1. Who we are Controller
CoachCraft is operated by:
Groninger Meeuwlaan 89, Barneveld, Netherlands
KVK registration: 82520313
Data protection contact: admin@rugbycraft.com
RugbyGo is the data controller for all personal data processed through the CoachCraft platform.
2. What data we collect
| Category | Examples | Source |
|---|---|---|
| Account data | Name, email address, role, club affiliation | Provided by the user on registration |
| Coaching content | Session plans, drills, team structures, attendance | Entered by coaches within the platform |
| Player records | Player name, position, performance notes | Entered by club administrators or coaches |
| Health & injury data | Wellness scores, injury details, rehabilitation notes | Entered by authorised coaches only, with explicit player consent |
| Usage data | Login timestamps, feature access logs, IP address | Collected automatically by the platform |
| Website statistics | Anonymous daily totals of page views, the site a visit came from, device type, how far pages are scrolled and which buttons are clicked. No cookies, no IP address kept, nothing that identifies you | Collected automatically on rugbycraft.com |
3. Legal basis for processing
| Processing activity | Legal basis | GDPR article |
|---|---|---|
| Account management and core platform access | Contract — necessary to provide the service you signed up for | Art. 6(1)(b) |
| Player performance records and coaching tools | Contract — core functionality of the platform | Art. 6(1)(b) |
| Health and injury data recording | Explicit consent — required separately from the player before recording | Art. 9(2)(a) |
| AI-assisted session planning | Legitimate interest — coaching assistance tools; no personal player data transmitted | Art. 6(1)(f) |
| Security audit logs | Legal obligation — maintaining records of data access | Art. 6(1)(c) |
| Responding to data subject rights requests | Legal obligation | Art. 6(1)(c) |
4. How we use your data
We use the data we collect to:
- Provide, maintain, and improve the CoachCraft platform
- Enable clubs to manage coaching sessions, player rosters, and team administration
- Support coaches in tracking player wellness and injury recovery (with player consent)
- Provide optional AI-assisted coaching features: an in-portal coaching assistant, and written player development reports generated from the skill ratings a coach has already recorded
- Maintain security audit logs and comply with legal obligations
- Communicate with you about your account and material changes to this policy
We do not use your data for advertising, profiling for commercial purposes, or any purpose incompatible with those listed above.
5. Data sharing and sub-processors
We share personal data only with the sub-processors listed below, each engaged under a written Data Processing Agreement:
| Sub-processor | Purpose | Location | Transfer mechanism |
|---|---|---|---|
| Google LLC (Firebase / Google Cloud) | Platform infrastructure, database, authentication, file storage | Data at rest: EU multi-region eur3 (Belgium and the Netherlands). Backend processing: EU (europe-west1, Belgium). Sign-in service (Firebase Authentication): United States. See section 6. |
Google Cloud DPA. Storage and processing of your team data within the EU. For the sign-in service only: EU-US Data Privacy Framework and Standard Contractual Clauses |
| Anthropic PBC | Optional AI coaching assistant and AI-drafted player development reports. Enabled only where a club supplies its own Anthropic API key; requests are sent directly from the coach’s browser to Anthropic and do not pass through CoachCraft servers. | USA | Standard Contractual Clauses (SCCs); Anthropic Data Processing Addendum (effective 24 Feb 2025). No player names, contact details, health or injury data are transmitted. See section 10. |
We do not sell personal data. We do not share data with third parties for their own marketing purposes.
6. International transfers
Storage. All personal data held in the CoachCraft database is stored in Google Cloud’s eur3 multi-region, which spans data centres in Belgium and the Netherlands. It does not leave the EU at rest.
Processing. All of our backend jobs that act on that data run in Google Cloud’s europe-west1 region in Belgium. This includes the personal data export used to answer access and portability requests, the deletion plan job used to answer erasure requests, the physiotherapy and wellness digest e-mails, the calendar feed, the payment webhook and every notification and scheduled job. None of your team, performance, development or health data is processed in the United States by us or by Google on our behalf.
