Privacy policy

In short

• Tennistiq tracks the tournaments, matches and rankings of tennis players, mainly in Belgium.
• Many of the players followed are minors: their data is entered and viewed by an adult close to them (parent, coach).
• We also use the public directories of the federations — people who don't have an account with us — and republish their tournaments, draws and results, readable without an account. Section 5 explains why, and how to object.
• Nothing is sold, rented or exchanged. No advertising, no commercial profiling.
• No audience measurement, no advertising trackers — hence no cookie banner (section 7).
• For any request: info@tennistiq.be.

1. Data controller

Raphaël Delvaux, a private individual established in Belgium. Tennistiq is a free service in private beta: no company has been incorporated so far, and these details will be completed before any billing (see the legal notice).

Contact for any question about data, and to exercise your rights: info@tennistiq.be.

No data protection officer has been appointed. Article 37 of the GDPR does not require one here: we are not a public authority, we do not carry out large-scale systematic monitoring, and we do not process special categories of data on a large scale.

2. Who this policy is for

Three groups of people, and the distinction shapes everything that follows:

• Account holders — adults who open an account and follow players (information provided directly, Art. 13 GDPR).
• Followed players — most often minors, whose data is entered by an adult in their follow group.
• People listed in the federation directories — about 46,700 AFT members, 32,000 Tennis & Padel Vlaanderen members, 5,900 FLT members and 12,000 players on the Tennis Europe junior tour (aged 12 to 16, from all over Europe), who have no account with us (information obtained indirectly, Art. 14 — see section 5).

3. Data processed

3.1 Account

Email address, first name, last name, hashed password (bcrypt; never stored in clear, never readable by us), role, time zone, language, theme preference, notification preferences, calendar feed token.

3.2 Sign-ins and security

For each open session: IP address and browser identifier (user agent). This is the only place in the service where an IP address is stored, and it has a specific purpose: to let you spot and revoke a session you don't recognise.

3.3 Notifications

Browser notification subscriptions (technical subscription address, encryption keys, browser identifier) and the history of notifications sent. The latter contain the text displayed, and therefore the names of the players concerned.

3.4 Followed players

First name, last name, date of birth, gender, playing hand, club, rankings, matches (dates, opponents, scores, format, round), tournament entries, ranking points, and — when live scoring is used — the shot-by-shot detail of every point (serve, type of shot, rally length).

3.5 Follow groups

Who follows which player, in what capacity (the declared relationship, "parent" by default), who invited whom, and when each invitation was accepted. This is a social graph, and we say so: it reveals family and professional ties.

3.6 Federation credentials (AFTNET code)

The federation only publishes a player's tournament entries in its members' area. A member of the follow group can therefore enter the player's PIN code so that the service can read them. This code:

• is encrypted before being written, with a key that is not stored in the database;
• is never displayed again, on any page, in any log or in any export;
• does not appear in backups in a usable form, since the key is not there;
• is used only for reading: never to enter, withdraw or change anything with the federation;
• is disabled after three failed sign-in attempts, so as not to lock the player's federation account;
• is deleted as soon as it is no longer used — end of following, departure of the member who entered it, deletion of the player or of the account.

3.7 Sharing

Reactions to a match, share tokens for a tournament recap, calendar feed token. Each token comes from an explicit action: its existence is the consent to serve the page without authentication.

3.8 Federation directories and results

Membership number, name, date of birth, gender, club and ranking of members; tournament draws and match results, with the names of the players involved. Sources: the public pages of the AFT (tennis.tppwb.be), Tennis & Padel Vlaanderen (tennisenpadelvlaanderen.be) and the FLT (flt.lu, flt.tournamentsoftware.com), and those of the Tennis Europe tour (te.tournamentsoftware.com), which publish neither club nor date of birth but the player's TE ID and their nationality at the tournament. To link the Tennis Europe profile of a Belgian or Luxembourg player to their national directory entry, we compare the name, gender and the age group played; this match is never displayed. See section 5.

3.9 Waiting list

Email address, and if you provide them: first name, last name, club, ranking, profile and message. No IP address is recorded with an access request.

3.10 Server technical logs

Independently of the application, the server keeps operating logs:

• the web server log, which records for each request the IP address, the page requested, the date and the browser — kept for 14 days;
• the system log, where the application writes its operating traces. Some of them contain players' names (progress of synchronisations with the federations) — kept for 30 days.

These logs are used solely to run and troubleshoot the service, and to detect a security incident. They are neither analysed for audience measurement nor matched with accounts.

3.11 Objection requests

Federation, licence number, email address and, if you write one, a message. No IP address is recorded with a request. The email address is erased as soon as the request has been handled (section 5).

3.12 What we do not process

No banking, health, biometric or location data. No advertising profile. No data purchased from third parties.

4. Purposes and legal bases

5. Federation data

This is the most sensitive processing in the service, and it deserves an explanation rather than a passing mention.

What is collected, and where from

We automatically collect the federations' public pages: member directory, tournament draws, results. These pages are accessible without an account. The only exception is the AFTNET members' area, which we enter only with the code voluntarily provided by a member of the follow group of the player concerned, and only to read that player's entries.

Why it is necessary

To calculate a player's points, you need to know their opponents. To project a ranking, you need a reference population. To show a player's run in a tournament, you need the whole draw. A player on their own has no ranking: a ranking is a position within a population.

What can be read without an account

What the federations publish, we republish, organised differently: the tournament calendar, draws and results, interclub pools, standings and match sheets, club pages, and a player's page — their name, club, official ranking and published results. These pages can be read without an account and can be found by search engines. They carry the players' names, as the federation publishes them.

