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PaceFlow Lite — Privacy Policy

Effective from 1 September 2026.

This policy applies to PaceFlow Lite, our mobile app. It does not apply to PaceFlow, our web platform for clubs and organisations, which has its own privacy policy.

Version 1.5 · Last updated: 25 August 2026

Some of what this document describes is still being built. We are publishing it before launch so you can see the standard we hold ourselves to. The following are in build and not yet live at the date of this version, and each is tracked as a launch gate in our data protection impact assessment:

• the in-app report control on coach feedback, replies and announcements
• in-app account deletion
• the guardian-visible area and the child-facing oversight indicator
• cloud sync as a separate opt-in, off by default
• a guardian attached at signup for every under-18 — today enforced for under-13s only
• guardian approval of every under-18 coach connection — today enforced for under-13s only
• ending a coach's access by leaving, removal or disbanding a squad
• Sign in with Apple as the production sign-in route
• generated or list-chosen display names for under-18s — today the display name is free text
• capture of a coach's clearance warranty and club affiliation before an under-18 connection

Where a section below describes one of these, it describes the position at launch.

(v1.0, 6 May 2026. v1.1, 24 July 2026 — corrected push notifications, data portability, coach visibility and training-data age limits; added our error-reporting and analytics processors. v1.2, 29 July 2026 — corrected the v1.3, 18 August 2026 — security-measures wording corrected; cloud sync made a separate opt-in; clubs may view footage inside PaceFlow rather than receive it; coach history visibility now depends on either party subscribing; added what happens to recordings when a coaching relationship ends. under-13 registration description to match the built product, aligned the under-18 leaderboard-consent rule across all our documents, and standardised our data-protection contact address. v1.4, 20 August 2026 — consistency pass across the whole pack: location wording aligned (county never shown for an under-18, home nation shown), the cloud-sync opt-in carried into every document, club in-app viewing reflected in the recipients table, coach history visibility aligned to the either-party-pays rule, and every control that is not yet live marked as in build rather than asserted as present. v1.5, 25 August 2026 — corrected three stray formatting markers that displayed as literal asterisks and mis-applied bold; no change to the substance of this document.)*

Data Controller: DINETICQ LIMITED Atic, 5 Oakwood Drive, Loughborough, England, LE11 3QF Company number: 13861110 Data Protection contact: privacy@dineticq.com

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1. What is PaceFlow Lite?

PaceFlow Lite is a mobile application that analyses cricket bowling videos to measure ball speed, bowling arm angles, foot contacts, and other biomechanical metrics. The app is developed and operated by DINETICQ LIMITED ("we", "us", "our").

2. What data we collect and why

2.1 Account data (when you register)

• Email address — Account login and communication. Lawful basis: Contract.
• Nickname — Display on leaderboards and in squads. Lawful basis: Contract.
• Date of birth — Age group categorisation, children's safeguarding. Lawful basis: Contract + Legal obligation.
• Gender — Leaderboard categorisation. Lawful basis: Contract.
• Height — Accurate ball speed calculation. Lawful basis: Contract.
• County/Region — Regional leaderboards (users 18+ only — never displayed for an under-18); optional sharing with cricket organisations where you consent, at any age. Lawful basis: Contract; Consent for third-party sharing.
• Country — Regional leaderboards; home nation shown on under-18 entries. Lawful basis: Contract.

2.2 Analysis data (when you analyse a video)

• Bowling metrics (ball speed, arm angles, knee angle, foot contacts) — Core service — providing your analysis results. Lawful basis: Contract.
• Event timings (JG, BFC, FFC, ball release) — Core service — identifying key bowling moments. Lawful basis: Contract.
• Video duration, FPS, frame count — Processing context. Lawful basis: Contract.
• View angle (side/rear) — Correct analysis pipeline. Lawful basis: Contract.

Analysis is performed entirely on your device — the measurement itself never needs a network connection.

