Privacy Policy for We Make Footballers® (Global Baseline)

Protecting Your Data

Last updated: 30th March 2026

We Make Footballers® Ltd, Registration number 07752847, trades at Willoughby House, 439 Richmond Road, Twickenham, TW1 2AG.

Your privacy is important to us. This Privacy Policy outlines how we collect, use, store, and protect your personal data when you use our website, booking software, and services.

By using our services, you consent to the practices described in this policy. These Privacy Terms apply globally, with additional protections based on local law. In the event of conflict, the jurisdiction-specific law prevails.

Local Law Compliance

• United States: WMF complies with the California Consumer Privacy Act (CCPA) and equivalent state privacy laws.
• United Kingdom: WMF complies with the Data Protection Act 2018 and UK GDPR.
• United Arab Emirates: WMF complies with Federal Data Protection Law No. 45 of 2021 (PDPL).
• Australia: WMF complies with the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs).

This Privacy Policy applies to all We Make Footballers programs including: regular weekly coaching classes, trial sessions, Fun Flair Festivals (one-day festival events), scouting services, and all other programs and services.

1. What This Policy Covers

• What data we collect about you.
• How we collect your personal data.
• What we do with your data.
• Where we store your data.
• How we keep your data secure.
• Whether we share your data with third parties.
• The cookies and pixels we use.
• Your rights in relation to your data.

This Privacy Policy forms part of our Website Terms. By accepting our Website Terms, registering for our services, or signing up for newsletters, you consent to the practices described herein. You may withdraw consent at any time by contacting us at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect the following types of personal data directly from you:

• Player Information: Name, date of birth, medical or additional needs information, performance data.
• Parent/Guardian Information: Name, email, phone number, payment details.
• Other Details: Feedback forms, correspondence, registration details.

2.2 Automatically Collected Information

We use tools such as Google Analytics, MoEngage, and cookies to collect:

• IP address and device information (browser, OS).
• Website/email engagement (pages visited, newsletter clicks).
• Timezone and geolocation data.

2.3 Publicly Available Information

We may collect data from public records (e.g., electoral register) for verification.

3. How We Use Your Information

We process data for the following purposes:

• Service Delivery: Managing bookings, communications, training.
• Marketing: Sending promotional emails, offers, tailored content.
• Session Analysis: Improving training and development.
• Recording and Sharing: VeoCam and similar footage may be shared with parents, scouts, or for marketing.
• Fraud Prevention: Verifying identities and preventing misuse.

3.1 Payment Data & Automatic Retry Processing

We Make Footballers® uses trusted, PCI-DSS compliant payment processors (including Stripe, GoCardless, or any future approved provider) to securely store payment credentials such as card tokens or bank mandate details. WMF does not store raw card or bank details.

Where the Parent provides payment information for a subscription or recurring booking, WMF may process this stored payment method to automatically reattempt failed payments in accordance with our Terms & Conditions. This processing includes:

• securely storing payment tokens through third-party payment processors;
• sending instructions to the payment processor to retry failed charges;
• notifying the Parent of failed payments and upcoming retry attempts;
• reconciling payment results for customer account management.

All retry processing is carried out under the legal basis of contractual necessity and explicit customer consent, as provided through the checkout process and our Terms & Conditions.

The Parent may withdraw consent for future retry attempts at any time through the Parent Area (subject to the cancellation terms applicable to their subscription). Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Payment data is processed in accordance with applicable privacy laws in the Parent's jurisdiction, including UK GDPR, the Data Protection Act 2018, CCPA or equivalent U.S. state laws, UAE PDPL, and the Australian Privacy Principles.

We Make Footballers' Customer Service team may contact Parents regarding failed, pending, or overdue payments for the purpose of assisting with account resolution. Support may include sending payment links, explaining how to update payment methods, and providing general guidance to help ensure the Parent's account remains up to date. All payments must be completed directly by the Parent. WMF staff will not collect, input, or process payment information on behalf of any Parent.

3.2 Legal Basis for Processing (GDPR Jurisdictions)

We process personal data under one or more of the following lawful bases:

• Contractual necessity: managing bookings, payments, and service delivery.
• Legitimate interests: improving training quality, analytics, service optimisation, fraud prevention.
• Consent: marketing communications, optional recordings, optional cookies, certain types of data sharing.
• Legal obligations: safeguarding, incident reporting, financial and regulatory compliance.

3.3 Medical or Additional Needs Information

Where provided by the Parent, medical or additional needs information is collected and processed to:

• Assess whether our programme is suitable for the child;
• Support safe participation in our sessions;
• Enable coaches to make reasonable adjustments where appropriate;
• Respond to any incidents or emergencies during sessions.

