StartSport
Privacy Policy
Last updated: Version 1.0 · effective 22 Sept 2026
**STARTSPORT**
**PRIVACY POLICY**
**Effective Date:** September 22, 2026
**Last Updated:** September 22, 2026
**Version:** 1.0
**IMPORTANT PRIVACY NOTICE**
StartSport respects the privacy of individuals whose Personal Data is processed through the StartSport Platform.
This Privacy Policy explains how StartSport collects, receives, uses, processes, stores, shares, transfers, protects, and otherwise handles Personal Data in connection with:
- the StartSport website;
- mobile applications;
- web applications;
- Student Accounts;
- University Accounts;
- Sports Organisation Accounts;
- Internship Applications;
- Internship Opportunities;
- communications;
- payments;
- AI-powered services;
- customer support;
- marketing;
- analytics; and
- other StartSport services.
By accessing or using StartSport, you acknowledge that you have read and understood this Privacy Policy.
Where consent is legally required for a particular processing activity, StartSport will obtain such consent in accordance with Applicable Law.
**1. WHO WE ARE**
StartSport is operated by:
**Legal Entity:** Startsport.co International – an Egyptian Limited Liability Company
**Commercial Name:** StartSport
**Country:** Arab Republic of Egypt
**Website:** startsport.co
For purposes of applicable data protection laws, StartSport may act as a data controller, processor, or other legally recognised data-processing role depending on the nature of the relevant processing activity.
**2. SCOPE OF THIS PRIVACY POLICY**
This Privacy Policy applies to Personal Data processed through:
1. the StartSport website;
2. StartSport mobile applications;
3. StartSport web applications;
4. Student Accounts;
5. University Accounts;
6. Sports Organisation Accounts;
7. Internship Applications;
8. Internship Opportunity participation;
9. StartSport communications;
10. payment processes;
11. customer support;
12. AI and recommendation systems;
13. verification processes;
14. marketing activities;
15. analytics and Platform improvement; and
16. other services operated by StartSport.
This Privacy Policy does not necessarily apply to third-party websites, applications, services, or organisations that are not controlled by StartSport.
**3. DEFINITIONS**
For this Privacy Policy:
**3.1 "Personal Data"**
means any information relating to an identified or identifiable natural person, as defined under Applicable Law.
**3.2 "Processing"**
includes collecting, recording, organising, storing, adapting, modifying, retrieving, consulting, using, disclosing, transmitting, distributing, restricting, deleting, or otherwise handling Personal Data.
**3.3 "Data Subject"**
means the individual to whom Personal Data relates.
**3.4 "User"**
means any person accessing or using StartSport.
**3.5 "Student"**
means a User using StartSport to discover, apply for, participate in, or complete an Internship Opportunity.
**3.6 "University"**
means a university or educational institution registered with or using StartSport.
**3.7 "Sports Organisation"**
means a sports club, federation, company, academy, agency, facility, event organiser, or other sports-related organisation using StartSport.
**3.8 "Internship Provider"**
means an organisation providing, hosting, supervising, sponsoring, or participating in an Internship Opportunity.
**4. PERSONAL DATA WE MAY COLLECT**
Depending on how you use StartSport, we may collect different categories of Personal Data.
**4.1 IDENTIFICATION DATA**
We may collect:
- full name;
- date of birth;
- age;
- gender where voluntarily provided or legally required;
- nationality;
- country of residence;
- profile photograph;
- identity verification information;
- identification document information;
- passport information where required for an international opportunity;
- government-issued identification information;
- signature or electronic acceptance records; and
- other information necessary to verify identity.
**5. CONTACT INFORMATION**
We may collect:
- email address;
- telephone number;
- mobile number;
- country code;
- residential or correspondence address;
- emergency contact information where required;
- communication preferences; and
- other contact information provided by the User.
**6. EDUCATIONAL INFORMATION**
For Students and University Users, we may collect:
- university name;
- faculty;
- department;
- degree programme;
- academic level;
- graduation year;
- student identification number;
- academic status;
- university email address;
- academic documents;
- CV;
- certificates;
- qualifications;
- academic achievements;
- courses;
- skills;
- areas of interest;
- previous internship information; and
- other educational information supplied by the User or authorised University.