Syncing your results to your account is a separate choice, and it is off until you make it. When you turn cloud sync on, your results — and the video and movement data behind them — are saved to your account so they are available across your devices and to any coach you have connected to. You can turn it off, and you can delete anything already synced. Publishing to a leaderboard, contributing training data, and sharing with cricket organisations are each separate opt-ins on top of this (sections 2.3 and 2.4).

2.2a Sign-up logging (fraud prevention)

When you create an account, we record:

• IP address — Detecting fraud, automated bot signups, account farming. Lawful basis: Legitimate interests (Art. 6(1)(f) UK GDPR).
• Browser / app user-agent — Same as above. Lawful basis: Legitimate interests.

We do not use this data to track your behaviour around the app, to profile you, or for marketing. It exists so we can identify obvious patterns — for example, ten thousand sign-ups from the same IP block — and so we can investigate if your account is later compromised.

For users under 18, we minimise this further: we store country only, not region or city.

Retention: sign-up logs are deleted automatically after 180 days. If you delete your account before then, your sign-up log is deleted at the same time.

You can request access to your sign-up log entry, or its deletion, by emailing privacy@dineticq.com.

2.3 Data you choose to share (consent-based)

You may opt in to the following. Each requires separate, explicit consent:

Leaderboard sharing: When enabled, your bowling speed, display name and age group are visible to other PaceFlow Lite users on public leaderboards. You can remove your entry at any time.

County is shown only for users aged 18 and over. An under-18 entry shows the speed, the display name, the age group and the home nation (for example England) — never the county, and never any more precise location. Under-18s can still compete in age-group rankings; we simply do not attach a place to a child's name.

No video of an under-18 is ever published. For users aged 18 and over, a verified entry may also include a short video clip of the delivery. For users under 18, a leaderboard entry is metrics only — the speed, the display name, the age group and the home nation, never the footage. This is not a setting, and it cannot be switched on by the child, by a parent or guardian, or by us.

Where an under-18 entry needs to be verified, the clip is uploaded privately, reviewed, and deleted once verification is complete. It is never visible to other users at any point.

Under-18 accounts also use a generated or chosen display name rather than free text, and their entries cannot be tapped through to a profile.

Training data: When enabled, an anonymised video clip of your bowling action (from first foot contact to follow-through, typically 3-4 seconds) is sent to our servers to help improve the accuracy of PaceFlow Lite's analysis. These clips are stripped of all personal identifiers — no account information is linked to training clips in our dataset.

Training data is not available to users under 18. This is an age limit, not a choice: the option is withheld from under-18 accounts entirely, and cannot be enabled by the child or by a parent or guardian on their behalf.

Third-party sharing: When enabled, your display name, age group, county and bowling performance data may be made available to cricket clubs, county boards, national governing bodies (e.g. ECB, Cricket Ireland) and accredited coaching academies for talent identification.

We do not send your video to these organisations. Where an organisation needs to see a delivery to assess it, an approved organisation may view it inside PaceFlow Lite, under an agreement with us, for a limited period. The footage is never copied to them, never downloadable, and every viewing is logged. That means we keep control of it: if you withdraw consent or delete your account, their access ends immediately and there is no copy elsewhere to chase.

For a user under 18, viewing access is granted only where a parent or guardian has approved that specific organisation. You can withdraw this consent at any time, which ends all access and stops any future sharing.

Anonymous analytics: When enabled, anonymous usage data (app opens, analysis completions) is collected with no personal information. Country is derived server-side from IP address; the IP address is not stored.

2.4 Squad and coaching data

Two routes into a squad. Most players join a squad themselves. But a coach can also create a profile for a player who holds no account at all — a "managed player". This section covers both; where a managed player is under 18, the protections below apply in the same way.

When you join a squad, your analysis metrics are shared with the squad's coach. The coach can view your bowling metrics, leave text feedback, and (for paid features) voice or video feedback on your deliveries.