This information is processed under the following legal bases:

• Contractual necessity: to deliver safe and appropriate coaching services;
• Legitimate interests: to ensure the safety of all participants and staff;
• Legal obligation: to comply with health and safety requirements.

Providing this information is optional. However, failure to disclose relevant needs may affect our ability to assess suitability or make appropriate adjustments.

See Section 13 of our Terms and Conditions for details on our Inclusion, Support & Reasonable Adjustments policy.

4. Sharing Your Information

4.1 Service Providers

We use trusted third parties for secure processing:

• Typeform – sign-up forms.
• Active Campaign – email communications.
• MoEngage – booking-related emails.
• Google Analytics – analytics.
• AWS – secure hosting.
• Make – automation.
• GetVero – promotional communications.
• Postmark – transactional emails.
• Twilio – SMS.
• ManyChat – WhatsApp.
• Veo – recording storage & sharing.

4.2 International Transfers

Data may be transferred outside the UK/EU (e.g., USA, UAE, Australia, India, Argentina). Standard safeguards (e.g., Standard Contractual Clauses, encryption) are applied.

Where required, international transfers are governed by Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum (IDTA), along with encryption and access controls.

4.3 Advertising

Our website may feature third-party ads. While we do not share identifiable data, advertisers may use cookies/pixels to personalize ads.

5. Photography, Filming and Image Use

5.1 Scope

This section applies to all photography, video recording, and image capture of children under 16 years old participating in WMF programs.

This includes weekly training sessions, trial sessions, Fun Flair Festivals, and all other WMF activities.

No photography, filming, or image capture of any child will occur without explicit parental consent obtained at registration.

5.1A VeoCam Recording & Parent Access

Where VeoCam cameras or equivalent automated recording technology are in operation at a WMF venue, sessions at that venue are recorded.

Not all WMF venues operate automated session recording. Parents will be informed at or prior to registration whether session recording is in use at the specific venue where their child is enrolled.

Where session recording is in operation, purposes are:

• (a) Coaching analysis and player development
• (b) Safeguarding and safety monitoring
• (c) Quality control and coach training
• (d) Parent review of their child's progress

Where recording is in operation, footage is uploaded to the secure VeoCam platform.

Parents are granted access to view footage of their own child only.

Parents cannot view footage of other children.

Sharing footage outside the VeoCam platform may breach other parents' privacy rights.

Legal basis: Legitimate interest (GDPR Article 6(1)(f))

Rationale: Where recording is in operation, it is used to:

• Deliver quality coaching through performance analysis
• Ensure child safety through visual documentation
• Provide parents with transparency into their child's development
• Support safeguarding investigations if incidents occur

Data storage:

• Footage stored on VeoCam secure servers where applicable
• Access restricted to authorised coaches, relevant Parents, and WMF administrators
• Retention period: three years from the date of recording
• Parents may download footage of their own child during the retention period

Your rights:

• Parents may object to session recording by emailing [email protected]
• Where WMF cannot reasonably deliver coaching or safeguarding obligations without recording at that venue, continued enrolment may not be possible

Where session recording is not in operation at a venue, this section does not apply to that venue.

Separate from marketing: Session recording footage is for internal coaching and parent access only. No session recording footage will be used for social media or marketing without separate explicit consent as set out in Section 5.2.

5.2 Consent at Registration

Explicit parental consent for photography and filming is obtained through the registration process.

By completing registration, the Parent confirms they have read and understood this Privacy Policy and the Photography Policy contained within the Terms and Conditions.

Consent is collected via the registration system with separate consent selections for:

• (a) Photography and video recording for internal coaching, training, and safeguarding purposes
• (b) Photography and video recording for social media and marketing use
• (c) Photography and video recording for scouting purposes and sharing with professional football clubs

Each consent category requires an active selection by the Parent.

No consent option is pre-selected.

The Parent must provide a response to each consent category to complete registration.

Registration constitutes documented consent for audit and compliance purposes.

5.3 Consent Record

The registration system records the following for each consent selection:

• (a) Parent name and verified email address
• (b) Child name and date of birth
• (c) Consent selection for each category (YES or NO)
• (d) Timestamp of consent
• (e) Program or event registered for

Consent records are retained for the duration of enrolment plus five years.

Consent records are available for regulatory audit upon request.

5.4 Effect of Consent Selections

Where the Parent selects YES to a consent category, WMF may use the child's image for that specified purpose.

