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TOCKA

Privacy Policy

how we handle your data.

1. Who We Are

1.1 Tocka Ltd is the data controller for the personal data processed through the Tocka platform. We are registered in England and Wales (company number 17125457), with our registered office at 2, Frederick Street, Kings Cross, London, WC1X 0ND.

1.2 We are registered with the Information Commissioner's Office (ICO) as a data controller. Our registration number is ZC115486.

1.3 If you have any questions about how we handle your data, you can contact us at [email protected].

2. What Data We Collect

2.1 Account data: your display name, email address, year of birth, and the profile details you choose to add: playing position, preferred side, the team you support, and the avatar you build in the app.

2.2 Game data: your availability responses (including changes and withdrawals), waitlist activity, game attendance, team assignments, match results, Player of the Match votes, predictions, Last Man Standing picks, and related activity within groups you belong to.

2.3 Rating data: your player ratings, calculated from game results, including one that combines your ratings across groups, and an attendance reliability score based on whether you play, arrive late, or withdraw close to kickoff.

2.4 Payment data: transaction records, payment amounts, and credit balances within the platform. We do not store your full card details — these are processed and stored by Stripe.

2.5 Technical data: IP addresses and basic request information recorded in server logs, and any device or browser information transmitted automatically when you access the Service. We also keep a 30-day record of page visits (the page, your account if you are signed in, and a hashed IP address) and of failed sign-in attempts, to understand how the Service is used and to detect abuse.

2.6 Push notification tokens: if you enable push notifications, we store the device tokens necessary to send notifications to your device.

2.6a Support messages: if you contact us through the help sheet or by email, we keep your message and our reply.

2.6b Players added by an organiser: an organiser can add you to their group by name before you have an account, for example to record a game you played in. We hold that name and the game data attached to it on the same terms as any other player's. You can ask your organiser to remove you, claim the record by creating an account, or contact us.

2.7 We do not collect any special category data (such as health data, racial or ethnic origin, or religious beliefs).

3. How We Use Your Data

Account data

Create and manage your account; authenticate your identity.

Lawful basis: Contract (Art. 6(1)(b)). Retained: until account deletion.

Game data

Provide core Service features: availability tracking, team balancing, results.

Lawful basis: Contract (Art. 6(1)(b)). Retained: for the life of the group, without your name after account deletion.

Rating data

Calculate and display player ratings; balance teams fairly.

Lawful basis: Legitimate interest (Art. 6(1)(f)). Retained: for the life of the group, without your name after account deletion.

Payment data

Process payments, manage credits, handle refunds, comply with tax obligations.

Lawful basis: Contract (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)). Retained: 6 years after last transaction.

Technical data

Maintain security, monitor performance, improve the Service.

Lawful basis: Legitimate interest (Art. 6(1)(f)). Retained: request logs, page visits and failed sign-in records for 30 days; other server logs for no longer than 12 months.

Push notifications

Send game reminders, availability requests, waitlist offers, payment requests, and occasional service announcements from Tocka.

Lawful basis: Consent (Art. 6(1)(a)). Retained: until notifications disabled or account deleted.

Email: game emails

Availability requests, team sheets, match wraps, waitlist offers and payment requests from groups you belong to, and alerts about your group if you organise one. You can switch each type off, group by group, under Notifications.

Lawful basis: Contract (Art. 6(1)(b)). Retained: your email address until account deletion; a record of what was sent is kept with your account.

Email: account and security

Password resets, email-change confirmations, replies to your support messages, the outcome of a request to join a group, and notice of material changes to this policy or the Terms. These are sent while you have an account.

Lawful basis: Contract (Art. 6(1)(b)); Legitimate interest (Art. 6(1)(f)) in keeping accounts secure.

Email: messages from Tocka

Occasionally we may email you ourselves to help you get set up (for example, if you have started a group and not yet got a game going) or to ask for feedback. These are not advertising and are never sent on behalf of anyone else. Every such message tells you how to stop them.

Lawful basis: Legitimate interest (Art. 6(1)(f)) in helping people use the Service and in improving it. You can object at any time (section 9.6).

4. AI Features and Data Processing

4.1 The Service uses AI to write match previews and reviews, group descriptions and group badges, and to help us draft replies to support messages. The AI provider is Anthropic, through its Claude API.

