PRIVACY POLICY

1. INTRODUCTION

At VICO LEGACY SPORTS S.L. (hereinafter referred to as «VICO Legacy,» «the Company,» or «we»), we consider the protection of personal data to be one of the fundamental pillars of our business.

We are committed to ensuring that all personal information provided by our users, players, families, legal guardians, sports clubs, academies, collaborators, and any other individuals who interact with us is processed lawfully, fairly, transparently, and securely.

The purpose of this Privacy Policy is to provide clear, simple, and comprehensive information about how we collect, use, store, and protect personal data obtained through our website, online forms, technology platforms, social media channels, electronic communications, and any other services offered by VICO Legacy.

Personal data is processed in accordance with the applicable data protection legislation, including in particular:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR);
  • Organic Law 3/2018 on Personal Data Protection and the Guarantee of Digital Rights (LOPDGDD);
  • Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE);
  • Any other applicable national or European legislation.

Our objective is to provide all users with maximum transparency regarding the processing of their personal data and to ensure that such data is handled with the highest standards of security and confidentiality

2. DATA CONTROLLER

In accordance with Article 13 of the General Data Protection Regulation (GDPR), the Data Controller is:

Company Name:
VICO LEGACY SPORTS S.L.

Tax Identification Number (CIF):
B24856056

Registered Address:
C/ Maestro Serrano No. 13
46120 Alboraya (Valencia)
Spain

Email:
info@vicolegacy.com

Telephone:
+34 626 600 337

Website:
www.vicolegacy.com

3. SCOPE OF APPLICATION

This Privacy Policy applies to all individuals who interact with VICO Legacy through any of the available communication channels, including but not limited to:

  • Website visitors
  • Individuals requesting information
  • Players
  • Parents or legal guardians
  • Sports clubs
  • Sports academies
  • Coaches
  • Scouts
  • Collaborators
  • Sports agencies
  • Player representatives
  • Suppliers
  • Job applicants

This Privacy Policy also applies to the processing of personal data collected through:

  • Our website
  • Online and paper forms
  • WhatsApp
  • Email communications
  • Social media platforms
  • Video calls
  • Sporting events
  • Sports camps
  • Legacy Trials
  • International programmes
  • The Scout Decision platform
  • Any other communication channel used by the Company

s, or use the website’s content for fraudulent purposes.

4. PRINCIPLES OF DATA PROCESSING

All personal data processed by VICO Legacy is handled in accordance with the principles established in Article 5 of the General Data Protection Regulation (GDPR).

Accordingly:

Lawfulness

Personal data will only be processed where there is a valid legal basis.

Fairness

Users will be informed in a transparent manner about how their personal data is processed.

Transparency

All relevant information will be made available in a clear, accessible, and understandable manner.

Data Minimisation

Only the personal data that is strictly necessary for the intended purpose will be collected.

Accuracy

Personal data will be kept accurate and, where necessary, up to date.

Storage Limitation

Personal data will only be retained for as long as necessary to fulfil the purposes for which it was collected.

Integrity and Confidentiality

Appropriate technical and organisational measures will be implemented to ensure the security and protection of personal data.

5. WHAT PERSONAL DATA DO WE COLLECT?

Depending on the service requested, we may collect different categories of personal information.

Identification Data

This may include:

  • First name
  • Last name
  • Date of birth
  • Nationality
  • Identity document
  • Passport
  • Photograph

Contact Information

This may include:

  • Address
  • Country
  • City
  • Postal code
  • Email address
  • Telephone number

Sporting Information

This may include:

  • Playing position
  • Current club
  • Previous clubs
  • Competition category
  • Sporting history
  • Achievements
  • Performance statistics
  • Height
  • Weight
  • Player profile
  • Technical reports
  • Assessment results

Sports Videos

With the appropriate consent, players may submit videos for sporting evaluation.

These videos may be reviewed by:

  • Scouts
  • Coaches
  • Partner clubs
  • Authorised technical staff

Such videos will be used exclusively for the purposes described in this Privacy Policy.

Photographs

During participation in activities organised by VICO Legacy, photographs may be taken for:

  • Organisational purposes
  • Identification purposes
  • Administrative purposes
  • Promotional purposes, where specific consent has been obtained

Medical Information

Where necessary to ensure the safety of participants, we may collect information relating to:

  • Allergies
  • Injuries
  • Medical conditions
  • Dietary restrictions
  • Medication
  • Special requirements

This information will be processed with enhanced confidentiality and only where strictly necessary for the provision of our services.

