User Privacy & Data Protection

Starting 11 Privacy Policy

Last Updated: October 2026 • Data Controller: Ouroborean Software Ltd (Company No. 17501725)

Starting 11 ("we", "us", or "our") is operated by Ouroborean Software Ltd, a company incorporated in England and Wales under Company Registration Number 17501725. We are committed to safeguarding your personal data and respecting your privacy in strict compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the EU General Data Protection Regulation (Regulation (EU) 2016/679).

Core Privacy Commitment: We practice strict data minimization. Starting 11 is built so you can enjoy tactical football prediction without invasive surveillance, cross-site trackers, or sale of your personal information.

1. Data Controller Information

The designated Data Controller responsible for your personal data is:

Ouroborean Software Ltd
Company Registration Number: 17501725 (England and Wales)
Privacy & Data Protection Contact: support@starting-11.com
Address: United Kingdom

2. Categories of Data We Process

We only collect and process data necessary to provide and secure the game:

Gameplay & Tactical Predictions: Player selections, formation keys, timestamp of lock, accuracy scores, and tournament/league points.
Profile Identifier: A chosen player display handle (pseudonym), favorite club allegiance, and optional avatar or provider token (if signing in via Google, Apple, or guest mode). We never require your real name, address, or financial details.
Device & Telemetry Data: Technical logs including app version, browser user agent, IP address for regional routing/anti-abuse, and crash stack traces strictly for bug fixing and latency optimization.
Local Storage State: Offline draft team sheets and local preference toggles are stored locally on your device in HTML5 `localStorage`.

3. Lawful Bases for Processing (UK GDPR / EU GDPR)

We process your data under clear, recognized legal bases:

Contractual Necessity (Article 6(1)(b)): To calculate your matchday prediction score, record leaderboard rankings, and enable private league play with friends.
Legitimate Interests (Article 6(1)(f)): To safeguard competitive game integrity, prevent automated bot abuse, maintain server performance, and debug errors.
Consent (Article 6(1)(a)): For optional browser push notifications regarding kickoff reminders and lineup drop announcements (which you can revoke anytime).

4. Cookie Policy & Tracking Technologies

Starting 11 operates a clean, privacy-first technical architecture:

No Advertising Cookies: We do NOT set third-party marketing, retargeting, or advertising cookies.
Essential Local Storage: We use device local storage (`localStorage`) strictly to preserve your tactical drafts, current session token, and UI preferences across page visits.
No Cross-App Surveillance: We do not track you across external websites or mobile applications.

5. Third-Party Infrastructure Providers

We never sell, rent, or trade your data. To deliver high-performance, secure cloud gaming, we process data with trusted infrastructure partners bound by Data Processing Agreements:

Cloud Infrastructure: Amazon Web Services (AWS) and Google Cloud Platform for serverless execution, CDN caching, and secure database hosting.
Authentication: Firebase Authentication (Google LLC) for secure OAuth verification (Google and Apple sign-in).

6. Data Retention & Erasure

Draft lineups stored locally on your device remain until cleared or overwritten. Competitive leaderboard scores are retained for the active sports season. You have the right to erase your user profile and historical scores at any time via the in-app profile settings or our dedicated Data Deletion Instructions.

7. Your GDPR & Statutory Data Rights

Under UK and EU data protection laws, you possess enforceable statutory rights:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate information (e.g., your display handle).
Right to Erasure ("Right to be Forgotten"): Request immediate permanent deletion of your profile and leaderboard entries.
Right to Restriction: Limit processing under certain legal conditions.
Right to Data Portability: Obtain your prediction history in a structured, machine-readable format.
Right to Object: Object to processing based on legitimate interests.
Right to Lodge a Complaint: You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

To exercise any of these rights, simply email us at support@starting-11.com.

8. Children's Privacy

Starting 11 is a free-to-play tactical prediction platform rated for general audiences (PEGI 3 / ESRB Everyone). We do not knowingly collect personal identifiable information from children under the age of 13. If you believe a child has provided us with personal information, please contact us immediately for prompt erasure.

9. Contact the Data Controller

Ouroborean Software Ltd
Company Registration No: 17501725
Email: support@starting-11.com
Website: https://starting-11.com