**7. PROFESSIONAL INFORMATION**
We may collect:
- CVs;
- employment history;
- internship history;
- professional experience;
- professional qualifications;
- skills;
- certifications;
- languages;
- professional interests;
- career objectives;
- portfolio information;
- professional profiles;
- professional references; and
- other information relevant to Internship Opportunities.
**8. INTERNSHIP APPLICATION DATA**
When a Student applies for an Internship Opportunity, StartSport may process:
- Application information;
- selected Internship Opportunity;
- application date;
- application status;
- eligibility information;
- documents;
- answers to application questions;
- interview information;
- assessment information;
- screening results;
- communication records;
- acceptance or rejection status;
- participation status;
- attendance information;
- evaluation information;
- completion information;
- certificate information; and
- other information necessary to administer the Application.
**9. UNIVERSITY DATA**
Where a University uses StartSport, we may process information relating to:
- University identity;
- authorised University representatives;
- University administrators;
- Student populations;
- Students associated with the University;
- Applications;
- Internship participation;
- completion information;
- certificates;
- University requests;
- administrative communications;
- reports;
- analytics; and
- other information necessary to provide University services.
**10. SPORTS ORGANISATION DATA**
Where a Sports Organisation uses StartSport, we may collect:
- organisation name;
- legal entity information;
- registration information;
- business address;
- contact information;
- authorised representative information;
- employee or administrator information;
- Internship Opportunity information;
- programme information;
- payment information;
- communications;
- contracts;
- verification documents; and
- other business information.
**11. PAYMENT INFORMATION**
Where Users make payments through StartSport, we may process information relating to:
- transaction amount;
- transaction currency;
- transaction date;
- transaction reference;
- payment status;
- payment method;
- billing information;
- refund information; and
- payment-related communications.
Where payment processing is performed by a third-party payment provider, StartSport may not receive or store complete payment-card details.
Payment providers may process payment information under their own privacy policies.
**12. TECHNICAL AND DEVICE INFORMATION**
When you access StartSport, we may automatically collect technical information including:
- IP address;
- device type;
- operating system;
- browser type;
- browser version;
- device identifiers;
- language settings;
- time zone;
- screen information;
- network information;
- Platform activity;
- pages visited;
- features used;
- access times;
- session information;
- error logs;
- crash reports;
- referral information; and
- similar technical information.
**13. LOCATION INFORMATION**
Depending on the functionality enabled and the User's permissions, StartSport may process:
- country;
- city;
- general geographic information;
- location associated with an Internship Opportunity;
- travel destination;
- or other location-related information voluntarily supplied by the User.
StartSport will not intentionally collect precise location information unless the relevant functionality requires it and the necessary legal basis and permissions exist.
**14. COMMUNICATION DATA**
We may retain communications between Users and StartSport, including:
- emails;
- support requests;
- Platform messages;
- application communications;
- notifications;
- telephone records where lawfully recorded;
- communications with customer support;
- communications concerning Applications; and
- other communications relating to StartSport services.
**15. INFORMATION FROM UNIVERSITIES**
Where permitted and authorised, StartSport may receive information from Universities concerning Students, including:
- Student identity;
- university affiliation;
- academic status;
- eligibility;
- Application information;
- programme participation; and
- other information required to administer University-related services.
The University is responsible for ensuring that it has the appropriate authority to provide such information to StartSport.
**16. INFORMATION FROM SPORTS ORGANISATIONS**
StartSport may receive information from Internship Providers concerning Applicants, including:
- Application status;
- interview results;
- acceptance;
- attendance;
- participation;
- performance;
- completion;
- evaluation;
- certificate eligibility; and
- other information necessary to administer an Internship Opportunity.
**17. INFORMATION FROM THIRD PARTIES**
Where legally permitted, StartSport may receive information from:
- Universities;
- Sports Organisations;
- Internship Providers;
- payment providers;
- identity verification providers;
- technology providers;
- analytics providers;
- communication providers;
- fraud prevention services;
- publicly available sources; and
- other authorised third parties.
**18. HOW WE COLLECT PERSONAL DATA**
We may collect Personal Data:
**18.1 Directly from you**
For example when you:
- create an Account;
- complete your profile;
- apply for an Internship;
- upload documents;
- contact us;
- make a payment;
- submit feedback;
- communicate with support; or
- otherwise use StartSport.