Other squad members can see your nickname and headline speed on the squad leaderboard. They cannot see your individual analyses, feedback or personal details.

How coaches and players are connected. There is no coach directory, and no way to browse, search for or view coach profiles in the app. A coach cannot find a player, contact a player, or add a player to a squad on their own. In build before launch: every connection between a coach and a player under 18 is started or approved by the parent or guardian. In practice this means the coaching relationship already exists offline before it exists in the app.

There is no private messaging channel in the app — for anyone. There is no inbox, no direct-message surface and no persistent chat, at any age. Coach feedback is attached to one specific analysis session — the delivery being discussed — and stays there. A player can reply, and the reply stays on that same session.

Squad announcements are the one other way a coach can communicate. An announcement is a short text update posted to the whole squad — "training moved to Thursday" — and it is deliberately one-way: players cannot reply to it, and it cannot be sent to an individual. Every member of the squad sees the same message, announcements are retained (including after a coach deletes one, so the record survives), and they carry a report control like any other content.

A parent or guardian can see all of it, by default. (This guardian view is in build before launch.) For every user under 18, the guardian attached to the account will be able to see the coach's feedback and any replies. This is on by default and is not something the coach or the child switches off. When a coach leaves feedback, the guardian is sent a notification containing a link into their own view of that session — we deliberately do not put the feedback content into the email, so the child's data stays inside the app where it is access-controlled and logged.

The child is told. Where a guardian can see a session, the app shows the child a clear, age-appropriate indicator that a parent or guardian can see it. We do not operate hidden or silent monitoring.

Everything is kept and can be reported. Coach feedback and replies are logged and retained (see section 4) — nothing is ephemeral or disappears. Every individual piece of feedback carries a report control, so a child, a guardian or a coach can report something that concerns them.

How much of your history your coach can see. Where either you or your coach holds a paid subscription, your coach can see your full analysis history. Where neither does, your coach sees your most recent side-view analysis and most recent rear-view analysis — the same two results you can see yourself on a free account.

So subscribing increases what your coach can see about you as well as what you can see about yourself; and a coach who subscribes can keep a full record for the players they coach, whether or not those players subscribe.

Leaving a squad, and what happens to your recordings. You can leave a squad at any time. That stops all future sharing with that coach, and they lose access to anything you record afterwards.

It does not automatically delete what has already been recorded, and we think it is fairer to say so plainly than to let you assume otherwise:

• Deliveries you recorded yourself stay yours. Leaving removes the coach's access to them.
• Deliveries your coach recorded for you — for example on their device at a session — remain available to that coach as a record of the coaching they did, unless you ask us to remove them. If you are under 18, a parent or guardian can end that access at any time and we will act on it.
• You keep access to all of it, permanently. Once you have claimed your profile, nothing your coach does — including deleting your profile from their squad — can take away your access to footage of you.

Your data follows you, not your coach. When you join a new squad, your bowling history goes with you and the new coach can see it (for an under-18, once a parent or guardian has approved that squad). Your previous coach's written feedback does not travel — their notes stay in the squad they were written in. Moving your data is always your choice, or your guardian's: a coach can never send your history to another coach, and a new coach never receives it without you joining them.

If you want a coach's copy deleted, that is a separate request from leaving a squad — ask us and we will handle it (see section 7).

Annotation videos. A coach may produce an annotation video — your own bowling footage with the coach's drawings and spoken voiceover recorded over it. These contain your image and the coach's voice together, are stored in our cloud storage, and are visible to you and the coach. They are retained until the squad is disbanded or either account is deleted (see section 4).

2.4a Push notifications

If you allow notifications, your device provides us with a push token — an identifier issued by Apple or Google that lets us send a message to that specific device. We store it against your account, with the platform (iOS/Android).

• Push token — To deliver notifications about your own account. Lawful basis: Contract.
• Platform (iOS/Android) — To route the notification correctly. Lawful basis: Contract.

