Effective date: 30 June 2026 · Last updated: 30 June 2026
1. Who we are
Clubble LLC (“Clubble”, “we”, “us”, “our”) operates the Clubble mobile app, website and related services (the “Platform”). We are incorporated and licensed in Sharjah Media City (licence no. 2539056.01). Contact: privacy@clubble.ae.
2. Scope and applicable law
This Policy explains what personal data we collect, how and why we use it, who we share it with, how long we keep it, and your rights under the UAE Personal Data Protection Law (PDPL) and its Executive Regulations, Federal Law No. 3 of 2016 on Child Rights (Wadeema’s Law) and Federal Decree-Law No. 26 of 2025 on Child Digital Safety.
3. Our roles (controller vs processor)
Controller (Clubble). Account, billing metadata from app stores, security, moderation, analytics and logs.
Processor (Clubble) for clubs. For club-uploaded media (photos and videos) and personal data contained within it, the club is the data controller and Clubble acts as its data processor by hosting and displaying content on the club’s instructions. The exception is when we remove or restrict content for safety or moderation, in which case we act as an independent controller for that limited purpose.
Controller (academy) for Leads. Where a parent’s enquiry and contact details are shared with an academy on a paid tier (a Lead), the academy is the independent data controller for that data and is responsible for handling it lawfully.
Clubs using the Platform accept the data-processing terms in our Terms and Conditions (§9A).
4. What we collect
We aim to collect the minimum necessary:
- Account and identity data. Name, email, phone number, password hash, user role (parent, minor, club, admin).
- Club profile data. Club name, logo, sport, emirate, Nominated Contact Methods (email, WhatsApp, Instagram), licence details (number, issuer, expiry), coach biography text the club provides.
- Parent enquiry data. When a parent sends an enquiry to an academy through the Platform, the parent’s name, contact details and the enquiry message.
- Media. Photos and videos that clubs upload to their profiles (may include faces, uniforms, locations).
- Declaration logs (no consent files by default). Timestamped records that a club declared (i) up-to-date coach checks and training, and (ii) parent or guardian consent exists for any identifiable minor in media, including promotional placements; plus the device, IP and user ID of the declarant.
- Reports and moderation data. Details you submit via the Report button or email (who is in the image, why you reported, your contact), our review notes, decision and timestamps.
- Device and usage data. Device identifiers, IP address, OS and app version, general location (city or region), crash and diagnostic logs, screens viewed and interactions. Used to secure and improve the Platform.
- Purchases and billing metadata. Plan type (Free, Essential or Featured; annual), renewal status and receipts as provided by the Apple App Store or Google Play. We do not store full card numbers.
- Optional child data. A child’s age group if a parent or guardian chooses to provide it in their account.
4A. Unclaimed academy profiles and shortlists
To help parents discover academies, we may publish a basic unclaimed profile for an academy that has not registered. An unclaimed profile shows only the academy name, the sport and a general area, taken only from publicly available information. It contains no personal data of any parent or child.
We do not run lead generation on unclaimed profiles. We do not collect, capture, hold, promise or share any parent enquiry or parent data in connection with an unclaimed profile, and there is no enquiry button on it.
A parent may save an academy, including an unclaimed academy, to a personal shortlist. A shortlist is stored only against that parent’s own account and is not shared with the academy. It sends nothing to the academy.
5. Sources of data
- You, when creating an account, using the app, sending an enquiry or filing a report.
- Clubs, when setting up profiles and uploading media.
- Publicly available sources, for the basic information shown on unclaimed academy profiles.
- Your device, for diagnostics and usage.
- Apple App Store and Google Play, for subscription metadata.
6. Why we use data (PDPL legal bases)
We process personal data where one or more bases apply:
- Contract. To provide accounts, listings, enquiries, purchases and support.
- Consent. For optional items such as marketing or child age group. You can withdraw consent at any time.
- Legal obligation. To comply with UAE law, including child safeguarding and responding to lawful requests.
- Legitimate interests. Platform security, fraud prevention, service improvement, and ensuring reported content is handled promptly and fairly, balanced against your rights.
7. How we use data
- Create and manage user and club accounts; display club profiles and media.
- Receive parent enquiries and, on paid tiers, pass them to the relevant academy as a Lead.
- Record club self-declarations for coach compliance and parental consent (no consent files by default).
- Run reporting and takedown workflows (acknowledge, review, action, appeal) and keep audit trails.
- Operate subscriptions via app-store SDKs and maintain entitlement status.
- Secure the Platform, diagnose issues, prevent abuse and improve performance.
- Send essential service emails and notifications (receipts, plan changes, policy updates).
8. Children’s privacy and safeguarding
- The Platform does not provide in-app messaging. Minors may browse under a parent or guardian’s supervision but must not contact clubs directly. Only a parent or guardian may use the listed Nominated Contact Methods.
- We do not collect personal data directly from children. Any data relating to a child is provided by their parent or guardian, for example an optional age group in the parent’s account or details a parent chooses to include in an enquiry, and is processed on that basis.
- Clubs may upload media showing minors only where they have obtained verifiable parent or guardian consent off-platform and have made the required declaration in the upload flow.
