PRIVACY POLICY

Last updated: 1 September 2026

1. General Information

1.1. This Privacy Policy explains how personal data is collected, used, disclosed, stored and otherwise processed in connection with the website https://torneox.com, the Torneox mobile application and the related digital services and functionality (collectively, the “Platform”).

1.2. The Platform is operated by UpperCX LLC, registration No. 30-1341599, legal address: 30 North Gould Street, Sheridan, Wyoming, 82801, United States (“Torneox”).

1.3. For the principal processing activities relating to User accounts, player profiles, Torneox licences, rankings, federation administration and operation of the Platform, Torneox acts as the data controller within the meaning of Regulation (EU) 2016/679 (“GDPR”).

1.4. The software and technical infrastructure underlying the Platform are provided and maintained by SIA Vertexo, registration No. 40203073672, legal address: Rīgas iela 47–2, Jūrmala, LV-2015, Latvia, operating under the Tournated brand (“Vertexo” or the “Technology Provider”).

1.5. When processing personal data on behalf of Torneox for the provision, hosting, maintenance and technical operation of the Platform, Vertexo acts as a data processor in accordance with Torneox's documented instructions and applicable data protection law.

1.6. In limited circumstances, Vertexo may process certain personal data as an independent controller where such processing is necessary for its own legal obligations, establishment, exercise or defence of legal claims, or protection of the security and integrity of its systems. Where Vertexo acts as an independent controller, it is responsible for the relevant processing in accordance with applicable law.

1.7. This Privacy Policy applies to Users of the Platform, including players, licence holders, tournament participants and persons acting on behalf of minors.

2. Personal Data We Process

Depending on how the Platform is used, Torneox may process the following categories of personal data.

2.1. Account and Profile Data

When a User creates or maintains an account, the Platform may collect:

first name;
last name;
email address;
date of birth;
gender;
telephone number;
country;
account identifiers;
login and authentication information;
profile information;
profile photograph, where provided; and
other information voluntarily added to the User's profile.

These data are used to create and administer the User's account, identify the User and provide Platform functionality.

2.2. Torneox Licence Data

When a User applies for, receives, renews or manages an Torneox licence, Torneox may process information contained in the User's profile together with information relevant to the licence, including, where applicable:

licence number and status;
licence validity information;
club affiliation;
coach information;
eligibility information; and
information concerning the issuance, renewal or administration of the licence.

Torneox is responsible for issuing and administering Torneox licences.

2.3. Tournament and Competition Data

When a User registers for or participates in a tournament or competition through the Platform, personal data may include:

identity and profile information;
contact information;
date of birth;
gender;
country;
club and coach information;
Torneox licence information;
ranking information;
selected tournament, category or competition;
registration status;
partner or team information;
draws;
schedules;
match information;
scores and results;
withdrawals, disqualifications or other tournament status information; and
other information reasonably necessary for the organization and administration of the relevant tournament.

2.4. Rankings, Results and Sporting Records

Torneox may process sporting information necessary for the administration and historical record of padel competitions, including:

tournament participation;
rankings;
rating or ranking points;
match history;
scores;
results;
categories;
sporting statistics; and
licence and competition status.

Certain sporting information may be made publicly available through the Platform where necessary for the operation of rankings, publication of tournament results and administration and promotion of official padel competitions.

2.5. Payment and Transaction Information

Payments made through the Platform may be processed by an independent payment service provider.

The payment service provider processes payment credentials, including payment card information, in accordance with its own legal and security requirements.

Torneox, Tournament Organizers and Vertexo do not receive or store the User's complete payment card details.

Torneox, Vertexo and/or the relevant Tournament Organizer may receive limited transaction information necessary to identify and administer a payment, such as:

payment status;
transaction identifier;
amount;
currency;
date and time of payment;
refund status; and
information identifying the Service or registration to which the payment relates.

2.6. Communications

If a User contacts Torneox, a Tournament Organizer or Platform support, the following data may be processed:

name;
contact details;
content of the communication;
information relating to the User's account, licence or tournament registration; and
information reasonably necessary to respond to the request.

2.7. Technical and Usage Data

When a User accesses or uses the Platform, certain technical information may be processed, including:

IP address;
device and browser information;
operating system;
session and authentication information;
date and time of access;
technical logs;
error and diagnostic information;
security events; and
information concerning interaction with the Platform.

