legal guardians, who must authorize registration and use of the Services on behalf of the minor. Arcademy may request supporting documentation and reserves the right to suspend or delete the account in case of inconsistencies.

Arcademy processes the data of the legitimate User in:
1. the User's consultation and/or contact with the services offered by Arcademy; and
2. the User's free, informed, and unequivocal consent, given after reviewing the Privacy Policy, which informs Arcademy about the processing of their data and/or the User's use of the Services.
Data processing not covered by any of the legal bases indicated above will be carried out if Arcademy deems it necessary to safeguard a legitimate interest and only if it does not conflict with the User's fundamental rights and freedom.

It is clarified that, in accordance with the provisions of the applicable regulations, the User's consent will not be necessary to obtain personal data when:
1. The requested data is obtained from sources with unrestricted public access;
2. The lists are limited to name, national identity document, tax or social security identification, occupation, date of birth, and address; and/or
3. They arise from a contractual, scientific, or professional relationship with the data subject and are necessary for its development or fulfillment.
Data Retention – How long does Arcademy store data?

Data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in Section 4 above.

Arcademy will retain essential information for a maximum period of 24 months to identify the origin of stored data and the start of the service provision.
Confidentiality and International Transfer – Does Arcademy disclose data to third parties?
Arcademy will keep collected personal data confidential and will not use it for purposes other than those established in Section 4 above. Arcademy requires the signing of confidentiality and personal data processing agreements by its employees and third parties that provide services that access the content of its databases (or includes such obligations within the service agreements it signs with such providers as indicated in the next paragraph).

Personal data will not be transferred, sold, exchanged, transmitted, or disclosed to third parties outside Arcademy without the User’s consent, except as legally required or for the purpose of providing the Services. This does not include certain employees and service providers who enable Arcademy to keep the Site and/or mobile application operational, fulfill the purposes set forth in Section 4 above, and/or answer User queries, who have agreed to maintain the confidentiality of the data provided and have committed to compliance with applicable personal data protection regulations at the time of their hiring. The contracts with service providers stipulate the purpose, scope, content, duration, nature, and purpose of data processing, the type of personal data, the categories of data subjects, and the obligations and responsibilities of Arcademy and the contracted third parties.

In particular:
1. Arcademy may share the personal information provided with Arcademy's parent companies, affiliates, subsidiaries, related companies, and/or intermediaries related to Arcademy.
2. Arcademy may share certain personal information provided by the User internally within Arcademy, with certain departments such as administration, marketing, or IT.
3. Arcademy transfers, processes, and stores its users' data to the AWS cloud, adopting the data protection recommendations provided by AWS, implementing server-side encryption (server side encryption) and HTTPS encryption in transit.
4. Arcademy operates its platform on infrastructure provided by Hetzner.
5. Arcademy uses the Google Play Store and Apple App Store as official channels for downloading its apps, WhatsApp and GitHub for internal communication and coordination, and Google Workspace for internal coordination and information processing.
Finally, the User should be aware that Arcademy may (and that Arcademy reserves the right to) disclose their information in the following cases:
1. If required by a judicial or administrative authority;
2. If necessary in order to exercise your rights under this Privacy Policy;
3. If necessary to comply with the law;
4. If such data could be useful for the protection of third party rights;
5. When it would be useful for the protection of the rights, property, or safety of Arcademy, its controlling, controlled, affiliated companies, directors, managers, employees, users, or the general public; and
6. When there are well-founded reasons relating to public safety, national defense or public health.
Security Measures – How does Arcademy ensure data security?
Arcademy implements technical and organizational measures to ensure the security, integrity, and confidentiality of data, in compliance with applicable regulations, to prevent alteration, loss, or unauthorized access or processing.

