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Youth Privacy Notice

Last updated: 25 April 2026

This Youth Privacy Notice explains how Pulsessivo.ai may be used in youth-team and youth-program contexts in Italy when the account is managed by a club, football school, academy, federation, school, or coach on behalf of a minor athlete. It should be read together with the main Privacy Policy, Terms of Service, and, where applicable, the Data Processing Agreement.

1. Who This Notice Applies To

This notice is intended for:

  • minor athletes participating in youth programs managed through Pulsessivo.ai;
  • parents, guardians, or other persons exercising parental responsibility for those athletes; and
  • clubs, football schools, academies, federations, schools, and coaches using the service for youth activities.

2. Who Decides How the Data Is Used

In most youth-program deployments, the club or sports organization using Pulsessivo.ai decides which data is entered, for what purposes it is used, and who may access it. That organization typically acts as the data controller.

Pulsessivo.ai generally acts as the data processor, providing hosting, security, support, and platform functionality on behalf of the controller.

If you are unsure who the controller is for a specific minor athlete, contact the responsible club, football school, or coach first.

3. What Data May Be Processed

Depending on how the youth program is configured, the platform may process:

  • athlete identity and team data, such as name, category, role, and team assignment;
  • parent or guardian contact details;
  • attendance, training load, wellness indicators, performance data, and coaching notes;
  • usage, security, audit-log, and support data;
  • uploaded files and support-related communications; and
  • if wearable devices are enabled, biometric or health-related data such as heart rate, activity levels, and performance metrics.

4. Purposes and Legal Bases

Youth-program data may be used to:

  • manage accounts, permissions, and team access;
  • organize training sessions, attendance, availability, and sports activities;
  • monitor workload, general wellness, and sports performance;
  • provide security, support, maintenance, and service protection; and
  • manage compatible hardware devices where selected by the organization.

The legal bases for processing are determined by the data controller in light of the specific organizational context and may include performance of the relationship with the athlete and family, legitimate interests of the controller, legal obligations, and, for special-category data under Article 9 GDPR, explicit consent or another valid legal basis under applicable law.

5. Rules Specific to Minors in Italy

For information-society services offered directly to minors in Italy, Article 2-quinquies of Legislative Decree 196/2003 sets 14 years of age as the threshold for autonomous digital consent.

For Pulsessivo.ai in youth-sports contexts, it is nonetheless recommended that:

  • there be no direct self-service sign-up by children or younger adolescents;
  • activation occur through club-managed accounts or another adult-authorized workflow;
  • appropriate notice and parental-consent records be collected and retained where required; and
  • access be limited to authorized persons with roles appropriate to their responsibilities.

6. Wearables and Special-Category Data

If the controller enables Pulsessivo Smart Bracelets or compatible devices, the platform may process special-category data, including biometric or health-related data.

For minor athletes, the organization should collect parent or guardian consent and, where appropriate, informed assent from the minor, unless the controller documents another valid legal basis under Article 9 GDPR.

The smart bracelet and the platform are not medical devices and do not replace medical assessment, diagnosis, or treatment.

7. Sharing and International Transfers

Pulsessivo.ai may use service providers for hosting, analytics, customer support, payments, tax operations, and email services under appropriate data protection arrangements.

Where data is transferred outside the EEA or the United Kingdom, appropriate safeguards are used, such as Standard Contractual Clauses or another valid transfer mechanism.

8. Retention Periods

Youth-program data is generally retained according to the controller's instructions and in compliance with contractual documentation and applicable legal obligations.

Indicative periods may include:

  • account data: for the duration of the relationship and a limited period afterward where required by law or contract;
  • support tickets and support requests: usually 12 to 24 months;
  • backups: up to 90 days; and
  • deletion or return at the end of the relationship: generally within 60 days, subject to backup cycles or further retention obligations.

9. Rights of Minors, Parents, and Guardians

Subject to applicable law, minor athletes and their parents or guardians may exercise rights of:

  • access to personal data;
  • rectification of inaccurate data;
  • deletion or restriction of processing;
  • objection to certain processing;
  • data portability, where applicable; and
  • withdrawal of consent for consent-based processing, including biometric processing where applicable.

Requests should first be directed to the controller managing the youth program. The right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) remains unaffected.

10. Contacts

For questions about a minor athlete's use of Pulsessivo.ai, contact the responsible club or organization first.

You may also contact:

If you believe data about a minor was collected outside an organization-managed youth program or without the required authorization, please contact us promptly.