Such information may be processed to operate, secure, maintain and improve the technical functionality of the Platform.

Information concerning cookies and similar technologies is provided separately in the Platform's Cookie Policy.

3. Purposes and Legal Bases for Processing

Personal data are processed only where there is an appropriate legal basis under applicable data protection law.

3.1. Providing the Platform and User Account

Personal data may be processed to:

create and administer User accounts;
authenticate Users;
provide Platform functionality;
maintain User profiles;
provide requested Services; and
communicate with Users regarding their accounts.

The legal basis is generally the performance of a contract or taking steps at the User's request before entering into a contract.

3.2. Torneox Licences and Federation Administration

Torneox may process personal data to:

issue and administer Torneox licences;
verify eligibility;
administer federation activities;
maintain official player information;
administer rankings and sporting records; and
enforce applicable Torneox regulations.

Depending on the relevant activity, the legal basis may be performance of a contract, compliance with a legal obligation and/or Torneox's legitimate interests in administering padel activities and federation functions.

3.3. Tournament Registration and Participation

Personal data may be processed to:

register Users for tournaments;
verify eligibility and licence status;
create categories, draws and schedules;
administer matches and results;
communicate tournament information;
calculate and publish rankings and results; and
otherwise administer competitions.

The legal basis is generally performance of a contract and/or legitimate interests relating to the proper organization and administration of sporting competitions.

3.4. Payments

Personal data may be processed to:

initiate and identify payments;
confirm payment status;
associate payments with licences or tournament registrations;
administer refunds;
maintain accounting records; and
prevent fraudulent transactions.

The legal basis may include performance of a contract, compliance with legal obligations and legitimate interests relating to payment administration and fraud prevention.

3.5. Security and Prevention of Abuse

Torneox and Vertexo may process technical and account information where necessary to:

maintain Platform security;
prevent unauthorized access;
investigate suspected fraud or misuse;
protect Users and the Platform;
identify technical problems; and
establish, exercise or defend legal claims.

The legal basis is the legitimate interests of Torneox and/or Vertexo in maintaining secure and reliable systems and protecting their legal rights.

3.6. Compliance with Legal Obligations

Personal data may be processed where necessary to comply with applicable legal, regulatory, accounting, tax, law enforcement or other mandatory requirements.

The legal basis is compliance with a legal obligation.

4. Tournament Organizers

4.1. Tournaments and competitions available through the Platform may be organized by members of Torneox (“Tournament Organizers”) or, where expressly indicated, by Torneox itself.

4.2. When a User registers for a tournament, the relevant Tournament Organizer may receive access to personal data reasonably necessary to organize and conduct that tournament.

Such information may include:

name and surname;
contact information;
date of birth;
gender;
country;
club and coach information;
licence information;
ranking information;
tournament registration information;
partner or team information; and
other information reasonably necessary for the relevant tournament.

4.3. Tournament Organizers do not receive the User's complete payment card details through the Platform.

4.4. A Tournament Organizer receiving personal data for the purpose of organizing its tournament is responsible for processing such data lawfully, securely and only to the extent necessary for the relevant purpose.

4.5. To the extent that a Tournament Organizer independently determines the purposes and means of processing personal data in connection with its tournament, that Tournament Organizer acts as an independent data controller and is responsible for its own processing activities.

4.6. Users may contact the relevant Tournament Organizer directly regarding processing activities carried out independently by that Tournament Organizer.

5. Children and Minors

5.1. The Platform may be used in connection with accounts, licences and tournament participation of minors.

5.2. Personal data relating to children are processed with particular care and appropriate safeguards.

5.3. Where processing of a child's personal data is based on consent and applicable law requires authorization from a person having parental responsibility or other lawful authority over the child, such consent or authorization must be provided by the child's parent, guardian or other legal representative.

5.4. A coach or another responsible adult may create or manage an account, register a minor for a tournament or otherwise act in relation to the minor only where that person is duly authorized to do so by the minor's parent, guardian or other legal representative or otherwise has lawful authority to act on behalf of the minor.

5.5. Where consent is relied upon for the direct provision of information society services to a child, the applicable age requirements under Latvian and European Union law shall apply.

5.6. Torneox may take reasonable measures to verify the authority of a person acting on behalf of a minor where appropriate.

