Legal
Privacy Policy
Life & Sports Academy coaches children. That means most of the personal data we hold belongs to someone who cannot consent for themselves, and it is the reason this policy is specific rather than general: it names the data we actually collect, why we hold it, how long we keep it, and what you can tell us to do with it.
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- Last updated
On this page16 sections
- 01Who we are
- 02What this policy covers
- 03The personal data we collect
- 04Where the data comes from
- 05Why we process it, and our lawful basis
- 06Children's data and guardian consent
- 07Photography, video and match footage
- 08Who we share data with
- 09Transfers outside Kenya
- 10How long we keep it
- 11Your rights under the Data Protection Act, 2019
- 12How to exercise your rights
- 13How we protect your data
- 14Cookies
- 15Changes to this policy
- 16Contact us, and how to complain
Who we are
Life & Sports Academy ("LSA", "the academy", "we", "us") is a youth football academy based in Lang'ata, Nairobi, Kenya. We are the data controller for the personal data described in this policy, which means we decide why and how it is used.
- Registered entity
- To be confirmed: registered legal name and registration number
- Registered address
- To be confirmed: registered postal address
- Training base
- Lang'ata, Nairobi, Kenya
- Data protection contact
- To be confirmed: name of the data protection contact — academy@lifeandsports.co.ke
- ODPC registration
- To be confirmed: ODPC data controller registration number
This policy is written to the Data Protection Act, 2019 (Kenya) and the Data Protection (General) Regulations, 2021, and is read together with our Cookie Policy and our Child Safeguarding and Player Welfare Policy.
What this policy covers
It covers the personal data we handle through this website, through enquiries and trials, and through running squads, sessions and fixtures. It applies whether you are a player, a parent or guardian, a coach, a volunteer, a partner organisation, or someone who simply sent us a message.
It does not cover websites we link to. A link to a partner, a federation or a social platform is not an endorsement of how that organisation handles your data, and once you leave this site you are on their terms, not ours.
The personal data we collect
We ask for the least we can and still do the job. Nothing on this website requires an account, and none of the forms below are pre-filled or tracked across pages.
- Trial enquiries
- The player's name and age group, the guardian's name, an email address, and — only if you choose to give them — a phone number, the player's school, and anything you write in the message box.
- Contact messages
- Your name, your email address, and optionally a phone number and a subject line, together with the message itself.
- Newsletter sign-ups
- An email address, and a note of which page you signed up from. Nothing else — not a name, not an interest profile.
- Partnership enquiries
- The organisation's name, a contact name, an email address, and optionally a phone number, a country, the kinds of partnership you are interested in, and your message.
- Registered players
- Once a player joins a squad we hold registration details needed to run football: name, date of birth, age group, position and squad number, guardian contact details, relevant medical and emergency information, attendance, and — where consent has been given — photographs and match footage.
- Technical data
- Our hosting and database providers keep server logs, which include IP addresses, for security and for diagnosing faults. We do not use them to build a picture of you.
Where the data comes from
- Directly from you, when you fill in a form on this site, call us, email us, or speak to a coach.
- From a parent or guardian, on behalf of a player under 18.
- From a school or community partner that refers a player to us, with the guardian's knowledge.
- From leagues, federations and competition organisers, in the course of registering squads and submitting team sheets.
Why we process it, and our lawful basis
Every use of personal data has to rest on one of the lawful bases in section 30 of the Data Protection Act, 2019. Ours are set out below.
What we do Why Lawful basis Respond to a trial enquiry and arrange a session You have asked us to. We cannot invite a player to a trial without knowing who they are and how to reach you. Consent, and steps taken at your request before entering into an agreement Answer a contact message You wrote to us and expect a reply. Consent, and legitimate interests in running the academy Register a player and run squads, sessions and fixtures Delivering the coaching the player has joined for, and meeting league and federation registration rules. Performance of an agreement, and legitimate interests Hold medical and emergency contact information Keeping a child safe during training and matches, and being able to act quickly if they are hurt. Explicit consent, and protection of vital interests Safeguard children and respond to welfare concerns Our duty of care, and our obligations under the Children's Act, 2022. Legal obligation, and protection of vital interests Publish photographs and match footage Reporting on what the academy does and celebrating the players in it. Consent, given in writing by a guardian and withdrawable at any time Send the newsletter You asked to hear from us. Consent, withdrawable in one click from any newsletter we send Follow up a partnership enquiry Discussing a partnership you approached us about. Legitimate interests, and steps taken before entering into a contract Keep the site and our records secure Preventing abuse of our forms, and diagnosing faults. Legitimate interests Keep financial and governance records Accounting, audit and reporting obligations. Legal obligation Children's data and guardian consent
Most of our players are under 18. Section 33 of the Data Protection Act, 2019 requires the consent of a parent or guardian before a child's personal data is processed, and requires that the processing is in the best interests of the child. We treat both as hard conditions rather than as paperwork.
- A trial enquiry must be made by a parent or guardian. The form asks for the guardian's name and contact details for exactly that reason, and a coach confirms the relationship in person before a player trains.
- Consent for registration, medical information and photography is taken in writing, on paper, at the point a player joins a squad. It is not bundled: a guardian can consent to a player joining and decline photography, and the player's place is unaffected.
- Consent can be withdrawn at any time by telling any member of staff, or by writing to the address in section 16. Withdrawal is not retrospective — it stops future use, and we will remove published material where we still control it.