Academic Information

Where required for certain international programmes, we may collect:

  • Educational institution
  • Academic level
  • Languages spoken
  • Certificates
  • Academic records

Financial Information

Where services are contracted, we may process:

  • Billing information
  • Payment history
  • Tax information

VICO Legacy does not currently process payments directly through its website.

6. PURPOSES OF PROCESSING

VICO Legacy processes personal data for the following purposes:

  • To respond to requests for information.
  • To manage registration and enrolment processes.
  • To organise Legacy Trials.
  • To manage sports development programmes.
  • To coordinate international sports camps.
  • To prepare sports performance reports.
  • To carry out technical player assessments.
  • To facilitate sporting opportunities.
  • To manage sports representation services.
  • To coordinate trials with partner clubs.
  • To manage administrative documentation.
  • To issue certificates.
  • To handle incidents and enquiries.
  • To ensure the safety and well-being of participants.
  • To comply with applicable legal obligations.
  • To respond to enquiries and requests.
  • To improve our services.
  • To produce internal statistical analyses.
  • To protect the legitimate interests of VICO Legacy.

7. LEGAL BASIS FOR PROCESSING

The processing of personal data is based on one or more of the legal grounds established in Article 6 of the General Data Protection Regulation (GDPR), including:

  • The consent of the data subject or, where the data subject is a minor, the consent of their parent or legal guardian.
  • The performance of a contract or the implementation of pre-contractual measures requested by the data subject.
  • Compliance with legal obligations applicable to VICO Legacy.
  • The legitimate interests pursued by VICO Legacy, provided that such interests do not override the fundamental rights and freedoms of the data subject.

Where processing is based on consent, such consent may be withdrawn at any time without affecting the lawfulness of any processing carried out before its withdrawal.

8. RETENTION OF PERSONAL DATA

VICO LEGACY SPORTS S.L. will retain personal data only for as long as necessary to fulfil the purposes for which it was collected and, subsequently, for the periods required by applicable legislation to address any legal responsibilities arising from such processing.

As a general rule, personal data will be retained as follows:

Requests for Information

Personal data will be retained for the time necessary to respond to the enquiry and, thereafter, for a maximum period of twenty four (24) months unless the individual requests its deletion sooner.

Clients and Participants in Sports Programmes

Personal data will be retained throughout the duration of the contractual relationship and, after its termination, for the periods required under applicable tax, commercial, and civil legislation.

Players Under Evaluation

Personal data will be retained for as long as the sporting assessment remains relevant for the provision of our services or until the individual requests its deletion, unless a legal obligation requires a longer retention period.

Medical Information

Medical data will only be retained for the period strictly necessary to ensure the participant’s safety and to comply with applicable legal obligations.

Photographs and Videos

Photographs and videos will be retained for the period authorised by the consent provided or until such consent is withdrawn.

CVs and Job Applications

Curricula vitae and recruitment applications will be retained for a maximum period of one (1) year unless the applicant expressly authorises a longer retention period.

Once the applicable retention periods have expired, personal data will be securely blocked where required by law and subsequently deleted or anonymised.

 

9. RECIPIENTS AND DISCLOSURE OF PERSONAL DATA

VICO Legacy will disclose personal data only where such disclosure is necessary for the provision of contracted services, where required by law, or where the data subject has provided their consent.

Depending on the services requested, personal data may be shared with:

  • National and international sports clubs.
  • Partner sports academies.
  • Coaches, sporting directors, and authorised technical staff.
  • Companies responsible for organising sporting events.
  • Partner educational institutions.
  • Hotels and accommodation providers.
  • Transport and logistics companies.
  • Insurance companies.
  • Financial institutions for the management of payments.
  • Public authorities where legally required.
  • Law enforcement authorities where appropriate.
  • Technology service providers acting as data processors.

Under no circumstances will VICO Legacy sell or transfer personal data to unrelated third parties for commercial or marketing purposes.

All service providers with access to personal data act as data processors and are contractually bound to comply with applicable data protection legislation.

10. INTERNATIONAL DATA TRANSFERS

Due to the international nature of VICO Legacy’s activities, certain processing operations may involve the international transfer of personal data.