5.7. Where appropriate, information relating to processing of children's personal data shall be provided in clear and understandable language taking into account the age and maturity of the child.

6. Marketing and Newsletters

6.1. Torneox may send Users information concerning Torneox activities, tournaments, events, offers, news and other promotional communications where permitted by applicable law.

6.2. Where consent is required, marketing communications shall be sent only after the User has provided the necessary consent.

6.3. Consent to receive marketing communications is voluntary and is not a condition for creating a Platform account, obtaining an Torneox licence or registering for a tournament unless the relevant communication is necessary for providing the requested Service.

6.4. Users may withdraw their consent or unsubscribe from marketing communications at any time by:

using the unsubscribe functionality included in the relevant communication; or
contacting Torneox at soccerlife@torneox.com.

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

6.6. Service communications necessary for administration of an account, licence, tournament registration, payment or another requested Service are not marketing communications and may continue to be sent where necessary.

7. Disclosure and Recipients of Personal Data

Personal data may be disclosed, where necessary and lawful, to the following categories of recipients:

Torneox personnel and authorized representatives;
relevant Tournament Organizers;
Vertexo as the Technology Provider;
hosting and cloud infrastructure providers;
payment service providers;
email and communications service providers;
IT, security and technical service providers;
professional advisers, auditors and service providers;
public authorities, courts, law enforcement authorities or regulators where disclosure is required by law; and
other recipients where the User has authorized disclosure or where another lawful basis applies.

Recipients receive access only to personal data reasonably necessary for the relevant purpose.

8. Vertexo as Technology Provider

8.1. Vertexo provides the software and technical infrastructure used for operation of the Platform.

8.2. Where Vertexo processes personal data on behalf of Torneox, such processing may include:

hosting and storage;
database management;
account and authentication functionality;
technical operation of registrations and licences;
technical payment integrations;
backups and recovery;
technical support;
maintenance;
security monitoring; and
troubleshooting.

8.3. Vertexo processes such data in accordance with Torneox 's documented instructions, the applicable data processing arrangements and applicable data protection law.

8.4. Vertexo may engage subprocessors where necessary to provide technical services, subject to applicable GDPR requirements concerning processors and subprocessors.

9. International Data Transfers

9.1. Torneox and Vertexo seek to use service providers and processing arrangements that provide an appropriate level of protection for personal data.

9.2. Where personal data are transferred outside the European Economic Area (“EEA”) to a country that has not been recognized as providing an adequate level of data protection, appropriate safeguards shall be used where required by applicable law.

Such safeguards may include:

European Commission Standard Contractual Clauses;
an applicable adequacy decision;
other transfer mechanisms permitted under the GDPR; or
another lawful basis for the relevant transfer.

9.3. Information regarding applicable safeguards may be requested from Torneox.

10. Data Retention

10.1. Personal data are retained only for as long as reasonably necessary for the purposes for which they were collected and to satisfy applicable legal, regulatory, accounting and legitimate operational requirements.

10.2. The applicable retention period depends on the nature of the data and the purpose of processing.

Relevant criteria may include:

whether the User maintains an active account;
whether the User holds an active or historical Torneox licence;
the need to maintain official tournament results, rankings and sporting records;
applicable accounting and tax retention requirements;
limitation periods for potential legal claims;
security and fraud prevention requirements; and
applicable statutory obligations.

10.3. Certain tournament results, rankings and historical sporting records may be retained for an extended period where necessary to preserve the legitimate historical and sporting record of Torneox competitions.

10.4. Where personal data are no longer required, they shall be deleted, anonymized or otherwise processed in accordance with applicable law.

11. Publicly Available Information

11.1. Certain information relating to sporting activities may be publicly displayed through the Platform.

Depending on the relevant competition and functionality, this may include:

player's first and last name;
country;
club;
licence status;
ranking;
tournament participation;
category;
draw;
match schedule;
match results;
ranking points; and
sporting statistics.

11.2. Such publication may be necessary for transparent administration of sporting competitions, rankings and official sporting records.

11.3. Torneox shall seek to ensure that information made publicly available is limited to what is reasonably necessary for the relevant sporting and federation purposes.

11.4. Contact information, complete date of birth and payment information shall not be made publicly available through the Platform unless there is a separate lawful basis for doing so.

12. Photographs and Audiovisual Materials

12.1. Photographs, video recordings and other audiovisual materials may be created during tournaments and other sporting events by Torneox, Tournament Organizers or persons authorized by them.