Arcademy maintains physical, electronic, and procedural safeguards to comply with federal standards for the protection of health information and operates its platform on infrastructure provided by Hetzner, complying with DIN ISO/IEC 27001 standards¹. All information provided to our servers is stored by AWS, respecting the shared responsibility model that complies with HIPAA standards², and the General Data Protection Regulation³. Arcademy also uses the Google Play Store and Apple Store as official channels for downloading its apps, in accordance with the privacy policies of each platform⁴. Arcademy uses WhatsApp and GitHub for internal communication and coordination, in compliance with their respective privacy policies and statements⁵. Similarly, Arcademy uses Google Workspace for internal coordination and information processing, a platform that also complies with HIPAA standards⁶.

Arcademy does not guarantee absolute privacy in the use of the Site, as the possibility that unauthorized third parties may gain knowledge of such privacy cannot be ruled out. The User acknowledges that existing technical means providing security are not impregnable and that even when all reasonable security precautions are taken, manipulation, destruction and/or loss of information is still possible. If a security incident is detected and poses a significant risk to the data subject, the relevant supervisory authority will be notified without delay, along with any corrective and mitigation measures implemented and/or to be implemented.
Arcademy is not responsible for the loss or deletion of user data. Furthermore, Arcademy does not accept any liability for any damage caused by computer viruses.

Finally, the User must also take measures to protect their information. Arcademy urges you to take every precaution to protect your personal information while online.
User Privacy Rights

Users are the owners of their personal data and have the right to access, rectify, delete, limit processing, object, request portability, and confidentiality. Requests may be submitted via email to [email protected] or by other means provided in applicable regulations. Once the request is received, it will be dealt with immediately in order to assist the User in the best possible way.

At any time, the User and the parents or guardians of minors whose data is being processed may exercise their rights of access, rectification, cancellation, objection, restriction of processing, portability, confidentiality, and deletion regarding their personal data.

To do so, you must accompany the communication with a photocopy of your ID, passport, or other valid document that identifies the rights holder, unless an electronic signature is used, in which case the presentation of identification documentation will be waived.

The deletion of certain data will not be permitted when it could harm the rights or legitimate interests of third parties, or when there is a legal obligation to retain the data.
Training - Do we train?
Arcademy trains its staff involved in personal data processing to ensure compliance with privacy and security commitments.
1. We define a minimal access and data handling approach. We limit internal access to necessary data, and all employees are trained in proper data handling to ensure they adhere to our strict commitment to data privacy and security.
2. We have an internal training program on best practices and the correct use of internal tools for all employees involved in data processing tasks.
Third-Party Links - Does the Site or mobile app contain links to other sites?

The Site and/or mobile application may contain links to third-party sites with privacy policies independent of Arcademy. The linked sites are not related to Arcademy, and their existence in no way implies any kind of suggestion, invitation, or recommendation to visit the destination sites or any kind of link or association between Arcademy and such sites. Arcademy is not responsible for, nor will it be liable for, the content, use, and activities of these linked websites, nor for any damages, whether actual or potential, material or moral, direct or indirect, suffered by users and arising from the information contained on such sites or from the relationship that users may establish with third parties whose services have been published on the Site and/or the mobile application. Without prejudice to the foregoing, any feedback regarding these linked websites will be helpful to Arcademy in improving its services and/or ensuring the integrity of the Site and/or mobile application. Arcademy undertakes to make every effort to prevent the presence of links to sites containing illegal content on its Site and/or mobile application.
Acceptance

Use of the Site by the User implies knowledge and full acceptance of Arcademy’s Privacy Policy and Terms and Conditions.

Likewise, the User acknowledges that the data requested by Arcademy is necessary, adequate, and not excessive to fulfill the purposes expressed in Section 4 of the Privacy Policy, which would be impossible to fulfill if said data is not provided.
User Communication - How can the User contact Arcademy?
For any questions about this Privacy Policy, Users may contact Arcademy via:
1. Written communication to Av. Coronel Niceto Vega 4639, Buenos Aires, Argentina.
2. Telephone: +54 9 11 3256-4201
3. Email: [email protected]
Modifications - Is this the most current version?

This is the current version of Arcademy’s Privacy Policy, updated on September 8, 2025.

Arcademy may modify this Policy at any time without prior notice. Changes will be effective from their publication on the Site or notification to Users, whichever occurs first. The User must stay informed about the terms included here by logging in periodically.

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