Sign-in. One exception applies to the service that signs you in. Firebase Authentication, the Google service that checks your email address and password, is operated by Google only from data centres in the United States. The data that service holds is your email address, a hashed form of your password, your account identifier, your sign-in provider, the times you signed in and the network address you signed in from. Nothing else about you passes through it. The transfer is covered by Google’s certification under the EU-US Data Privacy Framework and by the Standard Contractual Clauses in the Google Cloud Data Processing Addendum. We will move to an EU-resident sign-in service if Google makes one available on our platform.
Page delivery and request verification. Two further Google services sit in front of the platform and run on Google’s global infrastructure rather than in a fixed region. Firebase Hosting delivers the portal pages; the pages themselves contain no personal data, but Google records the network address of each request to detect abuse and to report usage, and retains those addresses for a few months. Firebase App Check confirms that each request comes from the genuine CoachCraft portals; the attestation it performs is not retained, and the short-lived token it issues is tied to a device and is kept for at most thirty days for replay protection. Neither service carries any of the data described in section 4. Both are covered by the same Data Privacy Framework certification and Standard Contractual Clauses.
Until 13 September 2026 a number of these jobs ran in Google Cloud’s us-central1 region in Iowa, United States, under Google’s certification under the EU–US Data Privacy Framework and the Standard Contractual Clauses in the Google Cloud Data Processing Addendum. That processing has ended and the corresponding functions have been deleted. Database access logs are held in Google Cloud Logging with a copy in an EU log bucket.
Separately, where a club enables the optional AI features, the content of those requests is processed by Anthropic in the United States. This transfer is covered by Standard Contractual Clauses (EU Commission Decision 2021/914, Module Two: controller to processor), incorporated into the Anthropic Data Processing Addendum.
No Special Category (health or injury) data is included in requests to Anthropic.
7. Data retention
| Data type | Retention period | Reason |
|---|---|---|
| Account data | Duration of account + 2 years | Contractual and legal basis |
| Coaching session records | Duration of club subscription + 2 years | Operational necessity |
| Player records (non-health) | Duration of active membership + 2 years | Operational necessity |
| Health & injury records | Duration of active membership + 3 years | Welfare duty of care; legal claims window |
| Security audit logs | 3 years | GDPR Art. 5(2) accountability; incident investigation |
| Consent records | Duration of processing + 6 years | Evidentiary record of lawful processing |
| AI request content (assistant and development reports) | Not retained by Anthropic beyond the immediate response | Zero-retention API configuration |
Deletion at the end of the retention period is not yet automated. Until it is, we delete that data by hand, working from a deletion plan that lists every record held about the person concerned. We follow the same process when you ask us to delete your data (see section 8). Health and injury records are always checked by a person before they are deleted, because clinical record keeping rules may require them to be kept for longer. Backup copies expire automatically, so deleted data is gone from backups within 90 days of the deletion date. We are building automated deletion and will update this section when it is in place.
8. Your rights
Under GDPR, you have the following rights in relation to your personal data:
Access (Art. 15)
Request a copy of the personal data we hold about you.
Rectification (Art. 16)
Request correction of inaccurate or incomplete data.
Erasure (Art. 17)
Request deletion of your data where there is no overriding legal basis to retain it.
Restriction (Art. 18)
Request that we limit processing while a dispute is resolved.
Portability (Art. 20)
Receive your data in a structured, machine-readable format.
Objection (Art. 21)
Object to processing based on legitimate interest.
Withdraw consent
Where processing is based on consent, withdraw it at any time without affecting prior processing.
Complaint (Art. 77)
Lodge a complaint with your national supervisory authority.
To exercise any right, contact us at admin@rugbycraft.com. We will respond within one month.
9. Youth players (under 16)
Where youth player data is processed under a prior arrangement, parental or guardian consent is required for all data collection, and a specific DPIA must be completed before onboarding. Processing of youth player wellness or health data requires explicit parental consent.
10. AI and automated processing
CoachCraft offers two optional AI-assisted features, both in the coach portal, and both powered by Anthropic’s Claude. Neither is switched on by default: a club must add its own Anthropic API key in Settings before either will run. That key is stored in the coach’s own browser and requests go directly from the browser to Anthropic, so the content of an AI request never passes through CoachCraft servers.
