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Privacy policy

Last updated 28 September 2026

Sportfolios processes photographs that frequently show children. This page explains what we store, why, for how long, and what you can ask us to do about it.

Who is responsible

For operating the Sportfolios platform, accounts and platform support, the controller is Diego Rodriguez, Rodriguez-Web, Delftstraße 8, 27474 Cuxhaven, Germany; email: diego@rodriguez-web.de. For gallery photographs and player data processed on a photographer's or studio's instructions, that customer is the controller and Sportfolios acts as processor under the applicable data-processing agreement. Payment providers may act as independent controllers for their payment services.

What we store

Grouped by purpose rather than by table:

  • Account data: name, email, optional profile photo, sign-in provider identity, locale, organisation membership and role. Authentication credentials are handled by the authentication provider.
  • Sports data: clubs, seasons, teams, players, jersey numbers, positions, birth years, guardian contacts.
  • Photographs: originals, generated derivatives, EXIF metadata and capture timestamps.
  • Recognition results: detected jersey numbers, player and jersey bounding boxes, confidence scores and the resulting player assignments.
  • Optional player references: reference photographs, face crops, numerical facial features used for comparison, comparison scores and appearance results when reference-based recognition is enabled.
  • Interaction data: gallery views, favourites, selections, orders and downloads.
  • Native purchase data: the selected photos and product, Apple transaction identifiers and signed transaction information, purchase verification results, and account-linked purchase and download history.
  • Notification data: a device registration identifier, push token, platform and app version when notifications are enabled.
  • Content reports: the gallery or photo concerned, the selected report reason, optional description, a hashed reporting-session identifier, review status and timestamps.
  • Access logs: share-link redemptions with salted hashes of IP address and user agent.

Optional reference-based recognition

Recognition can combine readable jersey numbers or names, kit and roster context, photo context and optional reference comparisons. Reference material may include manually supplied photographs and reference crops derived from reviewed assignments where the organisation and player settings permit this. The service can compare visible faces against the references supplied for that request. Results may be incorrect; authorised users can inspect and correct assignments. Recognition is used to organise photographs, not to make legal or similarly significant decisions about a person.

The organisation using Sportfolios determines whether this optional processing is enabled and is responsible for establishing and documenting the applicable legal basis for the photographed people. Sportfolios processes the reference material on its instruction and provides organisation- and player-level deletion controls.

When Google's Gemini analysis is used, image data or crops and the relevant recognition instructions and roster context are sent to Google's Gemini Developer API. Optional face comparison also uses a Sportfolios-operated OpenCV/SFace service on Google Cloud; it computes numerical facial features and comparison scores. Where a Google-based verification pass is used, the required comparison crops are also sent to Google. This processing can concern biometric data used to identify a player and must not be treated as ordinary anonymous image statistics.

What we do not do

Sportfolios does not operate a public, global face-search database or sell reference data. Recognition is scoped to the organisation and the references admitted to the request. An automatic assignment is not a guarantee of the person's identity and does not change the photographer's responsibility for gallery access and publication.

Sportfolios does not train a general model on uploaded photographs. Reviewed references used for later comparison are distinct from general-model training. Optional training-data export has separate organisation and player consent controls. External providers process submitted data under their applicable service and data-processing terms; information about Google's data handling is linked below.

Google Gemini API data-use terms

Legal bases

Contract (Art. 6(1)(b) GDPR) for requested account services and purchase delivery; legal obligations (Art. 6(1)(c)) for required accounting and compliance records; legitimate interests (Art. 6(1)(f)) for proportionate platform security, abuse prevention and access logging. Optional marketing and consent-based reference or training-export processing rely on the applicable consent (Art. 6(1)(a)). The photographer must determine the lawful basis for collecting and sharing the photographs. Where biometric identification is used, an applicable exception under Art. 9 GDPR, such as explicit consent where appropriate, is additionally required.

You may withdraw consent for future processing without affecting processing already lawfully carried out. Contact the photographer for gallery processing or Sportfolios for platform processing; technical camera permission, accepting general terms and permission to use an image in store marketing are not interchangeable with consent to biometric processing.

Mobile photo access and notifications

The mobile app uses the photos or camera you select to upload gallery photographs or change your profile picture. You can decline camera or photo permissions and continue to use features that do not need them. Originals are retained in the app's upload queue while transfer is pending or needs retry; they are uploaded to the selected workspace, not to an unrelated photographer. Changing a photo permission does not by itself delete a file already uploaded to a gallery.