Where the Parent selects NO to a consent category, WMF will not use the child's image for that purpose.

Selecting NO to any consent category does not prevent the child from participating in WMF programs.

Selecting NO to social media consent does not affect scouting consent and vice versa.

5.5 Device Policy

All photography and filming at WMF sessions and events must be conducted on WMF-owned or WMF-approved devices only.

Personal mobile phones and personal recording devices are prohibited for capturing images of children during sessions.

This applies to all WMF staff, coaches, and contractors.

Parents and carers may photograph or film their own child only.

Parents and carers must not capture identifiable images of other children without the consent of those children's parents.

5.6 Internal Use

WMF may record sessions for internal purposes including:

• (a) Coach training and quality assurance
• (b) Safeguarding and incident review
• (c) Performance analysis for coaching staff only

Internal use footage is stored securely and is not published externally.

Internal recording requires the Parent to have selected YES to internal use consent at registration.

Where consent was not provided, the child will be excluded from internal recordings where reasonably practicable.

5.7 Social Media and Marketing Use

WMF may use photographs and videos of children for social media and marketing only where the Parent selected YES to social media and marketing consent at registration.

Social media channels include but are not limited to:

• (a) Instagram (@wemakefootballers, @funflairfestivals, and local franchise accounts)
• (b) Facebook
• (c) TikTok
• (d) YouTube
• (e) X (Twitter)

Marketing use includes but is not limited to:

• (a) Website content
• (b) Promotional materials and flyers
• (c) Email campaigns
• (d) Advertisements
• (e) Future marketing campaigns for WMF programs and Fun Flair Festivals

WMF will not:

• (a) Tag or identify any child by name without separate explicit consent
• (b) Share any child's personal information including school, home address, or contact details
• (c) Use images in any context that could harm the child's dignity, privacy, or wellbeing
• (d) Sell or license images to third parties for their commercial use

Where consent was not provided at registration, WMF will make reasonable efforts to exclude the child from photographs and video.

In group or wide-angle shots where exclusion is not possible, WMF will not publish images where the child is identifiable.

5.8 Scouting and Professional Club Sharing

WMF operates scouting programs in partnership with professional football clubs.

WMF uses VeoCam and similar recording technology to capture session and event footage for scouting review.

Footage is shared with professional clubs and scouts only where the Parent selected YES to scouting consent at registration.

Scouting services are available for both regular weekly classes and Fun Flair Festivals.

Where scouting consent was provided at registration:

• (a) Footage may be reviewed by WMF-affiliated scouts
• (b) Footage may be shared with professional club academies
• (c) The child's information may be shared with affiliated scouts and football clubs
• (d) Scouts or clubs may contact parents directly if interested in a player

Where scouting consent was not provided at registration:

• (a) The child's footage will not be shared externally
• (b) The child's footage will not be flagged for scout review
• (c) The child's information will not be shared with scouts or clubs

5.9 Withdrawal of Consent

Parents may withdraw consent for any photography, social media, marketing, or scouting use at any time after registration.

Withdrawal requests must be submitted to [email protected].

Withdrawal requests must include the child's name and the consent category being withdrawn.

Upon receipt of a withdrawal request:

• (a) WMF will update the consent record in the registration system
• (b) WMF will cease using new images of the child for the withdrawn purpose immediately
• (c) WMF will remove existing images from social media channels within 30 days
• (d) WMF will retain images only where required for safeguarding, legal, or regulatory purposes

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Withdrawal of photography consent does not affect the child's ability to participate in WMF programs.

5.10 Updating Consent

Parents may update or withdraw their consent selections at any time by emailing their local WMF franchise with their request, copying [email protected].

Withdrawal and update requests must include the child's name and the specific consent category being changed.

WMF will use reasonable efforts to action consent changes promptly. Consent changes are not guaranteed to be processed instantaneously.

Updated consent applies to future image capture and use only.

Previously published content will be removed upon request within 30 days of confirmation of the withdrawal.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Withdrawal of photography consent does not affect the child's ability to participate in WMF programs.

5.11 No Photo Identification

Parents who select NO to photography consent may request a No Photo identifier for their child at check-in.

The identifier will be communicated to coaches for regular sessions.

WMF staff will make reasonable efforts to exclude identified children from all photography and filming.

Incidental inclusion in wide-angle or group shots may still occur despite reasonable efforts.

5.12 Retention of Images and Footage

Session and event recordings are retained for a maximum of three years.

Social media posts featuring children will be reviewed annually and removed where consent has been withdrawn.

Scouting footage shared with external clubs becomes subject to the receiving club's data retention policies.