**18.2 Automatically**
Through:
- cookies;
- analytics technologies;
- server logs;
- device information;
- security systems; and
- similar technologies.
**18.3 From organisations**
Including Universities and Internship Providers.
**18.4 From service providers**
Including identity verification, payment, communication, analytics, and security providers.
**19. PURPOSES OF PROCESSING**
StartSport may process Personal Data for the following purposes.
**19.1 ACCOUNT MANAGEMENT**
To:
- create Accounts;
- authenticate Users;
- manage profiles;
- verify identity;
- maintain security;
- manage permissions; and
- provide Platform access.
**19.2 INTERNSHIP APPLICATION PROCESSING**
To:
- process Applications;
- assess eligibility;
- communicate with Applicants;
- transmit relevant Application information to authorised Internship Providers;
- coordinate internships;
- manage acceptance;
- track participation;
- issue certificates; and
- administer the Internship Opportunity.
**19.3 UNIVERSITY SERVICES**
To:
- provide University dashboards;
- manage Student information;
- produce reports;
- track Applications;
- track participation;
- provide analytics;
- communicate with authorised University representatives; and
- provide other University-related services.
**19.4 SPORTS ORGANISATION SERVICES**
To:
- create organisation profiles;
- verify organisations;
- publish Internship Opportunities;
- receive relevant Applications;
- communicate with Applicants;
- manage programme participation;
- conduct evaluations; and
- administer Internship Opportunities.
**20. MATCHING AND RECOMMENDATION**
StartSport may use Personal Data to:
- recommend Internship Opportunities;
- identify potentially relevant opportunities;
- personalise Platform content;
- match Students with opportunities;
- identify eligibility;
- improve search results;
- improve recommendations; and
- provide career-related Platform functionality.
Recommendations are generated based on information available to StartSport and may not always be accurate or appropriate.
**21. ARTIFICIAL INTELLIGENCE**
StartSport may use artificial intelligence and automated technologies for:
- conversational assistance;
- opportunity recommendations;
- profile analysis;
- matching;
- search;
- classification;
- fraud detection;
- content moderation;
- customer support;
- Platform optimisation;
- analytics; and
- other legitimate Platform purposes.
AI outputs may be inaccurate, incomplete, outdated, or unsuitable for a particular User.
AI functionality should not be treated as professional, legal, immigration, medical, financial, employment, or academic advice.
Where Applicable Law requires additional safeguards for automated decision-making, StartSport will apply the relevant safeguards.
**22. LEGAL BASES FOR PROCESSING**
Depending on the circumstances and Applicable Law, StartSport may process Personal Data based on one or more legally recognised grounds, including:
a\. the Data Subject's consent;
b\. performance of a contract;
c\. taking steps requested before entering into a contract;
d\. compliance with legal obligations;
e\. protection of legitimate interests where legally permitted;
f\. prevention of fraud and security threats;
g\. protection of rights and property;
h\. compliance with governmental or regulatory requirements; and
i\. other lawful grounds recognised under Applicable Law.
The applicable legal basis may vary depending on the specific processing activity.
**23. CONSENT**
Where processing is based on consent:
**23.1**
Consent must be provided through an appropriate mechanism.
**23.2**
The User may withdraw consent where permitted by Applicable Law.
**23.3**
Withdrawal of consent does not invalidate processing lawfully conducted before withdrawal.
**23.4**
Withdrawal of consent may affect StartSport's ability to provide certain services.
**24. DATA SHARING**
StartSport may share Personal Data where necessary and legally permitted with:
- Internship Providers;
- Universities;
- payment providers;
- identity verification providers;
- cloud service providers;
- hosting providers;
- analytics providers;
- communication providers;
- security providers;
- fraud prevention providers;
- customer support providers;
- professional advisers;
- auditors;
- legal advisers;
- insurers;
- regulators;
- governmental authorities;
- courts;
- law enforcement authorities; and
- other service providers or parties where legally permitted.
**25. SHARING WITH INTERNSHIP PROVIDERS**
When a Student applies for an Internship Opportunity, StartSport may provide the relevant Internship Provider with information reasonably necessary to evaluate and administer the Application.
This may include:
- name;
- contact information;
- CV;
- educational information;
- professional information;
- Application responses;
- relevant documents;
- eligibility information;
- assessment information; and
- other information reasonably required for the Internship Opportunity.
