← HockeyCut
This text is a draft and will be updated when the final version is published.

Privacy Notice — HockeyCut

Not legal advice. Version EN-PRV-1.1-draft · 15 November 2026. Square brackets [...] are placeholders. Turkish users: see the Turkish notice (KVKK Aydınlatma Metni).

1. In short

2. Who is responsible (controller) and how to contact us

2.1. Controller: [COMPANY LEGAL NAME], [address], registered in Türkiye (registry no. [ ]). Email: [coming soon]. Data-protection contact / officer: [name or "none appointed"].

2.2. EU representative (GDPR Article 27): [name, address — to be appointed before we offer the Service in the EU].

2.3. UK representative (UK GDPR Article 27): [name, address — to be appointed before we offer the Service in the UK].

2.4. Who is responsible for what:

DataWho decides how it is usedOur role
Account, licence, payment, support, record of your acceptanceWe doController
Training Contribution (answers, clips, numeric data)We doController
Your match videos and projects on your own computerYou (the club, coach or other user)We are only the software provider; we do not receive them

3. What data we process

CategoryExamplesWhere from
Account and licenceName or email (if you give it), licence key (stored as a summary), a device summary (a one-way hash, not the raw device ID), operating system type, app versionYou, the app
PaymentOrder number, plan, amount, date, status. We do not store your card number; the payment provider doesYou, the payment provider
Support and legalMessages you send us, your complaints and requests, the record of your acceptance (version, time, anonymous user number, device summary)You, the app
Training ContributionYes/No answers; short clips (a few seconds, reduced quality, no sound) that can show players, referees, shirt names and numbers; event type, time, team code (home/away), position on the ice, confidence score, month, a random user numberYou, the app
Download requestYour email address, if you ask for a download link (the link works for [72] hours)You
WebsiteOnly strictly necessary cookies and similar storage (login session, language). No advertising or analytics cookiesYour browser
Security logsA shortened or hashed IP address, time, actionOur systems

What we do not ask for: sensitive data (health or injury details, religion, ethnic origin, political views) and biometric data. Clips are not meant to be used for these. We do not identify any person by face, voice or other biometric means. The software can follow a player from frame to frame inside one video; it does not tell us who the person is.

(for people in the EEA and the UK; "Art." = article of the GDPR / UK GDPR)

PurposeDataLegal basis
Open your account, give you the app, check your licence, apply package limitsAccount and licenceContract (Art. 6(1)(b))
Take payment, issue invoices, tax and accountingPaymentContract (Art. 6(1)(b)); legal duty (Art. 6(1)(c))
Support, answers to your requestsSupportContract; legitimate interests (Art. 6(1)(f))
Security, fraud prevention, misuse of licencesSecurity logs, licenceLegitimate interests (Art. 6(1)(f))
Proof of your acceptance of our terms, and defending legal claimsRecord of acceptanceLegitimate interests (Art. 6(1)(f)); legal claims
Train, test and improve our AI models and the ServiceTraining ContributionFor your own data (answers, user number): contract — the Training Contribution is the agreed price of the Free package and part of the Premium package (Art. 6(1)(b)), and our legitimate interests (Art. 6(1)(f)). For other people shown in clips: our legitimate interests (Art. 6(1)(f)) in building and improving the models. We have assessed these interests against the rights of the people shown, including children. [Balancing assessment on file — to be completed.]
Download link and emails you ask forEmailYour consent (Art. 6(1)(a)) — you can withdraw it
Service emails (security, changes to terms)EmailContract; legitimate interests

We do not rely on consent for the Training Contribution, because it is a condition of the Service. We do not use the Training Contribution for advertising or profiling people. We do not make decisions about people based only on automated processing.

5. Who receives the data

5.1. Service providers working for us (under written contracts): hosting and server providers ([Turhost, Türkiye — to be confirmed]); computing and storage providers used to train models ([names and countries to be inserted — e.g. cloud GPU or notebook providers]); payment provider / merchant of record ([name]); email provider ([name]).

5.2. Authorities and courts, when the law requires; professional advisers under confidentiality.

5.3. Business transfer: if we merge or sell the business, the data may go to the new owner, who must respect this notice.

5.4. We do not sell personal data and do not share it for advertising.

5.5. We do not send Training Contribution clips to third parties who want to build their own products.

5a. Connections the app makes

The app may connect to the addresses below on its own, even when you are not doing anything. This is so that the app works; your full match is never sent to any of them.

ConnectionWhenWhat is sent
Match catalogue and official match sheet: buznet-api.sporpano.com, stats.iihf.com (public sites of the federation/league and of the IIHF) When you paste the link of an official match page, the app connects only to that page's site: stats.swehockey.se (Sweden), mestis.fi and tulospalvelu.leijonat.fi (Finland), sihf.ch (Switzerland), eishockey.at (Austria), lhf.lv (Latvia), hokej.si (Slovenia), eliteleague.co.uk (England), fhr.ru, vhlru.ru and whl.ru (Russia), pro.ligasy.kz, jas.ligasy.kz and qyz.ligasy.kz (Kazakhstan), rbihf.be (Belgium), del-2.org and penny-del.org (Germany), hockey.lt (Lithuania) and the websites of US college teams (NCAA game pages).After you accept the first-run screen, when My Matches opens and then once an hour. Official sheet lookup: only when you ask for itOnly public tournament and match IDs. No video, player names or account details. These sites can see the IP address of the computer that connects.
Licence: revocation-list checkWhen the app starts and every 6 hoursNo personal data.
Licence: activationWhen you enter a licence keyLicence key, a summary (hash) of the device ID, device name, platform and version.
Training Contribution (our collection server)In the background, after you acceptYour answers and short clips. Details and safeguards: section 5 and the Training Contribution terms (not repeated here).
Only if you start or switch them on: downloading video from Google Drive; cloud verification; portal sync (currently off)When you start or enable themDrive download: file ID and Google authorisation only. Cloud verification: see section 5 and the Turkish notice. Portal sync is currently off.