- We do not knowingly collect personal data from a child directly through this website. If you believe a child has sent us data without a guardian's knowledge, tell us and we will delete it.
Photography, video and match footage
Photographs of children are personal data, and on a public website they are personal data anyone can see. We handle them on these terms:
- No image of a player is published without written guardian consent recorded against that player.
- Players are photographed in kit, taking part. We do not publish images taken in changing rooms, at medical treatment, or anywhere a child would reasonably expect privacy.
- We do not publish a player's full name alongside their photograph unless a guardian has specifically agreed to it, and we never publish a child's contact details, school address or home area with an image.
- Consent lapses when a player leaves the academy. We stop using their images in new material from that point, and remove existing material on request.
- Press, scouts and partner organisations photographing at our sessions do so under our safeguarding policy, and are told which players may not be photographed.
Transfers outside Kenya
Some of the services we rely on to run this website store data on servers outside Kenya. Where that happens, section 48 of the Data Protection Act, 2019 requires us to be satisfied that the data will have appropriate safeguards. We rely on the provider's contractual commitments, including standard data protection clauses, and we transfer no more than the service needs to work.
You can ask us which providers we currently use and where they store data, and we will tell you.
How long we keep it
We keep personal data for as long as we have a reason to, and then we delete it. "As long as we might one day want it" is not a reason.
What How long Then Trial enquiries that did not lead to a place 12 months from the enquiry Deleted Contact messages 24 months from the last exchange Deleted Newsletter subscriptions Until you unsubscribe The address is marked unsubscribed and removed from the sending list Registered player records While the player is at the academy, and for 3 years after they leave Deleted, other than a minimal record of squads and seasons Medical and emergency information While the player is at the academy, and for 3 years after they leave Deleted Safeguarding records and concerns Retained beyond the periods above where a duty of care or a legal obligation requires it Reviewed and destroyed once that duty ends Photographs and footage published with consent Until consent is withdrawn or the player leaves Removed from material we control Financial and governance records As required by Kenyan tax and companies legislation Destroyed at the end of the statutory period Partnership enquiries 24 months, or the life of the partnership plus 6 years Deleted Your rights under the Data Protection Act, 2019
Section 26 of the Act gives you the following rights over your own personal data. Where the data belongs to a child, a parent or guardian exercises them on the child's behalf.
- To be informed
- To know how your data is being used — which is what this document is for.
- Of access
- To be given a copy of the personal data we hold about you.
- To correction
- To have inaccurate or incomplete data put right, without delay.
- To deletion
- To have data deleted where we no longer have a reason to hold it, or where it was collected unlawfully.
- To object
- To object to processing we carry out on the basis of legitimate interests, including any use for direct marketing.
- To restrict
- To have us pause processing while a dispute about accuracy or lawfulness is resolved.
- To portability
- To receive data you gave us in a structured, commonly used and machine-readable format.
- To withdraw consent
- Where we rely on consent, to withdraw it at any time, as easily as it was given.
How to exercise your rights
Write to academy@lifeandsports.co.ke, or call +254 722 416 173, and tell us which right you want to exercise. You do not need to use any particular form of words, and you do not need to give a reason.
- We will acknowledge your request and, where we need to, ask you for enough information to be sure who you are — we are not going to hand a child's records to someone who cannot show they are that child's guardian.
- We will respond within 30 days. If a request is complex we may extend that, and we will tell you why before the 30 days are up.
- We do not charge for this. If a request is manifestly unfounded or repetitive we may charge a reasonable fee or decline it, and we will explain our reasoning in writing.
How we protect your data
- This website is served over HTTPS, so what you type into a form is encrypted in transit.
- Our database enforces access rules at the row level, so a member of staff can only reach the records their role allows — the restriction is in the database itself, not merely in the screens above it.
- Enquiry forms write to the database and are not emailed around in plain text.
- Access to player records is limited to coaching and administrative staff who need them, and is removed when someone leaves.
- Paper records, including consent forms, are held securely at the academy.
- No system is perfect. If a breach occurs that presents a real risk of harm, we will notify the Office of the Data Protection Commissioner within 72 hours as section 43 of the Act requires, and tell the people affected.
Changes to this policy
We update this policy when what we do changes. The date at the top of the page always reflects the current version, and where a change materially affects how we use your data we will say so directly — to registered families by email, and on this site.
Contact us, and how to complain
Questions about this policy, or about anything we hold, go to our data protection contact:
- Data protection contact
- To be confirmed: name of the data protection contact
- academy@lifeandsports.co.ke
- Phone
- +254 722 416 173
- Post
- To be confirmed: registered postal address
If you are not satisfied with how we have handled a request or a complaint, you have the right to complain to the Office of the Data Protection Commissioner, which regulates data protection in Kenya. You can reach the ODPC at odpc.go.ke, and you do not have to come to us first.
The rest of the set
- Terms of UseThe terms governing use of the Life & Sports Academy website, including enquiries, content and liability.
- Cookie PolicyThe cookies lifeandsports.co.ke sets, what each one does, and how long it lasts. No advertising, no third-party analytics.
- SafeguardingLife & Sports Academy's child safeguarding and player welfare policy: codes of conduct, reporting a concern, and who is responsible.
Something here unclear, or something you want us to change about what we hold? Write to academy@lifeandsports.co.ke or call +254 722 416 173.