We use notifications only to tell you about activity involving you — for example, a coach has left feedback on your delivery, a coach has posted an announcement to your squad, or someone has joined your squad.

We never send marketing or promotional notifications, and we do not use notifications to encourage you to share more data or upgrade.

You can turn notifications off at any time in your device settings; doing so stops delivery immediately. Your push token is deleted when you delete your account, and is replaced automatically if you reinstall the app.

2.4b Managed players — where a coach records a child who has no account

A coach can create a profile for a player who does not hold an account, so that the coach can record and analyse their bowling. We call this a managed player. This is the one route by which a child's data can enter the service without the child taking any action, so it carries the tightest controls we operate:

• A coach cannot create a junior managed player on their own. For any player under 18, the coach must identify a parent or guardian, and that guardian must approve before the profile is created.
• Nothing can be recorded or uploaded until the guardian approves. This is enforced on our servers, not merely hidden in the app.
• The guardian has the same visibility over coach feedback as they would for a child holding their own account.
• The child can take ownership later. A coach can issue a claim code; when the player redeems it, the recordings become theirs, under their own account and their own privacy choices.
• If a guardian declines, or never approves, the profile cannot be used and no footage of that child is processed.

2.4c Coaching referrals (Fast Bowlers Ltd)

Where a player has no coach, we may show a referral to Fast Bowlers Ltd, a company connected to DINETICQ Limited. We disclose that connection wherever the referral appears.

The referral is never shown on an under-18 account, and is shown to a guardian only where a guardian surface exists (in build). It is shown to the account holder — for an under-18, the parent or guardian — and never to a child. It is a static placement: it is not personalised, not targeted, and is never selected or triggered using a child's data. We do not profile children, and we do not advertise to them.

2.5 Our staff's access to your data

DINETICQ LIMITED operates PaceFlow Lite. As the operator of the service, authorised members of our staff may access your data in a limited set of circumstances:

• Support requests: to investigate and resolve a specific issue you have raised (for example, an analysis that failed to process, a subscription that did not activate, a missing feedback message)
• Bug investigation: when a defect is reproduced or a crash report implicates specific user data, for the minimum scope needed to diagnose and fix the issue
• Safeguarding and content moderation: to investigate reports of abuse, inappropriate content, or behaviour that breaches our Terms of Service
• Legal obligations: where we are required by law to produce or preserve data (for example, a lawful request from a UK police force or court order)
• Fraud and abuse prevention: to investigate suspected account takeover, payment fraud, or leaderboard manipulation

We apply the following safeguards to every such access:

• Need-to-know: access is restricted to staff whose role requires it. Not every employee has access to production user data.
• Audit log: staff access to a user's data is recorded with the staff member's identity, the user record accessed, the timestamp, and the ticket or incident reference that justified the access. (Full coverage of every staff access path, and per-staff credentials with two-factor authentication, are in build before launch.) The audit log is retained for 24 months and is available for inspection on your request.
• Purpose limitation: access requires a recorded reason (a support ticket ID, a bug reference, a safeguarding report, or a legal request). Browsing user data without such a reason is a disciplinary matter.
• Children: access to the data of users under 13 requires an additional justification and senior approval, even for support. Access to children's data is reviewed quarterly.
• Support dashboard: where possible, staff use a read-only support dashboard rather than direct database access. The dashboard only exposes the minimum fields needed for support and logs every query.
• Training: staff are trained on UK GDPR and our data-protection policies before being granted any production access.

If you would like to know whether our staff has accessed your data: email privacy@dineticq.com with the subject line "Data access request." We will respond within one calendar month with the relevant audit log entries or confirm that no access has occurred.

2.6 Data we do NOT collect

• We do not collect precise GPS location. Your county/region is selected from a dropdown at registration; the only location data we derive is the approximate country/region from your IP at sign-up (see section 2.2a).
• We do not collect your contacts, or photos other than bowling videos you choose to import.
• We do not use advertising identifiers, and we do not track you across other apps or websites.
• We do not use cookies or tracking pixels. Our analytics are cookieless and anonymous.
• We do not sell your personal data to advertisers, and we do not show advertising in the app.
• We do not send marketing notifications. Push notifications are only sent about activity on your own account (see section 2.4a).