Apart from these, the app does not connect to any other address on its own, and it does not check for updates.

6. If you appear in a clip (players, referees, parents, others)

6.1. A person who uses our app sent a short clip that shows you. We did not collect it from you. We do not know who you are: we do not receive names or shirt-number lists, and we do not use facial recognition. We cannot contact you.

6.2. We use the clip only to train, test and improve our models. We keep it encrypted, for at most [24 months].

6.3. The app user has declared to us that they have the right to use the video and that they asked for permission from the people shown (and from the parents or legal guardians of minors). We rely on this, but it does not replace your rights.

6.4. You can ask us to delete a clip that shows you, or object to its use, by writing to [coming soon]. Please tell us enough to find the clip (for example, the match, the date, the team, the time). We may ask for information to help us find it. If we cannot find a clip that shows you, we will tell you.

6.5. A parent or legal guardian can ask on behalf of a minor.

6.6. Because we cannot identify you, some rights (such as access or portability) can only be met if you give us information that lets us find your data (GDPR Art. 11).

7. Children

7.1. The app is for adults (18+). We do not offer it to children, and we do not knowingly collect personal information from a child directly.

7.2. Clips may show minors (for example, youth players). The adult who loads the video declares that they have the permission of a parent or legal guardian. We treat clips with minors with extra care: short clips, reduced quality, no names, no sound, encryption, limited access, and quick deletion on request.

7.3. If you think a child is using the app, write to [coming soon]. We will close the account and delete the data.

8. Transfers outside your country

8.1. Our servers are in [Türkiye]. We process the data there and use providers in other countries as listed in Section 5.

8.2. EEA and UK: Türkiye has no European Commission "adequacy" decision. When personal data goes from the EEA or UK to us or to our providers outside those areas, we use safeguards such as standard contractual clauses and extra measures (encryption, access limits) [exact safeguards to be confirmed]. You can ask us for a copy of the safeguards ([coming soon]).

8.3. Türkiye: we follow the transfer rules of KVKK Article 9 for transfers out of Türkiye.

9. How long we keep data

DataTime
Training ContributionAt most [24 months], or until you ask us to delete it, or until a valid deletion request from a person shown. Anonymised or aggregated results and trained models may stay (Section 12)
Account and licenceWhile the account is open; then up to [30] days to let you change your mind
Payment and invoicesAs long as tax and accounting laws require (for example, [10] years in Türkiye)
Record of acceptanceContract period + [10] years, to defend claims. After the account is closed, the licence link is deleted and the record stays under the anonymous user number
Support messages[2] years after the request is closed
Security logs[1] year
Download-link emailLink validity + [30] days, unless you agreed to emails

10. Your rights

10.1. EEA and UK: you can ask us for access, correction, deletion, restriction, portability (where it applies), and you can object to processing based on legitimate interests. You can withdraw consent (for example for emails) at any time. We answer within one month (we may extend it by two months for complex requests and will tell you).

10.2. United States: depending on your state, you may have the right to know, access, correct and delete your data, and to opt out of sale or sharing. We do not sell or share personal data (see Section 14).

10.3. Türkiye: your rights under KVKK Article 11 are in the Turkish notice.

10.4. Canada, Australia and other countries: you may have access, correction and complaint rights under your local law. Write to us and we will respond as the law requires.

10.5. How: email [coming soon] or use the request link in the app settings ([URL]). We may ask for information to confirm who you are. We do not charge for requests unless the law allows it.

10.6. Complaints: you may complain to your data-protection authority (for the EEA: the authority in the country where you live, work, or where the problem happened; for the UK: the Information Commissioner's Office; for Türkiye: the Personal Data Protection Authority). We ask you to contact us first, but you do not have to.

11. Security and incidents

We use encryption in transit and at rest, access controls and logging, separation of the stored clips from the web, and limits on who can read them. If a data breach is likely to risk people's rights, we notify the competent authority without undue delay and where possible within 72 hours, and we tell affected people where the law requires it.

12. AI models

We use the Training Contribution to build models that find events in hockey video. A trained model is not a copy of the clips, but it may be affected by them, and it cannot always be changed to remove one piece of data. We do not claim that a model "forgets" a clip. We delete the clips themselves on valid requests and stop using them for future training.

13. Cookies and similar technology

Our website and portal use only strictly necessary cookies and local storage (a login session, a two-step sign-in step, your language choice). We do not use advertising, analytics or social-media trackers, and we do not load fonts or scripts from third parties. If we add analytics later, we will update this notice and ask for consent where the law requires.

14. Regional information

A. EEA and UK

B. United States

C. Türkiye

For KVKK, please read the Turkish notice. In short: [COMPANY LEGAL NAME] is the data controller for the data in Section 2.4; your rights are in KVKK Article 11 and you can apply to us at [coming soon] or by registered electronic mail [KEP address].

15. Changes to this notice

We will change this notice when our practices change. For important changes we tell you by email or in the app before they apply, and, if the change affects the Training Contribution, the app shows the acceptance screen again. Earlier versions are kept.

16. Contact

[COMPANY LEGAL NAME] · [address] · [coming soon] · EU representative: [ ] · UK representative: [ ].


VersionDateChange
EN-PRV-1.0-draft2026-11-15First international English draft
EN-PRV-1.1-draft2026-11-15Added section 5a, connections the app makes