Privacy Policy
Last updated: September 15, 2026
This Privacy Policy governs the processing of personal data of all users of the YouSponsor platform, including Talents under the age of 18 (“Minor Talents”) and their respective parents or persons exercising parental responsibility. The provisions relating to Minor Talents (Section 6) supplement and, to the extent applicable, take precedence over the general provisions applicable to other users.
1. Introduction
Welcome to YouSponsor. We are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose and protect information when you visit our website and use our services, in compliance with Regulation (EU) 2016/679 (“GDPR”) and Legislative Decree No. 196/2003, as amended by Legislative Decree No. 101/2018 (“Italian Privacy Code”).
The Platform enables individuals (“Talents”) — including athletes, artists and creators under the age of 18 — to be presented to third parties (“Sponsors”) interested in providing financial support for their activities. The presence of Minor Talents requires the Data Controller to adopt enhanced safeguards, as described in Section 6.
2. Data Controller
The Data Controller is ALA SOFTWARE S.R.O., represented by its legal representative pro tempore, Mr. Luca Buriani, with registered office at Krajná 17137/7C, 821 04 Bratislava-Ružinov – Slovak Republic, Identification Number: 56 823 291 (“YouSponsor” or the “Data Controller”).
Email: info@yousponsor.io
3. Definitions
- Talent: the individual presented on the Platform as a person eligible for sponsorship (athlete, artist, creator or similar).
- Minor Talent: a Talent who has not yet reached the age of 18.
- Parent: the person exercising parental responsibility or legal guardianship over the Minor Talent.
- Sponsor: the user who financially supports a Talent through the Platform.
- Brand Sponsor: the company that promotes its brand through the YouSponsor Platform and the selected Talent or Talents.
- User: any person registered on the Platform, whether a Talent or Sponsor.
4. Categories of Personal Data Processed
4.1 Data Common to All Users
- Identification data: first name, last name, username, profile image.
- Contact data: email address, billing address.
- Payment data: billing details and transaction history on the Platform.
- Technical data: IP address, browser type, time zone, operating system.
4.2 Data Specific to Minor Talents
In addition to the data referred to in Section 4.1, with regard to Minor Talents, the Platform collects and processes, in compliance with the principle of data minimisation and only to the extent necessary to present the Talent to Sponsors:
- identification data of the Minor Talent (first name, last name, date of birth, nationality);
- images, videos and multimedia content relating to the Minor Talent's sporting, artistic or creative activities;
- data relating to results, performances and achievements, where published on the Platform;
- identification and contact details of the Parent, necessary for account management and the collection of consent;
- documentation evidencing the exercise of parental responsibility or legal guardianship, where required for the purpose of verifying consent.
5. Purposes and Legal Bases for Processing
| Purpose | Legal Basis |
|---|---|
| Creation and management of the account and profile | Performance of a contract (Art. 6(1)(b) GDPR); for Minor Talents under the age of 14, parental consent pursuant to Art. 8 GDPR and Art. 2-quinquies of the Italian Privacy Code |
| Management of sponsorships and payments | Performance of a contract (Art. 6(1)(b) GDPR) |
| Compliance with legal obligations (AML/KYC, tax obligations) | Legal obligation (Art. 6(1)(c) GDPR) |
| Publication of the profile, images and Talent content | Specific and explicit consent (Art. 6(1)(a) GDPR); for Minor Talents, separate consent from the Parent (Section 6.4) |
| Service, security and fraud-prevention communications | Legitimate interest of the Data Controller / performance of a contract (Arts. 6(1)(b) and 6(1)(f) GDPR) |
| Marketing and newsletters | Freely given, specific, informed and revocable consent (Art. 6(1)(a) GDPR) — never requested from Minor Talents |
6. Processing of Minor Talents' Personal Data
Children merit specific protection with regard to their personal data, as they may be less aware of the risks, consequences and rights relating to the processing of their personal data (Recital 38 GDPR). The Data Controller processes Minor Talents' personal data in accordance with Article 8 GDPR and Article 2-quinquies of the Italian Privacy Code, applying the safeguards described in this Section.
6.1 Age Threshold and Consent
Talents who have reached the age of 14 may validly provide consent to the processing of their personal data for access to Platform services that qualify as “information society services”, pursuant to Article 2-quinquies of the Italian Privacy Code.
For Talents under the age of 14, processing is lawful only where consent is given or authorised by the Parent.
Regardless of the Talent's age, the creation of an account, acceptance of the Terms of Service and execution of sponsorship agreements relating to a Minor Talent require the registration and express consent of the Parent, who acts as the account holder or co-holder until the Talent reaches the age of majority.
6.2 Verification of Age and Parental Consent
The Data Controller adopts reasonable measures, having regard to available technology, to verify the declared age and authenticity of parental consent, including:
- requesting the date of birth during registration;
- requesting an identification document from the Parent and, where necessary, documentation proving the family relationship or legal guardianship;
- implementing a double-confirmation procedure (e.g. a confirmation email sent to the Parent's email address) before activating the Minor Talent's profile;
- reserving the right to suspend the profile in the event of doubt regarding the Talent's actual age or the authenticity of the consent, until verification has been completed.
6.3 Child-Friendly Language
Information concerning the processing of personal data addressed to Minor Talents shall, where possible, be provided in clear, simple, concise and age-appropriate language that can also be understood by a minor, in addition to this complete Privacy Policy intended for the Parent.