StartSport will seek to limit disclosures to information reasonably necessary for the relevant purpose, subject to the Platform's functionality and Applicable Law.
**26. SHARING WITH UNIVERSITIES**
Where appropriate and legally permitted, StartSport may provide authorised University representatives with Student information relevant to the University's use of StartSport.
The scope of information available to a University may depend on:
- the University's contractual arrangement with StartSport;
- Student permissions;
- applicable law;
- Platform configuration;
- the purpose for which the information is required; and
- the University's role.
**27. SERVICE PROVIDERS**
StartSport may appoint third-party service providers to perform functions such as:
- cloud hosting;
- data storage;
- payment processing;
- identity verification;
- analytics;
- cybersecurity;
- communications;
- email delivery;
- SMS delivery;
- customer support;
- fraud detection;
- AI services;
- software development;
- infrastructure management; and
- technical support.
Such providers may process Personal Data only to the extent necessary for the services they provide and subject to applicable contractual and legal requirements.
**28. CORPORATE TRANSACTIONS**
If StartSport is involved in:
- a merger;
- acquisition;
- investment;
- restructuring;
- financing;
- sale of assets;
- sale of shares;
- joint venture;
- insolvency; or
- similar corporate transaction,
Personal Data may be transferred or disclosed as part of the transaction where legally permitted.
**29. LEGAL DISCLOSURES**
StartSport may disclose Personal Data where reasonably necessary to:
- comply with Applicable Law;
- comply with a court order;
- comply with governmental requests;
- protect StartSport's legal rights;
- enforce contracts;
- investigate fraud;
- investigate security incidents;
- prevent unlawful activity;
- protect Users;
- protect the public; or
- defend against legal claims.
**30. INTERNATIONAL DATA TRANSFERS**
StartSport may use service providers or partners located outside Egypt.
Accordingly, Personal Data may be transferred, stored, accessed, or processed outside the User's country.
Where Applicable Law requires specific conditions or approvals for international transfers, StartSport will implement the legally required safeguards.
**31. DATA SECURITY**
StartSport may implement appropriate technical and organisational measures designed to protect Personal Data against:
- unauthorised access;
- unauthorised disclosure;
- accidental loss;
- destruction;
- alteration;
- misuse;
- unlawful processing;
- security breaches; and
- other foreseeable risks.
Security measures may include:
- access controls;
- authentication;
- encryption where appropriate;
- monitoring;
- logging;
- backups;
- role-based access;
- security testing;
- incident management; and
- other appropriate controls.
However, no digital system can guarantee absolute security.
**32. USER RESPONSIBILITY FOR SECURITY**
Users must:
- maintain password confidentiality;
- use secure passwords;
- avoid sharing login credentials;
- protect personal devices;
- log out where appropriate;
- notify StartSport of suspected unauthorised access; and
- comply with security instructions.
StartSport is not responsible for security incidents caused by a User's failure to protect Account credentials or comply with reasonable security requirements, except where Applicable Law provides otherwise.
**33. DATA RETENTION**
StartSport will retain Personal Data for as long as reasonably necessary for the purposes for which it was collected, including:
- providing services;
- maintaining Accounts;
- administering Applications;
- complying with legal obligations;
- resolving disputes;
- enforcing agreements;
- preventing fraud;
- maintaining business records;
- protecting legal rights; and
- other lawful purposes.
Retention periods may vary depending on:
- the nature of the information;
- the purpose of processing;
- legal requirements;
- contractual requirements;
- dispute periods;
- security requirements; and
- legitimate business requirements.
**34. ACCOUNT DELETION**
Users may request closure of their Account through the available StartSport process.
Account deletion may not result in immediate deletion of all Personal Data where StartSport is legally permitted or required to retain certain information.
StartSport may retain information where necessary for:
- legal compliance;
- fraud prevention;
- security;
- dispute resolution;
- enforcement;
- accounting;
- audit;
- regulatory requirements; or
- other lawful purposes.
**35. DATA SUBJECT RIGHTS**
Subject to Applicable Law, Data Subjects may have rights relating to their Personal Data, including rights to:
- obtain information regarding processing;
- access Personal Data;
- request correction of inaccurate Personal Data;
- request updating of Personal Data;
- request deletion where legally available;
- object to certain processing;
- withdraw consent where processing relies on consent;
- request restriction of processing where legally available;
- exercise other rights provided by Applicable Law; and
- lodge complaints with the competent authority where legally available.
