Under review. This is the version 1 draft and it is being reviewed by our legal advisers. It may change before final publication. Items in square brackets will be completed before it is published.
1. Who we are and scope
[COMPANY NAME], tax ID (NIT) [NIT], registered at [ADDRESS], Colombia (“ProEvolution Lab”), provides the ProEvolution Lab sports performance intelligence platform and the website www.proevolutionlab.com.
This policy explains which personal data we handle, why, who we share it with and how you can exercise your rights. It applies in two different situations:
- Website: when you write to us through the contact form, ProEvolution Lab is the controller of that data.
- Platform: each club is the controller of its users' and athletes' data, and ProEvolution Lab handles it on the club's behalf as processor, under the Data Processing Agreement.
2. What data we handle
On the website
- What you give us in the contact form: name, club or institution, e-mail address and message.
- Your theme (light or dark) and language preferences, stored only in your browser.
- The website uses no tracking or advertising cookies and no third-party analytics tools.
In the platform
- Club users (administrators, coaching and support staff): name, e-mail address, role, optional profile photo, preferred language and theme, and technical security records (sign-ins, session activity and two-step verification).
- Athletes: name, date of birth, positions, jersey number, team and season, physical measurements (height and weight), sports background, call-ups and achievements, post-match evaluations, match participation, training attendance and coaching notes (stored encrypted).
- Athlete photo and video: only if the club records the corresponding authorization (from the legal guardian for a minor, or from the athlete themselves if of age).
- AI assistant (optional): each user's questions and answers, stored encrypted and visible only to their author.
3. What we use the data for
- Providing the service: recording matches, evaluations and attendance, and showing the club's dashboards and reports.
- Managing accounts, permissions and the security of the platform.
- Providing support and answering requests.
- Sending the service e-mails that are needed (invitations, password resets and important notices).
- Meeting legal obligations.
We do not sell personal data, use it for advertising or use it to train artificial intelligence models.
4. Legal basis
We handle data under Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and other Colombian personal data protection rules.
Processing is based on the data subject's authorization, which the club obtains and records, and on the performance of the service contract with the club. We respond to requests from authorities when the law requires it.
5. Athletes who are minors (children and adolescents)
The platform handles data of underage athletes. That is why we apply stricter rules:
- Processing serves and respects the best interests of children and adolescents and safeguards their fundamental rights (article 7 of Law 1581 of 2012).
- The club obtains the legal guardian's authorization before recording a minor's data; for photos and videos, the platform requires it to be recorded (who confirmed it and when).
- We collect only the data needed to support athletic development.
- Evaluations are observations of one match: never a judgement of an athlete's worth or potential, nor a diagnosis.
- The website does not collect data about minors.
Adult athletes, according to the age set by the club, give their own authorization.
7. International transfers
Platform data is stored on servers located in São Paulo, Brazil. Some providers process data in other countries: the e-mail provider and OpenAI, L.L.C., the platform's artificial intelligence provider, which processes the AI assistant's questions and the statistics that come with them in the United States, with athletes' and teams' names replaced by codes; this is an international data transfer. If the club connects its own AI account, that provider may process the data in other countries under the club's contract. In those cases we require adequate protection safeguards under Colombian rules. [To be confirmed with the legal adviser: applicable declarations or authorizations.] [PENDING LEGAL REVIEW: safeguards for the transfer to OpenAI in the United States.]
8. Security
- Encryption of information in transit and at rest, plus additional encryption of notes and free text.
- Isolation of each club's data in the database.
- Access based on each person's role, optional or club-wide two-step verification, and sign-out after inactivity.
- An audit log of sensitive actions.
- Passwords nobody can see: they are not stored as text.
No system is completely infallible; if an incident affects your data, we will act under the Data Processing Agreement and the law.
9. How long we keep data
- Platform data: while the club's service is active. If the club closes its account, it can export its data; after a waiting period of 30 days it is deleted.
- Change history (audit): 2 years.
- Session activity: 30 days.
- Undeliverable e-mails (bounces and spam complaints reported by the e-mail provider): 180 days, or until the user's account is deleted.
- AI assistant conversations: deleted automatically after 30, 90 or 180 days without activity, as set by the club.
- Traffic sent to OpenAI: OpenAI keeps it for up to 30 days, only for abuse monitoring. [PENDING LEGAL REVIEW]
- AI assistant usage record (without the text of conversations): 2 years.
- AI assistant security record: when the assistant blocks a misuse attempt, the question that caused it is kept, encrypted, visible only to the club Administrator and impossible to delete or change, as evidence: 2 years.
- Backups: expire according to the provider's schedule ([X] days).
- Contact form messages: [period to be defined].
10. Your rights
As a data subject you can access, update, correct and delete your data, request proof of the authorization, be informed about its use, revoke the authorization when there is no legal or contractual duty to keep it, and file complaints with the Superintendence of Industry and Commerce (SIC).
If your data (or that of an athlete you represent) is in a club's platform, you can contact that club's Administrator or write to us; we will coordinate with the club. We answer queries within ten (10) business days and claims within fifteen (15) business days. The procedure is in Data Deletion.
12. Use of artificial intelligence and data processing
The artificial intelligence assistant is an optional feature included in the plans, with monthly credits depending on the plan. This section explains how it handles data; the terms of use are in the Terms and conditions.
What it is used for
- Answering questions from the club's authorised users about how their teams and athletes are performing.
- Explaining how to use the platform.
- Summarising trends and preparing supporting information for the coaching staff. It never makes decisions about an athlete.
What leaves our servers
- The user's question and only the statistics that user can already see in the platform.
- Athletes and teams replaced by codes (for example, J-3F2A91); names the user types in their question are also rewritten before it is sent.
- Names are put back only on our server, when the answer is shown.
- Never contact details, ID numbers or medical data: the platform does not store them.
The provider of the assistant included in your plan
The assistant included in your plan runs on the API of OpenAI, L.L.C. (not ChatGPT), which processes the data in the United States. OpenAI keeps its API traffic for up to 30 days, only for abuse monitoring. [PENDING LEGAL REVIEW]
No model training
ProEvolution Lab does not use your club’s information to train artificial-intelligence models. The assistant included in your plan runs on the OpenAI API, which does not use data sent through its API to train its models, and before a question is sent we replace athletes’ and teams’ names with codes. In addition, every option to share data with OpenAI is turned off in the platform's OpenAI account.
If your club connects its own AI account
The club can connect its own key from an AI provider instead of using the plan's credits. In that case the terms of the club's own account apply, which ProEvolution Lab does not control:
- OpenAI: data sent through its API is not used to train its models, unless the club itself has turned on data sharing in its account.
- Google Gemini with a paid account (a Google Cloud project with billing): Google does not use prompts or responses to improve its products.
- Google Gemini on the free tier: Google may use the content to improve its products and AI, and people may review it; in the European Economic Area, Switzerland and the United Kingdom the paid-account rules also apply to the free tier. That is why we recommend a paid account.
Your rights
The rights in section 10 also apply to the data the assistant processes: you can request access, correction or erasure by writing to privacy@proevolutionlab.com.
Security
Questions and answers travel encrypted. Attempts to use the assistant for purposes that are not allowed are blocked and logged.
13. Changes to this policy
If we update this policy, we will publish the new version on this page with its date and, if the change is significant, we will notify club administrators.
14. Contact
For any personal data matter, write to privacy@proevolutionlab.com.