6.4 Publication of Images, Videos and Minor Talent Content
- The publication of images, videos, performance data or other content concerning a Minor Talent requires the Parent's explicit, specific and documented consent, separate from and additional to the consent given solely for the registration of the account.
- Such consent may be withdrawn at any time, with effect on the future visibility of the relevant content; withdrawal does not affect the lawfulness of processing carried out prior to such withdrawal.
- Images and content relating to Minor Talents shall not be used for advertising purposes beyond the presentation of the Talent to Sponsors, unless separate and specific consent has been obtained.
6.5 Prohibition of Profiling and Direct Marketing
- The personal data of Minor Talents shall not be used for behavioural profiling, direct marketing or targeted advertising purposes.
- Promotional communications relating to the Platform shall be addressed exclusively to the Parent, subject to the Parent's prior consent.
6.6 Data Retention and Deletion
The personal data of Minor Talents shall be retained for the period strictly necessary for the purposes for which they were collected and, in any event, no longer than 12 months following termination of the relationship with or removal from the Platform, except where longer retention is required by law (e.g. tax or anti-money-laundering regulations).
Upon reaching the age of majority, the Talent shall acquire full and exclusive control over their account and personal data and may, at any time, withdraw consents previously given by the Parent, request the deletion of content published during their minority or request the deactivation of their profile, in accordance with the enhanced right to be forgotten recognised for minors under Recital 65 GDPR.
The Data Controller undertakes to inform the Talent, upon reaching the age of majority, of the possibility of exercising these rights.
6.7 Enhanced Security Measures
The Data Controller adopts enhanced technical and organisational measures to protect the personal data of Minor Talents, including access restrictions to authorised personnel, role-based access controls and, where the processing is likely to result in a high risk within the meaning of Article 35 GDPR, a Data Protection Impact Assessment (DPIA).
6.8 Disclosure to Third Parties
- The personal data of Minor Talents shall not be transferred, sold or disclosed to third parties for their own independent commercial purposes.
- Any disclosure to third-party service providers shall take place only to the extent necessary to provide the relevant services and in accordance with the provisions of Section 8.
7. Data Retention — Other Users
The personal data of Sponsors and adult Talents shall be retained for the duration of the relationship with the Platform and thereafter for the period necessary to comply with legal obligations and, in any event, for no longer than 10 years, unless a different retention period is required by applicable sector-specific regulations (e.g. anti-money-laundering legislation).
8. Recipients and Disclosure of Personal Data to Third Parties
Personal data may be disclosed, strictly to the extent necessary, to:
Such parties shall act either as data processors pursuant to Article 28 GDPR or as independent data controllers, as specified in the relevant agreements.
- payment service providers and credit institutions for the management of transactions;
- identity verification and anti-money-laundering (KYC/AML) service providers;
- hosting, cloud and technology infrastructure service providers;
- the Data Controller's legal, tax and accounting advisers;
- public authorities, where required by law.
9. Transfers of Data to Third Countries
Where the Data Controller uses service providers located outside the European Economic Area, transfers of personal data shall take place on the basis of an adequacy decision adopted by the European Commission or, in the absence thereof, through Standard Contractual Clauses or other appropriate safeguards pursuant to Articles 44 et seq. GDPR.
10. Data Security
The Data Controller adopts appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 GDPR, including encryption of communications, access controls, regular backups and staff training, together with enhanced measures for Minor Talents' data as described in Section 6.7.
11. Data Subject Rights
If you are resident in the European Economic Area, you have the right to:
With regard to Minor Talents, these rights shall be exercised by the Parent until the Talent reaches the age of majority, without prejudice to the direct involvement of the Talent, depending on their age and level of maturity, in the exercise of their rights.
To exercise these rights, please contact:
- Access: obtain a copy of your personal data.
- Rectification: request the correction of inaccurate data.
- Erasure: request the deletion of your personal data (“right to be forgotten”).
- Restriction: request restriction of processing.
- Data portability: request the transfer of your data to another data controller.
- Objection: object to processing based on legitimate interests or to direct marketing purposes.
Email: info@yousponsor.io
12. Right to Lodge a Complaint
Without prejudice to the right to contact the Data Controller, the data subject — or the Parent on behalf of a Minor Talent — has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), at www.garanteprivacy.it, as the competent supervisory authority for Italy, or with the supervisory authority of the Member State of their habitual residence, place of work or place of the alleged infringement.
13. Cookies
The Platform uses technical, analytics and profiling cookies to improve the browsing experience, analyse website traffic and provide personalised content.
Detailed information regarding the categories, purposes and retention periods of the cookies used, as well as the procedures for managing or withdrawing consent, is contained in the Cookie Policy available in the relevant section of the website.
Profiling or marketing cookies are not activated on profiles identified as belonging to Minor Talents.
14. Changes to this Privacy Policy
The Data Controller reserves the right to amend this Privacy Policy at any time.
Material changes, particularly those relating to the processing of Minor Talents' personal data, shall be communicated to the relevant Users and, in the case of Minor Talents, to their respective Parents, with reasonable prior notice and, where necessary, a request for renewed consent.
15. Contact
For any request relating to this Privacy Policy or the exercise of your rights, please contact:
Email: info@yousponsor.io