These rights may be subject to statutory exceptions, limitations, verification requirements, or other legal conditions.
**36. HOW TO EXERCISE DATA RIGHTS**
Requests relating to Personal Data should be submitted to:
**Privacy / Data Protection Department**
Email: osakr@startsport.co
Address: startsport.co
StartSport may request reasonable information necessary to verify the identity of the requesting person.
StartSport may reject or restrict a request where permitted or required by Applicable Law.
**37. IDENTITY VERIFICATION FOR DATA REQUESTS**
To protect Users and prevent unauthorised disclosure, StartSport may require reasonable verification before processing a Data Subject request.
The information requested for verification will be limited, where reasonably possible, to information necessary to establish the identity and authority of the requester.
**38. MARKETING COMMUNICATIONS**
Where permitted by Applicable Law, StartSport may send communications concerning:
- Platform services;
- Internship Opportunities;
- new features;
- events;
- promotions;
- educational content;
- newsletters;
- partnership announcements; and
- other relevant communications.
Where required, StartSport will provide an appropriate mechanism to opt out of marketing communications.
**39. SERVICE COMMUNICATIONS**
Even if a User opts out of marketing communications, StartSport may continue sending essential service-related communications, including:
- security alerts;
- Account notices;
- Application updates;
- payment confirmations;
- changes to Terms;
- changes to Privacy Policy;
- service notices;
- legal notices; and
- other communications necessary to administer the User's Account.
**40. COOKIES**
StartSport may use cookies and similar technologies to:
- operate the Platform;
- maintain sessions;
- remember preferences;
- authenticate Users;
- improve performance;
- analyse usage;
- detect fraud;
- provide personalised functionality; and
- support marketing where legally permitted.
Additional information may be provided in StartSport's Cookie Policy.
**41. ANALYTICS**
StartSport may use analytics technologies to understand:
- Platform usage;
- user behaviour;
- feature performance;
- technical performance;
- traffic;
- conversion;
- Application activity;
- errors; and
- general Platform trends.
Analytics may involve third-party providers.
**42. PROFILING**
StartSport may use Personal Data to create profiles or segments for purposes such as:
- opportunity recommendations;
- user experience personalisation;
- fraud detection;
- security;
- analytics;
- Platform improvement; and
- marketing where legally permitted.
Where profiling has legal or similarly significant effects, StartSport will apply any additional requirements imposed by Applicable Law.
**43. AUTOMATED DECISION-MAKING**
StartSport may use automated systems as part of:
- eligibility screening;
- recommendations;
- fraud detection;
- content moderation;
- risk assessment;
- security;
- application administration; and
- other Platform processes.
Unless expressly stated otherwise, automated recommendations do not by themselves constitute a guarantee of acceptance or rejection.
Where Applicable Law grants a Data Subject specific rights concerning automated decision-making, those rights shall apply subject to applicable legal conditions.
**44. STUDENT DOCUMENTS**
Students may upload documents including:
- CVs;
- identification documents;
- certificates;
- university documents;
- passports;
- application forms;
- photographs;
- professional records; and
- other supporting documents.
Students must ensure that they have the right to provide such documents.
StartSport may reject documents that appear:
- fraudulent;
- incomplete;
- corrupted;
- unlawful;
- irrelevant;
- misleading; or
- otherwise unsuitable.
**45. SENSITIVE OR SPECIAL CATEGORIES OF DATA**
StartSport may avoid collecting sensitive or special categories of Personal Data unless reasonably necessary and legally permitted.
Where such information is required for a legitimate Platform purpose, StartSport will process it in accordance with Applicable Law and any additional safeguards required by law.
Users should not upload sensitive information unless StartSport expressly requests it or the information is necessary for the relevant service.
**46. CHILDREN AND MINORS**
StartSport may offer certain services or Internship Opportunities to persons below the age of majority.
Where required by Applicable Law, StartSport may require:
- parental consent;
- guardian consent;
- University authorisation;
- additional verification; or
- other safeguards.
StartSport may restrict or refuse access to services where the required consent or safeguards are unavailable.
