Privacy Policy

Last updated: July 1, 2026

0. Identity of the data controller

In accordance with articles 13 and 14 of the GDPR, the controller of personal data collected through the AgentPro platform is:

Company name: Nexivanta Systems OÜ
Registered office: Pärnu mnt 388b, Nõmme linnaosa, 11612 Tallinn, Estonia
Registration: RC 1759138 — Tallinn Commercial Register
Email: contact@agentproapp.com
Phone: +49 151 26233775

1. Data collection

AgentPro collects personal information such as your name, email address, sports agent license number and player portfolio data in order to provide and improve our services.

2. Data usage

Your data is used to: provide access to the platform, verify your licensed-agent status, improve our services through anonymous analytics, and communicate with you regarding your account.

3. Data security

AgentPro implements TLS encryption in transit, two-factor authentication and hosting operated by DigitalOcean Inc. in the London region (LON1, United Kingdom). Personal data processing is designed to comply with the requirements of the General Data Protection Regulation (GDPR).

4. Data sharing

We never share your personal data with third parties without your explicit consent, except when required by law or to deliver our services (e.g. licensed-agent status verification).

5. Data retention

Personal data is retained for as long as you use AgentPro and for 3 years after account termination, in accordance with legal obligations.

6. Your rights

You have the right to access, rectify, delete or export your data. The full exercise procedure is detailed in the "Exercising your GDPR rights" section below.

7. Cookies and tracking

AgentPro uses cookies to improve your experience. You can control cookies via the /settings/cookies page or through your browser settings.

8. Policy changes

We may modify this policy at any time. Changes will be notified by email and must be accepted to continue using the service.

9. Legal basis for each processing activity

In accordance with article 6 of the GDPR, each processing activity relies on an identified legal basis. The table below details the applicable legal basis for each purpose.

Processing	Purpose	Legal basis (GDPR Art. 6)
Agent account (name, email, password, profile)	Creation and management of the user account, delivery of the SaaS service	Performance of a contract — Art. 6.1.b GDPR
Agent license number (FIFA / FFF / other federations)	Verification of professional status and fraud prevention	Legal obligation (professional status verification) — Art. 6.1.c GDPR — combined with legitimate interest (fraud prevention and trusted-ecosystem guarantee) — Art. 6.1.f GDPR
Player data (portfolio management, contracts, statistics)	Operational management of the agent's portfolio	Legitimate interest of the agent and indirect contractual basis (representation mandate) — Art. 6.1.f and 6.1.b GDPR
Community data (posts, messages, interactions)	Community features and user-to-user messaging	Explicit consent — Art. 6.1.a GDPR

10. Hosting

Data is hosted by:

Provider: DigitalOcean, LLC (TODO — to be confirmed with legal: the Nexivanta documentation also mentions GCP/AWS; current production infrastructure is DigitalOcean App Platform)
Address: 101 Avenue of the Americas, 10th Floor, New York, NY 10013, USA
Platform: DigitalOcean App Platform
Storage region: London (LON1, United Kingdom) — a country covered by a European Commission adequacy decision

Data is hosted in the United Kingdom, a country covered by a European Commission adequacy decision (2021): the transfer requires no additional safeguards under Chapter V of the GDPR. As DigitalOcean, LLC is a US company, Standard Contractual Clauses (2021/914) govern any access from the United States.

11. Data Protection Officer (DPO)

Nexivanta Systems OÜ has appointed a GDPR referent tasked with supervising compliance with the GDPR and acting as the point of contact for data subjects and supervisory authorities. The competent supervisory authority is the AKI (Andmekaitse Inspektsioon, Tatari 39, 10134 Tallinn — www.aki.ee).

DPO contact: dpo@agentproapp.com
Mission: The DPO oversees compliance of processing activities, handles rights-exercise requests, and is the point of contact for the supervisory authority (AKI in Estonia).

12. Exercising your GDPR rights

In accordance with articles 15 to 22 of the GDPR, you have the following rights over your personal data. The procedure to exercise each right is detailed below.

Right of access (Art. 15 GDPR)
Obtain a copy of the data we process about you.
Right of rectification (Art. 16 GDPR)
Correct any inaccurate or incomplete data about you.
Right to erasure (Art. 17 GDPR)
Request the deletion of your data, subject to legal retention obligations.
Right to portability (Art. 20 GDPR)
Receive your data in a structured, machine-readable format, or request its direct transfer to another data controller.
Right to object (Art. 21 GDPR)
Object to the processing of your data for reasons relating to your particular situation, in particular for processing based on legitimate interest.
Right to restriction (Art. 18 GDPR)
Request the temporary suspension of processing, for example while verifying the accuracy of contested data.