• Never published: date of birth and age, registrations read in the AFTNET member area, the point-by-point record of a match, friendly matches, and any figure we calculate about a person (points, ranking projection, strength rating, prediction, position in an internal ranking).
• Indexing follows the federation: we checked, federation by federation, whether its own pages naming individuals are indexed by search engines. They are at the AFT and the FLT; they are not at Tennis & Padel Vlaanderen, whose draws we therefore keep out of search engines. The profiles and draws of the Tennis Europe tour, which brings together only players aged 12 to 16, are kept out of them too. We make no one easier to find than their federation does.

The balancing test (Art. 6.1.f)

• Interest pursued: enabling a player — or their parent — to understand their own ranking, which is impossible without the reference population; and making the results the federations publish easier to consult.
• Necessity: the federations offer no data interface; the information is already published by them.
• Impact on individuals: this is sports data, already public and not sensitive. It is never resold, never enriched with other sources, never used for advertising. Republishing it without an account exposes no one more than their federation does, where the federation lets itself be found by search engines; elsewhere, our pages are not indexed.
• Safeguards: no date of birth and no calculation attached to a person on a public page; a self-service objection, without an account, that hides the name as soon as it is received; indexing aligned, federation by federation, on the federation's own.

Why you were not notified individually

Article 14.5.b of the GDPR exempts from informing each person where doing so would involve a disproportionate effort. Contacting more than fifty thousand members individually about data their own federation publishes falls within that case. This policy, public and indexed, is the appropriate measure provided for by that same article.

Right to object

You can ask for your profile and your matches to be removed from our dataset, without having to give a reason (Art. 21), using the removal form — your federation, your licence number and an address for our reply are enough — or by writing to info@tennistiq.be. The parent or legal representative of a minor can make the request on their behalf.

• Immediately, your profile stops being exposed: your name is hidden from visitors without an account, including on shared scores.
• Within 30 days, your profile and your matches are removed from our dataset.
• After that we keep your federation and your licence number, and nothing else: this is what stops your profile from coming back the next time the directory is read. Your email address is erased as soon as the request has been handled.

A large part of this data concerns minors. That is why no date of birth, no age and no figure calculated about a person is published, and why an objection takes effect as soon as it is received.

6. Minors

A Tennistiq account can only be opened by an adult. The service is not intended to be used by a child without a parent's account. At present, accounts are only created on the publisher's invitation, which provides effective control of this rule.

A minor's data is entered and viewed by the adults in their follow group. By following a minor, the account holder declares that they are the minor's legal representative, or have their consent.

• A player's date of birth is shown only to the members of their follow group, never in general lists — a rule checked by our automated tests.
• Publishing a tournament recap is an act of the follow group. An administrator cannot publish on their behalf; they can only revoke a link.
• No minor's data is passed to any audience measurement or advertising tool — there are none.
• Our error-tracking tool is configured to receive no request body, no cookie, no header and no IP address: only the numeric identifier of the account concerned reaches it.

To exercise a child's rights (access, rectification, erasure), their legal representative can write to us at info@tennistiq.be.

7. Cookies and trackers

Everything the service stores on your device:

• A signed session cookie, httponly, SameSite=Lax: it keeps you signed in.
• The application session cookie, which remembers which page to send you to after signing in, and where applicable the identity of the administrator helping with your account.
• A language cookie, set only if you choose a language: it remembers that choice in this browser, even when you are signed out.
• A theme preference (light/dark) in local storage: it is not a cookie and is never sent to the server.

No audience measurement, no trackers, no pixels, no ad networks. All our cookies are strictly necessary for the service to work within the meaning of Article 129 of the Belgian law of 13 June 2005: that is why there is no banner — there is nothing to consent to. A banner that asked for nothing would be a polite lie.

In fairness: the site's fonts are loaded from Google Fonts, which passes your IP address to Google when pages are displayed. No cookie is set this way. We plan to host these fonts ourselves to remove this dependency.

8. Recipients and processors

No data is sold, rented or exchanged. Apart from these providers, only the service administrator has access to the data, and only to run the service and troubleshoot accounts.

A copy of the database is replicated every night to a second machine under our control, in Belgium. It is the only artefact that leaves the server, and it contains no usable AFTNET code, since the encryption key is not included. No data leaves the European Union.

9. Retention periods

10. Your rights

You have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time.

Access, portability and erasure can be exercised directly from your account, without writing to us or waiting:

• Download your data — a JSON file containing everything we hold about your account: profile, sign-ins and their IP addresses, notifications, follow groups, followed players and all their matches, including the point-by-point detail you recorded. The AFTNET code is not included: it is never returned by any means.
• Delete your account — a screen shows you beforehand, based on the actual state of your account, what will be deleted and what will remain.

The other rights (rectification, restriction, objection) are exercised by email to info@tennistiq.be, and are handled within one month.

Some data cannot be deleted on simple request: a match involves two players, and sports results published by the federation fall under section 5. Deleting an account therefore does not erase tournament data that also concerns other people.

Finally, you may lodge a complaint with the Data Protection Authority (Autorité de protection des données), Rue de la Presse 35, 1000 Brussels — dataprotectionauthority.be, contact@apd-gba.be, +32 (0)2 274 48 00.

11. Security

• Encrypted transport across the whole site (HTTPS, HSTS).
• Passwords hashed with bcrypt; we cannot read them.
• httponly and SameSite session cookies.
• Limits on the number of attempts for sign-in and public forms.
• AFTNET code encrypted at rest, with a key kept outside the database.
• Separation between accounts checked by a suite of automated tests run on every change.
• Restricted administrator access; when an administrator views an account to troubleshoot it, a banner says so on screen.

12. Changes

Each version of this policy is dated. Any substantial change is announced by email to account holders before it takes effect.