**47. THIRD-PARTY LINKS**
StartSport may contain links to external websites and services.
StartSport does not control the privacy practices of third parties.
Users should review the relevant third party's privacy policy before submitting Personal Data.
**48. SOCIAL MEDIA**
StartSport may operate or integrate with social media platforms.
Interactions with social media platforms may be subject to the relevant platform's own privacy policies and terms.
**49. DATA BREACHES AND SECURITY INCIDENTS**
If StartSport becomes aware of a Personal Data breach or security incident, StartSport may:
- investigate the incident;
- contain the incident;
- assess the impact;
- implement remediation measures;
- notify relevant authorities where required;
- notify affected Data Subjects where required;
- preserve relevant records; and
- take other legally required or reasonably necessary measures.
**50. FRAUD PREVENTION**
StartSport may process Personal Data to detect and prevent:
- fraudulent Accounts;
- fake Applications;
- identity fraud;
- payment fraud;
- document fraud;
- duplicate Accounts;
- abuse;
- platform manipulation;
- cyberattacks; and
- other unlawful or harmful activity.
Such processing may include automated tools and human investigation.
**51. LAW ENFORCEMENT AND GOVERNMENT REQUESTS**
Where legally required or permitted, StartSport may disclose Personal Data to:
- law enforcement;
- courts;
- regulators;
- government authorities;
- public bodies; and
- other competent authorities.
StartSport may also preserve information where necessary to comply with legal obligations or protect its rights.
**52. PROFESSIONAL ADVISERS**
StartSport may disclose relevant Personal Data to:
- lawyers;
- auditors;
- accountants;
- insurers;
- consultants;
- professional advisers; and
- other advisers
where reasonably necessary for legitimate business, legal, regulatory, accounting, insurance, or corporate purposes and as permitted by Applicable Law.
**53. DATA ACCURACY**
Users are responsible for ensuring that Personal Data supplied to StartSport is:
- accurate;
- complete;
- current; and
- not misleading.
Users should update information when it changes.
StartSport may rely on information provided by Users, Universities, Internship Providers, or authorised third parties unless StartSport has reason to believe the information is inaccurate.
**54. DATA MINIMISATION**
StartSport will seek, where reasonably practicable, to collect Personal Data that is relevant to the purposes for which it is processed.
However, the precise information required may vary depending on:
- the Internship Opportunity;
- the User type;
- the country;
- the University;
- the Internship Provider;
- legal requirements; and
- Platform functionality.
**55. DATA OWNERSHIP**
Personal Data remains subject to the rights and protections applicable to the Data Subject under Applicable Law.
Nothing in this Privacy Policy transfers ownership of Personal Data to StartSport.
StartSport receives the rights necessary to lawfully process Personal Data for the purposes described in this Privacy Policy and applicable agreements.
**56. USER-GENERATED CONTENT**
Where Users submit:
- photographs;
- videos;
- reviews;
- comments;
- CVs;
- profiles;
- biographies;
- application responses; or
- other Content,
StartSport may process and display that Content as necessary to provide the relevant Platform service and as otherwise permitted by the applicable Terms and Applicable Law.
**57. PUBLIC PROFILES**
Where StartSport provides public or semi-public profile functionality, certain User information may be visible to other Users or authorised parties.
Users should not include information in a public profile that they do not wish to make available through the relevant Platform functionality.
StartSport may provide controls allowing Users to manage certain profile visibility settings.
**58. UNIVERSITY VISIBILITY**
Where a Student is associated with a University using StartSport, certain Student information may be visible to authorised University representatives where permitted by the relevant University arrangement, Student permissions, Platform functionality, and Applicable Law.
**59. INTERNSHIP PROVIDER VISIBILITY**
Where a Student applies for an Internship Opportunity, relevant Student information may be made available to the Internship Provider for the purpose of evaluating and administering the Application.
**60. DATA PROCESSING AGREEMENTS**
Where StartSport processes Personal Data on behalf of a University, Sports Organisation, or other organisation in a legally recognised processor capacity, the parties may enter into an appropriate Data Processing Agreement.
Such agreement may establish:
- processing instructions;
- security requirements;
- confidentiality;
- sub-processors;
- international transfers;
- breach notification;
- retention;
- deletion;
- audit;
- data subject rights assistance; and
- other required matters.