- Coaching assistant. A chat assistant for coaching questions, session design and platform help. It is sent the coach’s current session plan settings, which are coaching context such as objectives, focus areas, session count and template. Anything a coach types into the free-text notes or chat box is also sent, so coaches are asked not to enter player names, health information or other personal details there.
- Player development reports. Where a coach has already recorded monthly skill ratings for a player, they can ask the AI to draft a written report from those ratings. The request contains the playing position, the numeric skill ratings and the change since the previous month. The player’s name is not transmitted; the report is matched back to the player locally, in the coach’s browser.
In both cases:
- No player names, contact details, health or injury records, or Special Category data are transmitted.
- No automated decisions with legal or similarly significant effects are made. Every output is advisory and coaching staff make all final decisions.
- Anthropic does not retain API request content beyond the immediate response.
Session plans themselves are generated by CoachCraft’s own rule-based planner, from the season phase, focus areas, templates and resources a coach selects. No AI is involved in generating a session plan, and no personal data leaves the platform when one is created.
Some clubs and unions using CoachCraft may optionally connect their own third-party AI services by configuring a club-owned API key within the platform settings. Where a club does this, CoachCraft (RugbyGo) is not the data controller or processor for the personal data submitted to that club's AI service — the club is. Clubs are solely responsible for the data protection compliance of their own AI integrations, including entering into appropriate agreements with their AI provider and ensuring data subjects are informed. RugbyGo does not access, store, or process any data submitted by a club through its own AI integration.
11. Data security
We implement the following technical and organisational security measures:
- All data encrypted in transit (TLS) and at rest (Google Cloud hardware-level encryption)
- Role-based access control enforced at the database level, not just the user interface
- Firebase App Check: every API request is verified as originating from a legitimate CoachCraft application
- Deny-by-default database rules: every data path is explicitly permitted or blocked
- Immutable server-side audit logs recording all access to sensitive and Special Category data
- Club workspace isolation: no cross-club data access is architecturally possible
In the event of a personal data breach, we will notify the Autoriteit Persoonsgegevens within 72 hours of becoming aware, and notify affected individuals without undue delay where the breach poses a high risk to their rights and freedoms.
12. Changes to this policy
We will notify all registered users of material changes to this Privacy Policy via email and in-app notification at least 14 days before changes take effect. The current version number and effective date are shown at the top of this page.
For non-material changes (formatting, typo corrections), we will update the page without advance notice. The version number will not change for non-material edits.
Change history.
- Version 1.4, 24 September 2026. Section 7 corrected: version 1.3 said that data is deleted automatically at the end of its retention period. That was wrong. Deletion is currently carried out by hand from a deletion plan, and automated deletion is still being built. Nothing about how your data is used has changed; the statement now describes what actually happens.
- Version 1.3, 14 September 2026. Section 5 and section 6 corrected: version 1.2 stated that no personal data was processed in the United States. That was wrong for the sign-in service, which Google operates only from the United States. The correction was made the day after the error was found. Section 6 also now describes the network address processing by Firebase Hosting and the device token used by Firebase App Check. Team, performance, development and health data are unaffected.
- Version 1.2, 13 September 2026. Section 5 and section 6 updated: all backend processing now takes place in the EU and the United States processing described in version 1.1 has ended. This change reduces the scope of international transfers and took effect without a notice period.
- 12 September 2026, non-material correction. Storage location corrected from
europe-west4to theeur3multi-region, which is where the data has always been held.
13. How to make a complaint
Contact us first
If you have concerns about how we handle your data, please contact us — we aim to resolve all queries within one month.
If you remain dissatisfied, you have the right to lodge a complaint with your national supervisory authority:
| Country | Authority | Website |
|---|---|---|
| Netherlands | Autoriteit Persoonsgegevens | autoriteitpersoonsgegevens.nl |
| Belgium | Gegevensbeschermingsautoriteit | gegevensbeschermingsautoriteit.be |
| Ireland | Data Protection Commission | dataprotection.ie |
| United Kingdom | Information Commissioner's Office | ico.org.uk |
| France | CNIL | cnil.fr |