4.2 Before anything is sent, player names are replaced with placeholder labels, and the real names are restored on our servers afterwards. Anthropic does not receive your name, email address or any account identifier. It does receive team line-ups as labels, ratings and results, and group-level details set by your organiser (such as group name, team names, kit colours, the general area of the venue, and the group's motto).

4.3 If you send us a support message, its text may be sent to Anthropic to help draft a reply. Your name, your group's name and the names of its players are replaced with labels first, and email addresses and phone numbers are removed; anything else you write is sent as written. A person at Tocka reads, edits and sends every reply.

4.4 Anthropic processes this data on our behalf and does not use it to train its models.

5. Who We Share Your Data With

5.1 Other members of your groups: your display name, availability, attendance, game activity, and your ratings and scoreboard position (an organiser can hide Group Rating from other members). Your email address is visible only to the organiser(s) of groups you belong to. Your year of birth is not shown to other members; team sheets show an age range for the team.

5.1a Join requests (group recruitment): if you ask to join a group you are not already a member of, and you consent when sending that request, the group's organiser(s) can see a limited summary of your playing record to help them decide: your display name, profile picture (a generated avatar, not a photo), playing position, preferred side, age band, overall rating, total games played, win rate, recent form, Player of the Match wins, and the number of groups you play in. They cannot see your email address, your exact age, or the names of the specific other groups you belong to. This summary is shown only when you have given consent.

5.1b After you leave a group: games you played stay in that group's history under the name you played as, until you delete your account.

5.1c People holding a group's links: someone with a group's invite link can see the names of players the organiser has added who have not yet claimed their place. Someone with a game's who's-in link can find a name on the group's list by typing part of it (section 6a). Organisers decide who gets these links.

5.1d Shared images: members can share result, team-sheet and record cards outside the app. These images show display names and, on some cards, ratings.

5.1e Tocka-wide Last Man Standing: if you enter, you choose how you appear to players outside your groups: under your group's name, under a name you pick, or anonymously.

5.1f Public group pages: if an organiser makes a group public, it gets a public page that search engines can index. It shows group-level information only. It does not show player names or individual ratings.

5.2 Stripe: we share necessary data with Stripe to process payments. Stripe acts as an independent controller for payment data. See Stripe's privacy policy at stripe.com/privacy.

5.3 Hosting and network: the Service is hosted on servers provided by Hetzner Online GmbH in Germany. Cloudflare, Inc. carries traffic between you and those servers and stores our database backups in Western Europe.

5.3a Email delivery: Brevo (Sendinblue SAS, France) delivers the emails described in section 3. It receives your email address, your display name and the content of the email.

5.3b Push delivery: push notifications are delivered through Apple (Apple Push Notification service), Google (Firebase Cloud Messaging) or your browser's push service. They receive your device token and the content of the notification.

5.4 AI provider: Anthropic, as described in section 4.

5.5 We do not sell your personal data to any third party. We do not share your data with advertisers.

5.6 We may disclose your data if required by law, regulation, or legal process, or to protect the rights, safety, or property of Tocka, our users, or others.

6. Cookies and Local Storage

6.1 The Service uses essential cookies and local storage to keep you logged in and to store your preferences. These are strictly necessary for the Service to function.

6.2 We do not use advertising cookies or third-party tracking cookies.

6.3 If we introduce analytics cookies in the future, we will update this policy and seek your consent where required.

6a. Responding Without an Account

6a.1 Some groups share a per-session link (for example, in a WhatsApp thread) that lets someone respond to a game without logging in or installing the app. Opening the link shows only the group name, the date and kickoff time, and how many spots are left — nothing else, until you say who you are.

6a.2 To respond, you type your name and pick yourself from the group's player list. If your organiser has let new names join for that game and your name isn't on the list, you can add your name instead: the page creates a player with just that name, your organiser sees it straight away and can remove it, and it's held like any player your organiser adds for you — same retention, same rights. You can't take over a name that's already on the list this way.

6a.3 When you respond (in / maybe / out), we store which group member you said you are, the game session, a timestamp, and a scrambled copy of a random code for this device (6a.4). Your group sees your response the same way as an in-app one; nobody sees the device code. We keep these records for as long as the group exists.

6a.4 We set a cookie so the link recognises you next time, instead of asking who you are each week. It's set only when you respond. It also holds a random code for this device, which isn't based on your address, your browser or anything else about you. It lets you move a name you added on this device onto your Tocka account later (6a.6). This cookie is strictly functional: it doesn't track you across other sites, and it expires after 180 days. You can tell the page "not me" or clear your cookies to reset it.