WMF is not responsible for footage retention by third-party clubs after sharing.

5.13 Dignity and Privacy Protection

All photography and filming must respect the dignity and privacy of the child.

WMF will not capture or publish images that:

• (a) Depict a child in distress, injury, or embarrassment
• (b) Could be used to identify a child's location, school, or personal circumstances
• (c) Could affect the child's reputation or wellbeing
• (d) Could be misused or taken out of context

WMF reserves the right to reject or remove any image that does not meet these standards.

5.14 Safeguarding Override

Safeguarding concerns override all marketing and promotional considerations.

Where a safeguarding concern is identified:

• (a) WMF will immediately cease publication of relevant images
• (b) WMF will review all images featuring the affected child
• (c) WMF will cooperate with relevant authorities as required

WMF staff must report any concerns about image misuse to the designated safeguarding lead.

5.15 Personal Data in Images

Personal details including the child's name, contact information, school, or address will not be shared alongside images without separate explicit consent.

Name tagging on social media requires separate explicit consent beyond social media photography consent.

WMF will not respond to third-party requests for child identification from published images.

5.16 Verifiable Parental Consent

Parental consent is verified through the registration system which requires:

• (a) Verified parent or guardian email address
• (b) Active selection of each consent option (not pre-checked boxes)
• (c) Timestamp and record of consent maintained for legal compliance

For children under 16 in the United States, verification steps are implemented in compliance with COPPA 2.0.

For United Arab Emirates registrations, additional verification is implemented in compliance with Federal Decree Law No. 26 of 2025.

6. Data Retention

• Personal Data: Retained 5 years after last interaction.
• Medical or Additional Needs Data: Retained for the duration of enrolment plus 5 years (to meet safeguarding and legal obligations).
• Session Recordings: Retained 3 years unless renewed consent is given.
• Marketing Data: Retained until opt-out.

Retention periods reflect safeguarding requirements, legal obligations, and our legitimate interests in maintaining accurate training and service records.

7. Your Rights

You may:

• Access, correct, or delete your data.
• Withdraw consent for marketing or recordings.
• Request portability (where legally applicable).
• Lodge complaints with your local data authority (see supplements below).

To exercise your rights, please contact us at [email protected].

8. Cookies and Pixels

We use cookies/pixels to:

• Analyze site performance.
• Personalize experiences.
• Track marketing engagement.

You can manage cookies via browser settings.

9. Data Security

We use strict measures including:

• Encryption in transit/storage.
• AWS secure hosting.
• Limited, authorized access.

10. Complaints

If you have a concern, contact [email protected]. We aim to respond within 30 working days.

Jurisdiction-Specific Supplements

United States 🇺🇸

• Law: COPPA 2.0 (Children's Online Privacy Protection Act as amended) applies to children under 16; California Consumer Privacy Act (CCPA) and equivalent state privacy laws apply.
• Children's Data: Parental consent required for all children under 16; verifiable parental consent mechanism required.
• Photography: Explicit parental consent required before image capture; data minimization principles apply.
• Rights: Access, deletion, correction; right to opt-out of sale/sharing.
• Complaints: Federal Trade Commission (FTC) or state Attorney General.

United Kingdom 🇬🇧

• Law: UK GDPR and Data Protection Act 2018; Online Safety Act applies to identifiable children.
• Children's Data: Parental consent required for children under 13; explicit consent required for photography of all children under 16.
• Photography: Company-owned devices only for staff photography; FA safeguarding standards apply.
• Rights: Access, rectification, restriction, deletion, portability.
• Complaints: Information Commissioner's Office (ICO).

United Arab Emirates 🇦🇪

• Law: Federal Decree Law No. 26 of 2025 (Personal Data Protection Law); Federal Data Protection Law No. 45 of 2021 (PDPL); Wadeema's Law (child protection).
• Children's Data: Extra protection required; explicit and verifiable parental consent mandatory.
• Photography: Sharenting restrictions apply to organizational image use; all image use must not affect the dignity or privacy of the child.
• Safeguarding: Staff must escalate concerns to UAE authorities.
• Rights: Correction or deletion under PDPL.
• Complaints: UAE Data Office.

Australia 🇦🇺

• Law: Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs).
• Children's Data: Treated as sensitive information; parental consent required for all children under 16.
• Photography: Consent obtained at registration constitutes written consent for commercial image use; purpose disclosure mandatory.
• Safeguarding: State child protection laws apply.
• Rights: Access, correction, complaint.
• Complaints: Office of the Australian Information Commissioner (OAIC).