3. Children's privacy

PaceFlow Lite may be used by children. We take the following measures in compliance with the UK Data Protection Act 2018 and the ICO Children's Code (Age Appropriate Design Code):

We treat 13 as the data-consent age (Article 8(1) UK GDPR) and 18 as the safeguarding age. These are two different lines and we apply them separately: a 15-year-old may hold their own account, but every safeguarding protection below still applies to them.

• Under 13 — the guardian owns the account. A child under 13 does not hold an account with us. The parent or guardian registers, holds the account, and is our contract-holder and primary point of contact. The child uses the app under that account. We do not ask a child under 13 to create an account or to consent to anything.
• 13 to 17 (United Kingdom) — the child may hold the account, with a guardian attached. A young person aged 13 to 17 may register in their own name, but a parent or guardian must be attached at signup. (In build before launch — today this is enforced for under-13s only.) We collect the guardian's email address and send them a single-use link to confirm. Until the guardian confirms, the account is limited to on-device analysis: the young person can record and view their own results, but nothing leaves the device — no upload, no squad, no leaderboard.
• Outside the United Kingdom. Some countries set a higher age or require verified parental consent up to 18. Our consent rules follow the country of signup. At launch PaceFlow Lite is available in the United Kingdom only.
• All users under 18 — safeguarding protections apply regardless of who holds the account. Sharing consents default to OFF. No video of an under-18 is ever published to a leaderboard (see section 2.3). There is no private messaging channel with a coach, and every coach connection is guardian-approved (see section 2.4). The guardian can see coach feedback by default, and the child is shown that this is the case. Display names are generated or chosen from a list rather than free text, and profiles cannot be opened from a leaderboard entry.
• All children: privacy information is presented in clear, age-appropriate language. We do not profile children, and we do not use their data for marketing or advertising. A child's county is never displayed on a leaderboard — the only location shown on an under-18 entry is the home nation (for example England).

4. How long we keep your data

• Account data — Until you delete your account
• Analysis metrics (paid subscribers) — Until you delete your account
• Analysis metrics (free users) — Latest side-view analysis and latest rear-view analysis only (two slots). A new side-view recording replaces the previous side-view analysis and clip; a new rear-view recording replaces the previous rear-view analysis and clip. The two slots are independent.
• Video clips (free users, cloud-synced) — Retained in cloud for as long as the associated analysis is retained (see row above). Deleted when that analysis is replaced by a same-angle recording.
• Leaderboard entries — Until you withdraw consent or delete your account
• Video clips (leaderboard) — Until you withdraw consent or delete your account
• Training data clips — Retained indefinitely in anonymised form (not linked to your account)
• Squad membership — Until you leave the squad or delete your account
• Coach feedback, replies and annotation videos (your footage with the coach's drawings and voiceover) — Until the relevant squad is disbanded or either account is deleted. Retained on all tiers — including free — even after the analysis clip they refer to has been replaced under the free-tier limit
• Squad announcements — Retained after a coach deletes one, so the record survives
• Guardian contact details — Until the associated account is deleted
• Consent records (including guardian consent) — 7 years from the end of the account relationship, as the evidential record that consent was validly obtained
• Push token (device identifier for notifications) — Until you delete your account, uninstall the app, or disable notifications
• Anonymous analytics — 24 months
• Error and crash reports — 90 days
• Sign-up log (IP, user-agent, country) — 180 days, then auto-deleted

When you cancel a paid subscription:

• Your cloud data is retained for 30 days (grace period)
• After 30 days, data moves to archive storage (retained for 12 months)
• After 13 months, archived data is permanently deleted unless you resubscribe
• Data on your device is unaffected by subscription changes