Such transfers may occur, among other circumstances, when it is necessary to share information with:

  • Foreign sports clubs.
  • International sports academies.
  • Sports organisations.
  • Technology providers whose servers are located outside the European Economic Area (EEA).
  • Sports management platforms.
  • Companies collaborating in international programmes.

Where personal data is transferred outside the European Economic Area, VICO Legacy will ensure that such transfers comply with Articles 44 and subsequent provisions of the General Data Protection Regulation (GDPR).

To ensure an adequate level of protection, VICO Legacy may rely on one or more of the following safeguards:

  • Adequacy Decisions adopted by the European Commission.
  • Standard Contractual Clauses approved by the European Commission.
  • Binding Corporate Rules (BCRs), where applicable.
  • Any other safeguard recognised under applicable data protection legislation.

11. PROCESSING OF MINORS' PERSONAL DATA

The protection of minors is a priority for VICO Legacy.

Many of our sports programmes, camps, and player evaluation processes are intended for participants under eighteen (18) years of age.

Accordingly:

  • Personal data relating to minors will only be processed where the express consent of a parent or legal guardian has been obtained whenever required by applicable law.
  • Parents or legal guardians are responsible for providing accurate information and ensuring that the minor’s personal data remains up to date.
  • Any authorisation relating to participation in sports programmes, technical evaluations, travel, emergency medical treatment, or the use of photographs or videos must be granted by the legal guardian whenever legally required.
  • VICO Legacy implements enhanced safeguards to ensure the confidentiality and security of all personal data relating to minors.
  • Under no circumstances will personal data relating to minors be processed for purposes incompatible with those for which it was originally collected.

12. USE OF TECHNOLOGY PLATFORMS

To manage players, conduct sporting evaluations, monitor recruitment processes, and organise sports programmes, VICO Legacy may use specialised technology platforms.

We currently use, among others:

Scout Decision, a sports management platform used for player assessment and monitoring.

Through this platform, we may process information including:

  • Player profiles
  • Competitive history
  • Technical reports
  • Sports videos
  • Photographs
  • Contact information
  • Assessments carried out by coaches and scouts

VICO Legacy selects only service providers that offer appropriate guarantees regarding data protection and information security.

Where these providers act as data processors, the corresponding Data Processing Agreements (DPAs) are executed in accordance with Article 28 of the General Data Protection Regulation (GDPR).

 

13. ANALYTICS TECHNOLOGIES AND COOKIES

The VICO Legacy website uses analytical tools to better understand how visitors use our website, improve user experience, and optimise the content and services we provide.

We currently use:

Google Analytics

This tool allows us to obtain aggregated statistical information regarding, among other things:

  • Number of visitors
  • Pages visited
  • Time spent on the website
  • Device used
  • Browser type
  • Approximate geographical location
  • Traffic source

Under no circumstances is this information used to make automated decisions producing legal or similarly significant effects on users.

Further information regarding the use of cookies can be found in our Cookie Policy.

14. YOUR RIGHTS

Any individual whose personal data is processed by VICO Legacy may exercise the following rights at any time and free of charge:

  • Right of access
  • Right to rectification
  • Right to erasure («Right to be Forgotten»)
  • Right to object
  • Right to restriction of processing
  • Right to data portability
  • Right to withdraw consent at any time
  • Right not to be subject to automated decision-making, where applicable

To exercise any of these rights, you may submit a written request to:

VICO LEGACY SPORTS S.L.

📧 info@vicolegacy.com

Your request should include sufficient information to enable us to verify your identity and clearly specify the right you wish to exercise.

If you believe that the processing of your personal data infringes applicable data protection legislation, you have the right to lodge a complaint with the Spanish Data Protection Authority (Agencia Española de Protección de Datos – AEPD) or with your local supervisory authority, where applicable.

15. SECURITY MEASURES

VICO Legacy implements appropriate technical and organisational measures to ensure a level of security appropriate to the risks involved, in accordance with Article 32 of the General Data Protection Regulation (GDPR).

These measures include, among others:

  • Information access controls
  • User and permission management
  • Regular data backups
  • Protection against unauthorised access
  • Antivirus and anti-malware systems
  • Secure communication protocols
  • Staff training on data protection and information security
  • Internal procedures for managing security incidents

Despite these measures, users acknowledge that no computer system or method of electronic transmission over the Internet can guarantee absolute security against all potential risks.