**61. SUB-PROCESSORS**
StartSport may use third-party service providers that process Personal Data on StartSport's behalf.
StartSport may maintain a list of relevant categories or specific sub-processors where required by Applicable Law or contractual commitments.
**62. INTERNATIONAL PARTNERS**
Because StartSport may facilitate internships across multiple countries, Personal Data may need to be shared with authorised organisations outside Egypt.
Such disclosures will be handled in accordance with Applicable Law and the applicable contractual and operational requirements.
**63. DATA RETENTION AFTER ACCOUNT TERMINATION**
Closing an Account does not necessarily require immediate deletion of all related information.
StartSport may retain information where reasonably necessary for:
- legal obligations;
- contractual obligations;
- financial records;
- fraud prevention;
- security;
- disputes;
- investigations;
- enforcement;
- regulatory requirements;
- audit requirements; or
- legitimate business purposes where legally permitted.
**64. BACKUPS**
Deleted information may remain temporarily within backup systems until the relevant backup cycle expires or the information is securely overwritten.
StartSport may retain backup copies where reasonably necessary for security, disaster recovery, legal compliance, or business continuity.
**65. BUSINESS RECORDS**
StartSport may retain records relating to:
- Applications;
- payments;
- contracts;
- communications;
- transactions;
- Account activity;
- consent records;
- disputes;
- complaints;
- security incidents; and
- legal matters
for the periods reasonably necessary to satisfy legal, contractual, operational, security, accounting, or evidentiary requirements.
**66. CHANGES TO THIS PRIVACY POLICY**
StartSport may update this Privacy Policy from time to time.
Changes may be made to reflect:
- legal requirements;
- regulatory developments;
- Platform changes;
- new services;
- new technologies;
- changes in data processing;
- security improvements; or
- business developments.
The updated version will indicate the applicable effective date.
Where legally required, StartSport will provide additional notice or obtain consent.
**67. ACCEPTANCE OF UPDATED PRIVACY POLICY**
Where continued use of StartSport constitutes lawful acceptance of an updated Privacy Policy, continued use after the effective date may constitute acceptance.
Where consent is legally required for a material change, StartSport will obtain the required consent.
**68. PRIVACY COMPLAINTS**
Users may contact StartSport regarding privacy concerns, data processing, or Personal Data requests.
**Privacy Department**
Email: osakr@startsport.co
StartSport will review complaints and respond in accordance with Applicable Law and its internal procedures.
**69. REGULATORY COMPLAINTS**
Nothing in this Privacy Policy prevents a Data Subject from exercising any statutory right to submit a complaint to a competent data protection authority.
**70. SECURITY AND COMPLIANCE COOPERATION**
Users agree to cooperate reasonably with StartSport in relation to:
- security investigations;
- fraud investigations;
- identity verification;
- data protection requests;
- legal compliance;
- dispute resolution; and
- Platform security.
**71. NO ABSOLUTE SECURITY GUARANTEE**
While StartSport may implement security measures, no method of transmission, storage, processing, or electronic communication can be guaranteed to be completely secure.
Users acknowledge the inherent risks associated with internet-based services.
**72. PRIVACY OF COMMUNICATIONS**
Communications with StartSport may be stored or reviewed where reasonably necessary for:
- customer support;
- quality assurance;
- security;
- fraud prevention;
- training or improvement of support systems where legally permitted;
- legal compliance;
- dispute resolution; and
- other legitimate purposes.
Where required by law, StartSport will provide appropriate notice or obtain consent.
**73. RECORDING OF CALLS**
Where legally permitted and appropriately notified, StartSport may record or monitor calls for:
- quality assurance;
- training;
- security;
- fraud prevention;
- dispute resolution; and
- compliance.
**74. EMAIL AND ELECTRONIC COMMUNICATION**
By using StartSport, Users acknowledge that StartSport may communicate electronically regarding:
- Accounts;
- Applications;
- payments;
- Internship Opportunities;
- security;
- legal notices;
- Platform updates;
- customer service; and
- other relevant matters.
Electronic communications may constitute valid communications where permitted by Applicable Law.
**75. PRIVACY BY DESIGN**
StartSport may consider privacy and security requirements when designing:
- Platform functionality;
- databases;
- user interfaces;
- Application workflows;
- University dashboards;
- Sports Organisation dashboards;
- AI systems;
- analytics systems; and
- other services.