- We handle children’s data in line with Wadeema’s Law and the Child Digital Safety Law (Federal Decree-Law No. 26 of 2025).
- Parents and guardians may withdraw consent at any time. See §10 Reporting and takedown and §13 Your rights.
9. Sharing your data
We do not sell personal data. We share it only as needed:
- Service providers (processors). Firebase (Google Cloud) for authentication, database, file storage, logging and crash reports. Where used, a transactional email provider.
- Academies (paid tiers). On the Essential and Featured tiers we share a parent’s enquiry and contact details (a Lead) with the academy the parent enquired about, so the academy can respond. On a Free Listing we do not share the parent’s details with the academy. We share no enquiry data for unclaimed profiles because none is collected.
- App stores. Apple and Google receive purchase and renewal data and handle payments. Their privacy policies apply to store accounts.
- Legal and safety. Competent authorities when required by law or to protect users, especially minors.
- Other users. Information you choose to publish on your club profile (name, logo, media, contact methods) is visible to other users.
10. Reporting and takedown (photos and videos)
Any user can flag a photo or video in the app for removal at any time. If you see your child, or yourself, in media without consent:
- Use the in-app Report button on the item, or email report@clubble.ae.
- We send an automated receipt within 1 hour (report ID).
- Child-safety reports are reviewed within 24 hours; other reports within 72 hours.
- Outcomes: removal, restrict and verify (temporarily hidden while we ask the club for proof), or retain (with a brief explanation).
- Clubs must produce proof of consent on request (24 hours for child-safety, 72 hours otherwise) or face suspension or removal under the Terms.
- We keep an audit log of the report and outcome for five (5) years.
11. International transfers
We primarily host on Firebase (Google Cloud) in regions selected to minimise distance from the UAE (for example Mumbai or Frankfurt). Where data is transferred internationally, we apply appropriate safeguards (contractual terms with processors, security measures). You can request details at privacy@clubble.ae.
12. Security
- Encryption in transit (TLS 1.2+) and at rest (AES-256).
- Role-based access, least-privilege and access logging.
- Sensitive screens may block screenshots or recordings where technically feasible.
- Regular reviews of access and staff training.
13. Your rights (PDPL)
You may access your data and request a copy, correct inaccuracies, delete your data (subject to lawful retention), port your data (machine-readable format), object to processing in certain cases, and withdraw consent (where processing relies on consent).
How to exercise. Use the in-app “Privacy Request” form or email privacy@clubble.ae. We may verify your identity (for example a one-time code). We aim to acknowledge within 3 business days, delete or correct within 15 business days, and export within 20 business days. You may also complain to the UAE Data Office.
14. Retention
- Accounts and club profiles: while your account is active and up to 6 years after closure (tax and dispute defence).
- Parent enquiries and Leads: while needed to handle the enquiry and for a reasonable period afterwards for dispute and record purposes, then deleted or anonymised.
- Declaration logs and moderation records: while related media or profile is live, and for at least 2 years after removal or closure.
- System logs and diagnostics: typically 12 to 24 months unless needed longer for security.
When retention ends, we delete or anonymise data.
15. Cookies, SDKs and app permissions
- Web cookies and local storage: essential (login and security) and limited analytics if enabled.
- Mobile SDKs: Firebase Auth, Database, Storage and Crashlytics, plus app-store billing SDKs.
- Permissions: camera, photos and media library (when you upload), notifications (service messages), approximate location (if you allow, to improve search). You can change permissions in your device settings.
16. Payments
All purchases are processed by the Apple App Store (iOS) or Google Play (Android). We receive subscription status and limited purchase metadata from the store. We do not store payment card details. For refunds or cancellations, use your store account settings.
17. Third-party links
Club profiles may list external links, for example WhatsApp or Instagram. Those services are governed by their own privacy policies. We are not responsible for their practices.
18. Changes to this policy
We may update this Policy from time to time. If changes are material, we will notify you by email or in-app at least 14 days before they take effect. The “Last updated” date shows the latest version.
19. Contact
Data protection: privacy@clubble.ae
Reports (photos and videos): report@clubble.ae
Listing removal (unclaimed profiles): support@clubble.ae
General: support@clubble.ae
Clubble LLC, Sharjah Media City, PO Box 839, Sharjah, United Arab Emirates
App Store and Google Play at-a-glance summary
- Data collected. Account and identity, club profile info, parent enquiry data, media uploaded by clubs, declaration logs, device and usage, subscription status from app stores, report submissions.
- Purposes. Provide and secure the service; display club profiles and media; route parent enquiries to academies on paid tiers; handle reports and takedowns; manage subscriptions; improve reliability.
- Data linked to the user. Account and identity, device and usage (for security), parent enquiry data, report submissions, subscription status.
- Sharing. Service providers (Firebase), academies on paid tiers (Leads), app stores (Apple and Google), authorities if legally required. No sale of data.
- Security. Encryption in transit and at rest; role-based access; audit logging.
- Retention and deletion. See §§14 and 13 (you can request deletion or export).
- Children. Browsing allowed under guardian supervision; no direct contact with clubs by minors; no data collected directly from children; clubs must have guardian consent for minor media and declare it at upload.