5. Who we share your data with

We share your data only with the following categories of recipients:

• Microsoft Azure (UK South region) — Account data, analysis metrics, video clips. Purpose: Cloud hosting and storage.
• Apple / Google (via RevenueCat) — Subscription status. Purpose: Payment processing.
• Apple / Google (push notification services) — Push token and notification content. Purpose: Delivering notifications to your device.
• Sentry (EU region) — Error and crash diagnostics, account identifier. Purpose: Diagnosing crashes and defects.
• PostHog (EU region) — Anonymous, cookieless usage events. Purpose: Understanding which features are used.
• Cricket organisations (with your consent) — Display name, age group, county, performance metrics; time-limited in-app viewing of a delivery clip (no copy is transferred, every viewing logged). Purpose: Talent identification.
• Squad coaches (with your consent) — Analysis metrics, video clips and movement data for analyses you have synced, feedback threads. Purpose: Coaching services.

Sentry and PostHog are both configured to store data in the European Union. Neither is used for advertising, and neither tracks you across other apps or websites.

We do not share your data with any other third parties unless required by law.

6. International data transfers

All data is stored in Microsoft Azure's UK South data centre. Data does not leave the United Kingdom.

Microsoft's engineers may access data for support purposes under Microsoft's Data Processing Addendum, which includes Standard Contractual Clauses for any incidental international access.

7. Your rights

Under UK GDPR, you have the right to:

• Access your personal data (request a copy)
• Rectify inaccurate data (edit your profile)
• Erase your data ("Delete Account" in the app, or email us)
• Restrict processing in certain circumstances
• Port your data — email us and we will provide your personal data in a structured, commonly used, machine-readable format (JSON) within one calendar month, free of charge
• Object to processing based on legitimate interest
• Withdraw consent at any time (toggle off in Privacy Settings)

To exercise any right: use the in-app settings, or email privacy@dineticq.com. We will respond within one calendar month.

Erasure timeline: When you delete your account, all personal data is purged from our systems within 30 days. Anonymised training data (not linked to your account) is not affected.

8. Data security

We implement the following security measures:

• Encryption at rest: All data stored in Azure is encrypted using AES-256 (Azure default)
• Encryption in transit: All communications use TLS 1.2 or higher
• Authentication: We are moving to Sign in with Apple, so that we do not create, store or handle passwords at all. (In build before launch.)
• Access controls: Every request is authorised against the requesting account, so you can only reach your own data and data explicitly shared with you
• On-device processing: Video analysis runs entirely on your device; video is not uploaded unless you opt in
• Security testing: We carry out structured security reviews of the app and our backend, with findings tracked to remediation; we run automated vulnerability and dependency scanning; and we use continuous cloud threat monitoring. We commission independent penetration testing as the service grows, and review that decision at least annually and whenever the service changes materially

9. Automated decision-making

PaceFlow Lite uses machine learning models to detect bowling events and measure metrics. This is a measurement tool: it does not make decisions about you that produce legal or similarly significant effects, and we do not profile you. Leaderboard rankings reflect measured performance only.

The rules on automated decision-making are now at Articles 22A to 22D UK GDPR (as substituted by the Data (Use and Access) Act 2025). We do not take significant decisions about you by solely automated means. Where any decision affecting you is automated, you will be told, you may make representations, you may ask for human review, and you may contest the outcome.

10. Changes to this policy

We may update this policy from time to time. We will notify you of material changes via:

• In-app notification
• Email (if you have an account)

The "Last updated" date at the top of this policy indicates when it was last revised.

11. Complaints

If you are unhappy with how we handle your data, you have the right to complain to the Information Commissioner's Office (ICO):

Information Commissioner's Office Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: 0303 123 1113 Website: ico.org.uk

12. Contact us

For any questions about this privacy policy or your personal data:

DINETICQ LIMITED Atic, 5 Oakwood Drive, Loughborough, England, LE11 3QF Email: privacy@dineticq.com Company number: 13861110