**76. ACCESS CONTROL**
StartSport may restrict internal access to Personal Data based on:
- role;
- business need;
- authorisation;
- security requirements;
- contractual obligations; and
- Applicable Law.
**77. EMPLOYEE AND CONTRACTOR ACCESS**
StartSport may permit authorised employees, contractors, consultants, and service providers to access Personal Data where reasonably necessary to perform their duties.
Such access may be subject to confidentiality and security obligations.
**78. THIRD-PARTY RESPONSIBILITY**
Where Personal Data is transferred to an independent third party acting as its own controller, that third party may process the information according to its own legal obligations and privacy policy.
StartSport is not responsible for independent processing conducted by third parties outside StartSport's control, except where liability is imposed by Applicable Law.
**79. USER RESPONSIBILITY FOR THIRD-PARTY DISCLOSURES**
Users should carefully consider information uploaded to StartSport where that information may subsequently be disclosed to:
- Universities;
- Internship Providers;
- service providers;
- authorised partners; or
- other recipients disclosed through the Platform.
Users should not upload information that they do not have the right to disclose.
**80. DATA PROTECTION CONTACT**
For all data protection matters:
**StartSport Data Protection / Privacy Department**
**Email:** osakr@startsport.co
Where StartSport appoints a formal Data Protection Officer or equivalent privacy officer, the relevant contact details may be published here.
**81. CONTROLLING VERSION**
The English version of this Privacy Policy shall be the controlling version unless Applicable Law requires otherwise.
Where StartSport publishes translated versions, translations are provided for convenience unless otherwise stated.
**82. GOVERNING LAW**
This Privacy Policy shall be governed by the laws of the Arab Republic of Egypt.
**83. SEVERABILITY**
If any provision of this Privacy Policy is found invalid or unenforceable, the remaining provisions shall continue in effect to the extent permitted by Applicable Law.
**84. ENTIRE PRIVACY FRAMEWORK**
This Privacy Policy should be read together with:
1. StartSport Terms & Conditions;
2. StartSport Cookie Policy;
3. StartSport Refund Policy;
4. StartSport Community Guidelines;
5. applicable Internship Opportunity terms;
6. University agreements;
7. Sports Organisation agreements; and
8. Data Processing Agreements where applicable.
**85. FINAL ACKNOWLEDGEMENT**
BY USING STARTSPORT, CREATING AN ACCOUNT, SUBMITTING AN APPLICATION, PROVIDING PERSONAL DATA, OR OTHERWISE USING THE PLATFORM, THE USER ACKNOWLEDGES THAT:
1. THE USER HAS READ THIS PRIVACY POLICY;
2. THE USER UNDERSTANDS HOW STARTSPORT MAY PROCESS PERSONAL DATA;
3. THE USER UNDERSTANDS THAT PERSONAL DATA MAY BE SHARED WITH RELEVANT UNIVERSITIES, INTERNSHIP PROVIDERS, AND SERVICE PROVIDERS WHERE LAWFULLY NECESSARY;
4. THE USER UNDERSTANDS THAT INTERNATIONAL INTERNSHIP SERVICES MAY REQUIRE INTERNATIONAL DATA TRANSFERS;
5. THE USER UNDERSTANDS THAT STARTSPORT MAY USE AUTOMATED SYSTEMS AND ARTIFICIAL INTELLIGENCE;
6. THE USER UNDERSTANDS THAT CERTAIN DATA PROCESSING MAY BE NECESSARY TO PROVIDE STARTSPORT SERVICES;
7. THE USER UNDERSTANDS THAT CERTAIN INFORMATION MAY BE RETAINED AFTER ACCOUNT CLOSURE WHERE LAWFULLY NECESSARY; AND
8. THE USER ACKNOWLEDGES THAT THIS PRIVACY POLICY MAY BE UPDATED FROM TIME TO TIME IN ACCORDANCE WITH ITS TERMS AND APPLICABLE LAW.
**86. DOCUMENT CONTROL**
**Document:** StartSport Privacy Policy
**Version:** 1.0
**Effective Date:** September 22, 2026
**Last Updated:** September 22, 2026
**Owner:** StartSport Legal / Data Protection Department
**END OF PRIVACY POLICY**