Privacy Policy
Effective Date: March 3, 2026
Version 1.0
TwoRivers ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains what personal data we collect through the SportCut website and application, how we use it, and your rights under applicable data protection law, including the EU General Data Protection Regulation (GDPR).
1. Data Controller
The data controller responsible for your personal data is:
TwoRivers
Raunistulantie 31 A 10, 20300 Turku, Finland
Email: cpo@youchip.pro
2. Personal Data We Collect
We collect personal data through two distinct channels: the SportCut website and the SportCut application. The data collected in each context differs in nature and purpose.
2.1 Website — Contact & Registration Data
When you interact with the SportCut website (e.g., sign up, request information, or create an account), we collect the following personal data directly from you:
This data is provided voluntarily by you and is necessary to establish your account and communicate with you about the service.
2.2 Application — Technical & Usage Data
When you use the SportCut application, we collect technical data related to your usage of the app. This data is associated with your unique user license ID rather than your name or contact details directly. The technical data we may collect includes:
While this data is technical in nature, it can be associated with a specific individual via their unique user license ID. Therefore, it qualifies as personal data under the GDPR and is treated accordingly.
3. Legal Basis for Processing
We process your personal data on the following legal bases under Article 6 of the GDPR:
Contract performance (Art. 6(1)(b)): Processing your name, phone number, and email is necessary to provide you with the SportCut service and manage your account.
Legitimate interests (Art. 6(1)(f)): Processing technical and usage data linked to your user license ID is necessary for our legitimate interests in maintaining, improving, and securing the application.
Consent (Art. 6(1)(a)): Where we process data for purposes beyond those described above (e.g., marketing communications), we will ask for your explicit consent before doing so.
4. How We Use Your Data
We use the personal data we collect for the following purposes:
4.1 Website Data (Name, Phone, Email)
4.2 Application Data (Technical Data via License ID)
5. Sharing of Personal Data
We do not sell your personal data. We may share your data with the following categories of recipients:
Service providers: Trusted third-party vendors who assist us in operating the service (e.g., cloud hosting, analytics, email delivery, payment processing). These parties process data only on our behalf under data processing agreements.
We use Google Firebase (operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to collect and store technical usage data linked to your user license ID. Google acts as a data processor on our behalf under Google's Data Processing Terms, which incorporate Standard Contractual Clauses (SCCs) as the legal mechanism for transferring data outside the EEA. Firebase processes data only as instructed by us and may not use it for its own purposes. For more information, see Google's Privacy Policy at https://policies.google.com/privacy.
Legal obligations: We may disclose data if required by law, regulation, court order, or governmental authority.
Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.
Where we engage processors outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:
Website data (name, phone, email): Retained for the duration of your account and for up to 3 years following account closure, unless a longer retention period is required by law.
Application technical data: Retained for up to 24 months from the date of collection, after which it is anonymized or deleted.
When data is no longer needed, it is securely deleted or anonymized so that it can no longer be associated with an identifiable individual.
Application technical data (Firebase): Retained for up to 24 months, after which it is deleted or anonymized. You can request earlier deletion by contacting us at cpo@youchip.pro.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:
While we take reasonable precautions, no method of transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals in accordance with GDPR requirements.
Technical data collected through the application is stored in Google Firebase, which maintains ISO 27001 certification and SOC 2/3 compliance. Firebase infrastructure is subject to Google's security standards and regular independent audits.
8. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights regarding your personal data:
Right of access (Art. 15): You may request a copy of the personal data we hold about you.
Right to rectification (Art. 16): You may request correction of inaccurate or incomplete data.
Right to erasure (Art. 17): You may request deletion of your personal data in certain circumstances ("right to be forgotten").
Right to restriction (Art. 18): You may request that we restrict the processing of your data in certain circumstances.
Right to data portability (Art. 20): You may request your data in a structured, machine-readable format.
Right to object (Art. 21): You may object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at cpo@youchip.pro. We will respond within 30 days. You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutettu) or the supervisory authority in your country of residence.
9. Cookies and Tracking Technologies
The SportCut website may use cookies and similar tracking technologies to improve your browsing experience and analyze website traffic. A separate Cookie Policy or consent banner will be displayed on the website informing you of the cookies in use and allowing you to manage your preferences.
The SportCut application does not use browser cookies. Technical data collected in the app is gathered through the application itself and linked to your user license ID as described in Section 2.2.
10. Children's Privacy
SportCut is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data without parental consent, please contact us at cpo@youchip.pro and we will promptly delete such data.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the application, or applicable law. When we make material changes, we will notify you by updating the "Effective Date" at the top of this policy and, where appropriate, by providing notice through the application or via email.
Your continued use of SportCut after the updated policy takes effect constitutes your acknowledgment of the changes.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:
TwoRivers — Data Privacy
Raunistulantie 31 A 10, 20300 Turku, Finland
Email: cpo@youchip.pro
This Privacy Policy applies to all users of the SportCut website and application operated by TwoRivers.
Effective Date: March 3, 2026
Version 1.0
TwoRivers ("we", "us", "our") is committed to protecting your privacy. This Privacy Policy explains what personal data we collect through the SportCut website and application, how we use it, and your rights under applicable data protection law, including the EU General Data Protection Regulation (GDPR).
1. Data Controller
The data controller responsible for your personal data is:
TwoRivers
Raunistulantie 31 A 10, 20300 Turku, Finland
Email: cpo@youchip.pro
2. Personal Data We Collect
We collect personal data through two distinct channels: the SportCut website and the SportCut application. The data collected in each context differs in nature and purpose.