12.2. The controller responsible for such recording shall ensure that the processing has an appropriate legal basis and that required information is provided to participants.

12.3. The specific legal basis and conditions may depend on the nature of the event, the context of the recording and the intended use of the material.

12.4. Registration for or participation in a tournament through the Platform does not by itself constitute consent for Vertexo to use a participant's image for Vertexo's own advertising or commercial purposes.

13. Automated Decision-Making

13.1. The Platform may use automated calculations to support sporting functionality, including calculation of rankings, points, standings, draws or other competition-related information based on applicable sporting rules and input data.

13.2. Torneox does not use solely automated decision-making producing legal or similarly significant effects on Users within the meaning of Article 22 GDPR unless Users are specifically informed otherwise where required by law.

14. Security

14.1. Torneox and Vertexo implement appropriate technical and organizational measures designed to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction, alteration or disclosure.

14.2. Such measures may include, as appropriate:

access controls;
authentication mechanisms;
encryption;
logging and monitoring;
backups;
infrastructure security;
restriction of access based on roles and responsibilities; and
procedures for responding to security incidents.

14.3. No electronic system can be guaranteed to be completely secure. Users are also responsible for maintaining the confidentiality of their account credentials.

15. User Rights

Subject to the conditions and limitations established by applicable data protection law, Users may have the right to:

obtain confirmation as to whether their personal data are being processed;
access their personal data;
request correction of inaccurate or incomplete personal data;
request deletion of personal data;
request restriction of processing;
object to processing based on legitimate interests;
receive certain personal data in a structured, commonly used and machine-readable format;
request transmission of such data to another controller where applicable;
withdraw consent at any time where processing is based on consent; and
exercise rights relating to certain automated decision-making where applicable.

These rights are not absolute and may be subject to exceptions provided by law.

16. How to Exercise Your Rights

16.1. Requests concerning personal data for which Torneox acts as controller should be sent to:

soccerlife@torneox.com

or by post to:

UpperCX LLC
address 30 North Gould Street, Sheridan, Wyoming, 82801, United States

16.2. Torneox may request information reasonably necessary to verify the identity of the person making the request and to protect personal data against unauthorized disclosure.

16.3. Vertexo may assist Torneox technically in responding to data subject requests where the relevant information is processed through the Platform.

16.4. Where a request concerns processing independently carried out by a Tournament Organizer, the User may be directed to the relevant Tournament Organizer.

16.5. Requests shall be handled within the time limits required by applicable data protection law.

17. Complaints

17.1. Users are encouraged to contact Torneox first if they have questions or concerns regarding the processing of their personal data.

17.2. Users also have the right to lodge a complaint with the competent data protection supervisory authority.

In Latvia, the supervisory authority is:

Datu valsts inspekcija
(Data State Inspectorate of Latvia)

The current contact details of the supervisory authority are available on its official website.

17.3. The right to lodge a complaint does not affect any other administrative or judicial remedy available under applicable law.

18. Cookies and Similar Technologies

18.1. The Platform may use cookies and similar technologies necessary for authentication, security, functionality and other purposes.

18.2. Cookies or similar technologies that are not strictly necessary shall be used only in accordance with applicable consent requirements.

18.3. Detailed information regarding cookies, their purposes, providers and duration is provided in the Platform's Cookie Policy.

18.4. Where required, Users may manage their cookie preferences through the cookie consent functionality made available on the Platform.

19. Changes to this Privacy Policy

19.1. Torneox may update this Privacy Policy where necessary to reflect changes in:

applicable law;
processing activities;
Platform functionality;
organizational arrangements;
technologies; or
service providers.

19.2. The current version shall be published on the Platform together with the date of the latest update.

19.3. Where changes materially affect Users or their rights, additional notice shall be provided where required by applicable law.

20. Contact Information

For questions concerning this Privacy Policy or the processing of personal data by Torneox:

UpperCX LLC
Registration No.: 30-1341599
Legal address: 30 North Gould Street, Sheridan, Wyoming, 82801, United States
Email: soccerlife@torneox.com

For technical issues concerning operation of the Platform:

SIA Vertexo / Tournated
Registration No.: 40203073672
Legal address: Rīgas iela 47–2, Jūrmala, LV-2015, Latvia
Email:hello@tournated.com