If notifications are enabled, a push registration links a device token to your account so the service can send functional notifications. You can turn off notification permission in your device settings. Push permission is not consent to marketing email.

Purchases in the iOS app

Digital photo purchases offered inside the iOS app use Apple's in-app purchase system. Apple processes the payment; Sportfolios does not receive your Apple payment-card details. Sportfolios verifies signed transaction information and associates the verified purchase with your account, the selected product and the photos to be delivered. This information is used to deliver the purchase, display purchase history, prevent transaction reuse and respond to refunds or revoked transactions.

Web checkout and physical-product checkout use their separately identified payment provider, such as Stripe. The available product, licence and checkout method are shown before purchase. A gallery may instead permit free viewing or downloads; opening a free gallery does not itself create a paid order.

Where data is stored

The primary database uses Firestore's eur3 European multi-region. Gallery media and application hosting use the configured Google Cloud storage and hosting infrastructure. These storage locations do not mean that every external service processes all data exclusively in the EU. Firebase Authentication, Google Gemini, Apple or Google sign-in, app-store payment services, Stripe, and Expo/device push services have their own processing infrastructure and applicable terms.

Google/Firebase provide authentication, storage and hosting; Google Gemini receives the analysis data described above when it is used. Apple processes iOS in-app payments; Google Play receives transaction data where its billing flow is available. Stripe handles applicable web or physical-product payments. Push notifications use Expo and the relevant Apple/Google delivery service. Where transactional email is enabled, the configured email delivery provider receives the recipient and message; authentication messages may come from Firebase. Sportfolios does not store payment-card numbers.

International processing may be subject to applicable adequacy decisions or contractual safeguards such as standard contractual clauses. Contact diego@rodriguez-web.de for information about the safeguards and processors applicable to your service; an EU database location alone is not a transfer safeguard for a separate AI or payment provider.

How long we keep it

Gallery access follows the photographer's expiry and publication settings. Access expiry is not the same as immediate erasure of the stored files; media remain subject to workspace deletion and cleanup policies. Uploaded player references have no fixed automatic expiry and remain until removed or disabled through the relevant controls. Deleting stored reference material excludes it from subsequent admitted comparison requests.

The face-comparison service holds numerical reference features in memory during a request, without an application-level reference-feature cache shared between requests. This is not a promise of immediate physical-memory zeroisation or cancellation of an in-flight request that already received data. Order/invoice, consent, security and deletion records may need to remain for applicable legal obligations or the establishment, exercise or defence of legal claims.

Deleting your account

You can start account deletion in the mobile account settings. For security, a recent sign-in and an explicit confirmation are required; an Apple-linked account additionally confirms Apple authorization so it can be revoked. The service completes deletion through a retryable erasure process rather than only hiding the account.

Deletion removes the account identity, profile and push registrations. A workspace you solely own without other active members is deleted with its private media. A shared workspace is not erased merely because one member leaves; its content remains with the workspace. If you are its only owner and other members remain, transfer ownership before deleting your account. Export anything you need before confirming deletion.

Accounting, consent, security audit and deletion-request records may be retained where necessary for legal obligations and proof of processing. Account-linked operational purchase reservations are removed and retained mobile purchase records have direct account and access-link identifiers removed. A deletion confirmation is shown only after the erasure processor succeeds; a failed request can be retried.

Request Sportfolios account deletion without the app

Content safety reports

Customers can report content in an accessible mobile gallery or contact diego@rodriguez-web.de about privacy, copyright, child safety or other concerns. A report is stored for review with the affected gallery or photo and a hashed reporting-session reference. Please include only information needed to explain the concern, not unrelated sensitive personal information.

Submitting a report does not automatically remove a photograph. The mobile option to hide a photographer is a local preference on that device, not a server-wide block, removal of the photographer's account or a deletion request. Contact support if you need removal or another action beyond hiding content on your device.

Your rights

You may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interest. Requests are tracked against the statutory one-month deadline. Write to diego@rodriguez-web.de. You also have the right to complain to a supervisory authority.

Photographs of children

Photographers must take particular care with photographs and player data concerning children and obtain any required guardian permission. Where a birth year is supplied, Sportfolios uses it for minor-related safeguards. Missing or inaccurate roster information cannot establish that a person is an adult. An organisation must not bypass the applicable sharing or recognition restrictions, and a player can be excluded from automatic assignment. Contact support promptly about a child's photograph or an inappropriate public link.

Privacy policy · Sportfolios