2.1 Website — Contact & Registration Data
When you interact with the SportCut website (e.g., sign up, request information, or create an account), we collect the following personal data directly from you:
- Full name
- Phone number
- Email address
This data is provided voluntarily by you and is necessary to establish your account and communicate with you about the service.
2.2 Application — Technical & Usage Data
When you use the SportCut application, we collect technical data related to your usage of the app. This data is associated with your unique user license ID rather than your name or contact details directly. The technical data we may collect includes:
- Device type, operating system, and version
- App version and feature usage events
- Session duration and interaction logs
- Error and crash reports
- Performance and diagnostic metrics
While this data is technical in nature, it can be associated with a specific individual via their unique user license ID. Therefore, it qualifies as personal data under the GDPR and is treated accordingly.
3. Legal Basis for Processing
We process your personal data on the following legal bases under Article 6 of the GDPR:
Contract performance (Art. 6(1)(b)): Processing your name, phone number, and email is necessary to provide you with the SportCut service and manage your account.
Legitimate interests (Art. 6(1)(f)): Processing technical and usage data linked to your user license ID is necessary for our legitimate interests in maintaining, improving, and securing the application.
Consent (Art. 6(1)(a)): Where we process data for purposes beyond those described above (e.g., marketing communications), we will ask for your explicit consent before doing so.
4. How We Use Your Data
We use the personal data we collect for the following purposes:
4.1 Website Data (Name, Phone, Email)
- Creating and managing your SportCut user account;
- Communicating with you about your subscription, support requests, and service updates;
- Sending transactional messages (e.g., account confirmation, password reset);
- Responding to inquiries and providing customer support;
- Sending marketing communications, where you have given consent or where permitted by applicable law.
4.2 Application Data (Technical Data via License ID)
- Diagnosing and fixing bugs, crashes, and technical issues;
- Monitoring and improving application performance and stability;
- Analyzing feature usage to guide product development;
- Detecting and preventing fraudulent or unauthorized use of the service;
- Enforcing license terms and subscription entitlements.
5. Sharing of Personal Data
We do not sell your personal data. We may share your data with the following categories of recipients:
Service providers: Trusted third-party vendors who assist us in operating the service (e.g., cloud hosting, analytics, email delivery, payment processing). These parties process data only on our behalf under data processing agreements.
We use Google Firebase (operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to collect and store technical usage data linked to your user license ID. Google acts as a data processor on our behalf under Google's Data Processing Terms, which incorporate Standard Contractual Clauses (SCCs) as the legal mechanism for transferring data outside the EEA. Firebase processes data only as instructed by us and may not use it for its own purposes. For more information, see Google's Privacy Policy at https://policies.google.com/privacy.
Legal obligations: We may disclose data if required by law, regulation, court order, or governmental authority.
Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.
Where we engage processors outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
6. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:
Website data (name, phone, email): Retained for the duration of your account and for up to 3 years following account closure, unless a longer retention period is required by law.
Application technical data: Retained for up to 24 months from the date of collection, after which it is anonymized or deleted.
When data is no longer needed, it is securely deleted or anonymized so that it can no longer be associated with an identifiable individual.
Application technical data (Firebase): Retained for up to 24 months, after which it is deleted or anonymized. You can request earlier deletion by contacting us at cpo@youchip.pro.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:
- Encryption of data in transit (TLS) and at rest;
- Access controls limiting data access to authorized personnel;
- Regular security assessments and monitoring;
- Incident response procedures for data breaches.
While we take reasonable precautions, no method of transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected individuals in accordance with GDPR requirements.
Technical data collected through the application is stored in Google Firebase, which maintains ISO 27001 certification and SOC 2/3 compliance. Firebase infrastructure is subject to Google's security standards and regular independent audits.
8. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights regarding your personal data:
Right of access (Art. 15): You may request a copy of the personal data we hold about you.
Right to rectification (Art. 16): You may request correction of inaccurate or incomplete data.
Right to erasure (Art. 17): You may request deletion of your personal data in certain circumstances ("right to be forgotten").
Right to restriction (Art. 18): You may request that we restrict the processing of your data in certain circumstances.
Right to data portability (Art. 20): You may request your data in a structured, machine-readable format.
Right to object (Art. 21): You may object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at cpo@youchip.pro. We will respond within 30 days. You also have the right to lodge a complaint with the Finnish Data Protection Ombudsman (Tietosuojavaltuutettu) or the supervisory authority in your country of residence.
9. Cookies and Tracking Technologies
The SportCut website may use cookies and similar tracking technologies to improve your browsing experience and analyze website traffic. A separate Cookie Policy or consent banner will be displayed on the website informing you of the cookies in use and allowing you to manage your preferences.
The SportCut application does not use browser cookies. Technical data collected in the app is gathered through the application itself and linked to your user license ID as described in Section 2.2.
10. Children's Privacy
SportCut is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data without parental consent, please contact us at cpo@youchip.pro and we will promptly delete such data.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the application, or applicable law. When we make material changes, we will notify you by updating the "Effective Date" at the top of this policy and, where appropriate, by providing notice through the application or via email.
Your continued use of SportCut after the updated policy takes effect constitutes your acknowledgment of the changes.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact:
TwoRivers — Data Privacy
Raunistulantie 31 A 10, 20300 Turku, Finland
Email: cpo@youchip.pro
This Privacy Policy applies to all users of the SportCut website and application operated by TwoRivers.