PRIVACY
POLICY.

ONNEEDLE Manufacturing (Pty) Ltd respects the privacy of STRIDE users and is committed to processing personal information responsibly, securely and transparently.

This Privacy Policy explains what information STRIDE may collect, why it is collected, how it is used and protected, when it may be shared, how long it may be retained, and the rights available to users regarding their personal information.

For purposes of South Africa's Protection of Personal Information Act 4 of 2013 (POPIA), ONNEEDLE Manufacturing (Pty) Ltd acts as the responsible party for personal information processed through STRIDE where it determines the purpose and means of processing.

The information STRIDE collects depends on the services and features a user chooses to use.

Account and identity information may include:

• full name;
• email address;
• mobile or contact number;
• username or account identifier;
• password or authentication information;
• date of birth or age information where required;
• profile photograph; and
• organisation, club, federation or team affiliation.

Athlete and sports information may include:

• athlete profile and registration information;
• team or club membership;
• match participation, fixtures and results;
• performance statistics and sporting achievements;
• rankings, training or participation records; and
• digital player passport information.

Where applicable, STRIDE may also process health, fitness, injury, rehabilitation, transaction, device and technical information required for a relevant service or feature.

STRIDE may request access to device functions only where they are required for a user-facing feature.

• camera or photo access for profile or sporting content;
• file or media access where a user chooses to upload content;
• location where a location-dependent STRIDE feature requires it; and
• notifications for fixtures, events, platform activity or relevant updates.

STRIDE seeks to minimise access to personal and sensitive information and should not request device permissions that are not necessary for the relevant feature.

STRIDE may use personal information to:

• create and manage user accounts;
• authenticate users and protect accounts;
• create athlete and participant profiles;
• manage digital player passports;
• administer clubs, federations, teams and competitions;
• publish or manage fixtures, results and standings;
• record sporting participation and performance;
• support sports administration and governance;
• enable event-related functionality;
• facilitate communication between authorised ecosystem participants;
• provide commerce or payment-related functionality;
• improve STRIDE features and user experience;
• provide customer and technical support;
• prevent fraud, misuse and security incidents; and
• comply with legal, regulatory or contractual obligations.

Where POPIA applies, STRIDE processes personal information only where there is a lawful justification. Depending on the circumstances, this may include user consent, performance of an agreement, compliance with a legal obligation, protection of a legitimate interest, or another lawful basis recognised under applicable data-protection law.

Where consent is relied upon, a user may withdraw that consent where the law permits.

STRIDE does not sell users' personal information.

Information may be shared only where reasonably necessary for STRIDE services, legal obligations or authorised sporting activities.

• clubs, teams and federations;
• event organisers and authorised administrators;
• coaches and authorised health professionals;
• service, hosting and cloud-infrastructure providers;
• payment-service providers;
• communication, analytics, security or technical-service providers; and
• regulators or authorities where legally required.

Access should be restricted according to the user's role and the purpose for which the information is required.

Some STRIDE features are designed to make legitimate sporting information visible within an event, league, club or broader sporting environment.

This may include athlete or player name, team, squad information, fixtures, competition participation, match statistics, results, standings or sporting achievements.

Sensitive personal information should not be made publicly available merely because a user participates in sport.

STRIDE may operate in sporting environments that include children and young athletes. Where personal information relating to a child is processed, STRIDE will seek to comply with applicable legal requirements governing children's personal information.

Where required, processing may depend on consent or authorisation from a parent, guardian or other legally competent person.

STRIDE seeks to limit the personal information collected about children to information reasonably necessary for legitimate sporting, administrative, safety or platform purposes.

ONNEEDLE takes reasonable technical and organisational measures designed to protect personal information against loss, unauthorised access, unlawful processing, alteration, misuse, disclosure and destruction.

• access controls and authentication;
• role-based permissions;
• secure communications;
• encryption where appropriate;
• logging and monitoring;
• secured infrastructure and backups; and
• restricted administrative access.

No internet-connected service can guarantee absolute security. Users are also responsible for protecting their passwords and account credentials.

STRIDE retains personal information only for as long as reasonably necessary for the purpose for which it was collected, provision of STRIDE services, legitimate sporting or organisational records, contractual requirements, dispute resolution, security, fraud prevention, or legal and regulatory obligations.

Information that is no longer required will be deleted, de-identified or securely archived where appropriate. Some information may remain temporarily in secure backup systems after deletion from active systems until the relevant backup cycle expires.

Users may request deletion of their STRIDE account and associated personal information.

Requests may be submitted to stride@onneedle.co.za from the email address associated with the STRIDE account.

Subject to applicable law, users may have the right to:

• request confirmation of whether their personal information is being processed;
• request access to personal information;
• request correction or updating of inaccurate information;
• request deletion of information where permitted;
• object to certain processing;
• withdraw consent where processing relies on consent; and
• lodge a complaint with the appropriate data-protection authority.

Some service providers supporting STRIDE may operate infrastructure outside South Africa. Where personal information is transferred across national borders, ONNEEDLE will seek to ensure that the transfer is permitted under applicable data-protection law and that appropriate safeguards are applied.

STRIDE may use third-party technology or services to support hosting, authentication, notifications, payments, analytics, crash reporting, security or other platform functionality.

These providers may process limited information as necessary to provide their services. Where STRIDE integrates with external services, those services may also have their own privacy policies.

Information declared in STRIDE's Google Play Data Safety section should accurately reflect the actual data collected, shared and processed by the version of STRIDE distributed through Google Play.

ONNEEDLE will seek to review these disclosures when STRIDE functionality, permissions, SDKs or data practices change.

This Privacy Policy may be updated from time to time to reflect changes to STRIDE, data-processing activities, legal or regulatory requirements, service providers, or Google Play requirements.

The latest version will be published on this page with an updated effective or revision date.

STRIDE Privacy / Support

ONNEEDLE Manufacturing (Pty) Ltd
2347 Molalakgori Str
Mahwelereng-A
Mokopane, 0626
Limpopo
South Africa

Email: stride@onneedle.co.za
Tel.: +27 62 694 6012