6a.5 To stop abuse of these links, we keep short-lived counts of attempts per link and per IP address. They aren't stored with your data.

6a.6 If you have a Tocka account, you can sign in from the link. If your organiser lets new names join a game, you can answer as yourself and the group is added to your app; your organiser sees you in the group's list and can remove you. If you added a name on this device and nobody else has ever answered as it, you can move it and its answers onto your account, or onto a new one you create from the page.

7. International Data Transfers

7.1 Your personal data is stored on servers in the European Economic Area (EEA), hosted by Hetzner Online GmbH in Germany. Transfers between the UK and the EEA are covered by mutual adequacy decisions, meaning your data receives an equivalent level of protection to that provided under UK law.

7.2 Some of the providers in section 5 process data outside the UK and EEA, mainly in the United States: Apple and Google (push delivery), Cloudflare (network), Stripe (payments), and Anthropic (the limited data described in section 4).

7.3 Where that happens, the transfer is covered by UK adequacy regulations (including the UK–US data bridge where the provider is certified) or by the ICO's International Data Transfer Agreement or Addendum in our contract with the provider. See the providers' own privacy policies for details.

8. Data Security

8.1 We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit (HTTPS/TLS), access controls, and regular backups.

8.2 Payment card data is handled entirely by Stripe and is never stored on our servers.

8.3 While we take reasonable steps to protect your data, no system is completely secure. We cannot guarantee the absolute security of your data.

9. Your Rights

Under UK GDPR, you have the following rights in relation to your personal data:

9.1 Right of access: you can request a copy of the personal data we hold about you.

9.2 Right to rectification: you can ask us to correct inaccurate or incomplete data.

9.3 Right to erasure: you can ask us to delete your data, subject to our legal obligations.

9.4 Right to restrict processing: you can ask us to limit how we use your data in certain circumstances.

9.5 Right to data portability: you can request your data in a structured, commonly used, machine-readable format.

9.6 Right to object: you can object to processing based on legitimate interests. This includes messages from Tocka about setup or feedback: use the link in the message, or reply and say so, and they stop.

9.7 Right to withdraw consent: where we rely on consent (e.g. push notifications), you can withdraw it at any time by turning them off under Notifications or in your device settings.

9.8 You can download a JSON copy of the personal data we hold about you at any time from your profile picture (top-right corner) → Profile → Download my data. The file covers your account, group memberships, match history, ratings, payments, votes and predictions, and admin actions you have taken. To exercise any other right, or for help interpreting your download, contact us at [email protected]. We will respond within one month.

9.9 If you are unhappy with how we have handled your data, tell us at [email protected]. We will acknowledge your complaint within 30 days and tell you the outcome. You can also complain to the Information Commissioner's Office (ICO) at ico.org.uk.

10. Data Retention

10.1 We retain your personal data only for as long as necessary for the purposes set out in this policy, or as required by law.

10.1a When you sign up we keep your details for up to two days while we wait for you to confirm your email; if you don't, they are deleted.

10.2 When you delete your account, your email address, password, profile details, push subscriptions and notification settings are deleted immediately, and your name is removed. You are withdrawn from any upcoming games, and your group sees that as a normal withdrawal under your name. Games you played stay in your groups' records under the label "Former player", and you no longer appear in any leaderboard or record list. If you owe a group money or are owed credit, that group's organisers are told your name and the amount. Payment records are kept for 6 years for tax compliance. Page-visit records age out within 30 days, and copies in our backups age out as the backups are replaced.

10.3 Anonymised data (which cannot be used to identify you) may be retained indefinitely for analytical and statistical purposes.

11. Children's Privacy

11.1 Users must be at least 13 years old to create an account. Users aged 13 to 15 must have the consent of a parent or guardian before using the Service. We collect year of birth during registration to verify eligibility.

11.2 Payment features are restricted to users aged 16 and over, or where an adult's payment method is used with their consent.

11.3 If we become aware that we have collected personal data from a child under 13, we will take steps to delete that data promptly.

12. Changes to This Policy

12.1 We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, regulatory, or operational reasons.

12.2 We will notify you of material changes by email or through the Service. The effective date at the foot of this policy shows when it was last revised.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Tocka Ltd, Data Controller
2, Frederick Street, Kings Cross, London, WC1X 0ND
Email: [email protected]