16. SOCIAL MEDIA AND EXTERNAL PLATFORMS

VICO LEGACY SPORTS S.L. maintains an active presence on various social media platforms and digital channels to provide information about its services, share sports-related content, promote events, engage with the community, and respond to enquiries from users and clients.

VICO Legacy may maintain official profiles on platforms including, but not limited to:

  • Instagram
  • Facebook
  • LinkedIn
  • TikTok
  • YouTube
  • Any other social media platforms that may be incorporated in the future

Users’ interactions with these social media profiles are subject both to this Privacy Policy and to the respective terms of use and privacy policies established by each platform.

When a user follows our profiles, interacts with our publications, or contacts us through social media, VICO Legacy may only access the information that the user has made publicly available or has voluntarily chosen to share with us.

Personal data obtained through these platforms will be used exclusively for the following purposes:

  • Responding to enquiries and requests for information.
  • Managing communications with users and clients.
  • Providing information about programmes, activities, and sporting events organised by VICO Legacy.
  • Publishing institutional and sports-related content.
  • Improving the quality of our services.

VICO Legacy is not responsible for the processing of personal data carried out directly by social media platforms, each of which acts as an independent data controller in accordance with its own privacy policies.

 

Users are encouraged to review the privacy policies and privacy settings of any social media platform they use.

17. LINKS TO THIRD-PARTY WEBSITES

The VICO Legacy website may contain links to websites operated by third parties, including sports clubs, academies, partner organisations, public authorities, sponsors, and other service providers.

These links are provided solely for the convenience of users and to facilitate access to information that may be of interest.

However, VICO Legacy exercises no control over the content, availability, privacy practices, or terms of use of such external websites.

Accordingly:

  • VICO Legacy does not guarantee the accuracy or currency of the information published on third-party websites.
  • VICO Legacy accepts no responsibility for the processing of personal data carried out by such third parties.
  • The inclusion of any external link does not imply the existence of any commercial relationship, sponsorship, recommendation, or endorsement by VICO Legacy unless expressly stated.

Users are encouraged to review the privacy policies and legal notices of any third-party website before providing personal information.

18. CHANGES TO THIS PRIVACY POLICY

VICO LEGACY SPORTS S.L. reserves the right to amend, update, or modify this Privacy Policy at any time whenever necessary to:

  • Comply with legislative or regulatory changes.
  • Meet new legal obligations imposed by competent authorities.
  • Introduce new services or website functionalities.
  • Implement new technological tools.
  • Modify the Company’s personal data processing activities.
  • Improve transparency and the protection of users’ rights.

Any modifications will be published on this website and shall become effective from the date of publication unless a different effective date is expressly indicated.

Where changes significantly affect the rights of data subjects or involve new processing activities based on consent, VICO Legacy will take appropriate measures to inform users and, where legally required, obtain renewed consent.

Users are encouraged to review this Privacy Policy periodically to remain informed about how we protect their personal information.

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19. CONTACT AND EXERCISE OF YOUR RIGHTS

For any enquiries regarding this Privacy Policy, the processing of your personal data, or the exercise of your rights under applicable data protection legislation, you may contact:

VICO LEGACY SPORTS S.L.

Registered Address:
C/ Maestro Serrano No. 13
46120 Alboraya (Valencia)
Spain

Email:
info@vicolegacy.com

Telephone:
+34 626 600 337

Website:
www.vicolegacy.com

Requests relating to the exercise of your rights should contain sufficient information to identify you and clearly specify the right you wish to exercise.

VICO Legacy will respond to such requests within the time limits established by the General Data Protection Regulation (GDPR), unless an extension is permitted by applicable law.

If you believe that the processing of your personal data does not comply with applicable data protection legislation, you have the right to lodge a complaint with the competent supervisory authority.

In Spain, the competent supervisory authority is:

Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD)

C/ Jorge Juan, 6
28001 Madrid
Spain

Website: www.aepd.es

20. FINAL PROVISIONS AND ENTRY INTO FORCE

This Privacy Policy has been prepared by VICO LEGACY SPORTS S.L. to ensure compliance with applicable personal data protection legislation and to provide users with a transparent framework explaining how their personal information is collected, used, stored, and protected.

This version of the Privacy Policy shall enter into force on the date of its publication on the official VICO Legacy website and shall remain in effect until replaced by a subsequent updated version.

The continued use of the VICO Legacy website and the services provided by the Company constitutes acceptance of this Privacy Policy as published and amended from time to time.