Exercise procedure

Available channels: Online form available from your personal area: /settings/privacy — OR email to the DPO: dpo@agentproapp.com
Required identification: If the request is submitted via your authenticated account (/settings/privacy), no additional document is required. If the request is sent by email, a copy of an identity document (ID card, passport or driving license) is required to verify your identity, in accordance with article 12.6 of the GDPR.
Response SLA: 1 month maximum from receipt of the complete request, in accordance with article 12.3 of the GDPR. This period may be extended by 2 additional months (i.e. 3 months in total) for complex or numerous requests; in that case, you will be informed of the extension and its reasons within the initial one-month period.
Cost: Free of charge, except for manifestly unfounded or excessive requests (Art. 12.5 GDPR).
Complaint to a supervisory authority: If you consider that your rights are not respected, you can lodge a complaint with the competent supervisory authority, the AKI (Estonia — www.aki.ee).

9. Automated processing (GDPR Art. 22)

AgentPro provides decision-support tools based on automated processing (profiling within the meaning of Article 22 GDPR). No decision producing legal effects is taken solely on the basis of such processing: the outputs are indicative and intended to inform a human professional. This section describes each of the automated treatments and the rights of the profiled persons.

Hybrid AI Valuation

Purpose: Provide agents with an indicative estimate of a player's market value to prepare negotiations and evaluate a portfolio.
Legal basis: Legitimate interest of the agent (Art. 6.1.f GDPR) in having contractual valuation support, balanced against the player's rights (identifier pseudonymised on the model side).
Underlying logic: Proprietary multi-factor statistical model (age, position, stats, minutes played, market comparables) combined with a call to Anthropic's Claude language model for contextual synthesis. The player's name is pseudonymised before any LLM call.
Consequences: Non-decisional numeric estimate. No contract refusal, disciplinary sanction or access restriction is triggered automatically. The agent retains full responsibility for the commercial decision.

Club Psychological Profiles

Purpose: Help agents and sporting directors understand a club's communication culture (tone, responsiveness, recurring topics) before making contact.
Legal basis: Legitimate interest (Art. 6.1.f GDPR) in preparing a negotiation from publicly available data (press releases, official club social media). No personal data of club members is targeted.
Underlying logic: Automated collection of publicly available club content and analysis by Anthropic's Claude language model to produce a qualitative profile. No individual scoring of executives.
Consequences: Indicative textual summary intended for internal use. Produces neither a binding ranking nor a compelling recommendation. The profile can be ignored, contested or supplemented by the user.

Intelligent Transfer Matching

Purpose: Suggest statistically compatible player-club pairs to guide prospection.
Legal basis: Legitimate interest (Art. 6.1.f GDPR) of the agent in identifying transfer opportunities, subject to the player's right to object.
Underlying logic: Compatibility score computed from club needs (open positions, budget, playing style) and player profile (statistics, age, value, availability). The computation combines a weighted similarity algorithm and a Claude call for narrative justification, with pseudonymisation of the player's name.
Consequences: The score is an indicative priority ranking. No contact, offer or contractual commitment is triggered automatically. Any follow-up action is performed by a human.

Right to human intervention and contestation

In accordance with Article 22(3) GDPR, the data subject may contest any automated output and obtain a human review. A 'Contest this score' button appears below each AI output on the platform: submitting it (POST /accounts/ai-contest/, capped at 10 requests per day) triggers a manual review by our Compliance team, which will respond within 30 days.

Right to object to automated profiling

A player or club representative may object at any time to the application of these automated treatments to their data, without having to justify the request. Exercising this right results in the exclusion of the relevant data from the Hybrid AI Valuation, the Intelligent Transfer Matching and the Club Psychological Profiles.

Email dpo@agentproapp.com

Please specify in your email which data or identifiers are concerned. Confirmation will be sent to you within 30 days.

Data Protection Officer (DPO): info@nexivanta.com
For any request to exercise your rights or questions relating to the processing of your data, please contact our DPO at the address above. See also the "Exercising your GDPR rights" section below.