> For the complete documentation index, see [llms.txt](https://docs.ultie.org/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.ultie.org/site-policy/privacy-policy.md).

# Privacy Policy

* Last updated: 10 September 2026

## 1. About This Policy

This Privacy Policy explains how ULTIE LTD handles personal information when you visit or use Ultie, create an Account, manage a child profile, join a Club or Team, take part in an Event, use payment features, or contact us.

Ultie is used by players, Family managers, parents and legal guardians, Team managers, Club representatives, Event staff, Organizers, and visitors to public Event pages.

Ultie and the relevant Organizer may be responsible for different parts of the same activity. Section 3 explains this division.

## 2. Who We Are

ULTIE LTD operates Ultie and is the controller where it decides why and how personal information is used.

* Company: ULTIE LTD
* Company number: 16415880
* Registered office: 124–128 City Road, London, England, EC1V 2NX
* Privacy contact: <privacy@ultie.org>
* General support: <support@ultie.org>

ULTIE LTD is established in the United Kingdom and is registered with the UK Information Commissioner's Office under registration number ZB974379.

We have appointed Konstantin Basos, established in Portugal, as our representative in the European Union under Article 27 of the GDPR.

You may contact our EU Representative about the processing of your personal data at:

* Address: R. do Recife 7, 2780-034 Oeiras, Portugal
* Email: <const@ultie.org>

Ultie has not appointed a statutory Data Protection Officer; the privacy contact above handles all data-protection matters.

## 3. When Ultie or an Organizer Is Responsible

### Ultie as controller

Ultie is responsible for processing where it determines the purpose and essential means. This includes:

* Accounts, authentication, and Global profiles;
* Club profiles and Club-membership administration;
* Family accounts and platform-wide age rules;
* platform security, diagnostics, support, and service notices;
* cookie choices and Ultie's analytics;
* Ultie's contract formation and acceptance evidence, corporate accounting, compliance, dispute, and legal-claim records; and
* the published historical sports record described in Section 7.

### Organizer as controller

An Organizer controls Event administration, including the purposes and essential means for:

* Event and Team applications;
* Rosters and Event player profiles;
* Organizer-created forms and surveys;
* Event waiver content, signing requirements, and admission decisions;
* Organizer-directed Event messages;
* Event fees, refund decisions, and payment-status administration; and
* Event staff access.

For these activities, Ultie acts as the Organizer's processor under the Organizer Data Processing Agreement. The Organizer must provide any additional privacy information that applies to its Event.

When information is first published on a public Event page, Ultie maintains the limited historical sports record described in Section 7 as a separate controller. Other Organizer-controlled Event information remains within the Organizer relationship.

### Active payment provider as controller

Mollie or Stripe acts separately as controller for the payment service supplied through the Organizer's connected provider account. The provider's own terms and privacy information govern that service. Ultie remains responsible for the connection, payment interface, provider-status synchronization, and Event-accounting records that Ultie controls.

### Club membership

Ultie is the controller for Club-membership records: invitations, applications, current membership status, and Club roles. Club managers administer their Club under the Terms of Use; they must have authority for the people they add or manage and may use membership information only for administering the Club. When a person leaves a Club or is removed, the active membership ends and Ultie does not keep a standalone historical Club-membership record.

Club membership is separate from an Event Team and Roster. Event Teams, Rosters, Event player profiles, and Event-scoped Club name or avatar snapshots remain within the Organizer's Event boundary.

If you are unsure who controls a record, contact the relevant Organizer or email <privacy@ultie.org>.

## 4. Information We Handle

The information depends on the features you use.

### Account and Global profile information

* email address;
* first and last name;
* authentication and sign-in identifiers;
* date of birth;
* gender;
* country;
* language, preferences, and Account settings;
* optional profile photo;
* session, login, and Account-security records; and
* links between a Global profile and Event player profiles.

### Children and Family account information

* Family manager and child relationships;
* a child's name, date of birth, country, and profile information;
* age-based permissions and actions;
* adult identity and authority confirmations; and
* records of the person who acted for a child in a supported flow.

### Club, Team, and Event information

* Club membership, invitations, applications, current status, and management roles;
* Team applications and Team manager details;
* Event, Division, Roster, and Event player profile information;
* Event staff roles and access;
* schedules, Games, scores, results, Spirit of the Game information, awards, and statistics;
* Organizer-created questions, answers, attachments, and internal notes;
* non-medical emergency-contact information; and
* public Event history.

Organizer forms, surveys, and internal Event notes must not be used to request health, medical, biometric, racial or ethnic origin, religious or philosophical belief, sexual-life, sexual-orientation, or other special-category information. Free-text controls reduce this risk but cannot make it technically impossible for a person to enter unexpected information. If prohibited information is entered, Ultie and the responsible Organizer may restrict, remove, or remediate it.

### Waiver information

* player identity and date of birth;
* waiver template and version;
* signer identity and authority;
* authority-attestation version;
* signature and signing time; and
* technical evidence needed to record the signing action.

Adults sign for themselves. For a Minor, the supported route requires an adult signer: a Family manager signs where the waiver is assigned through the Family-managed route; otherwise a parent or another legally authorized adult may sign through the external flow.

A waiver is a participation or liability instrument. It is not consent to process personal information for unrelated purposes.

### Payment information

* payer name and email where needed;
* Event, Team, player, and Team-balance links;
* payment identifier, original amount and currency, current net amount, fee, method, and status;
* internal manual-refund accounting and chargeback or dispute evidence;
* manual cash, bank, or cheque records;
* the name of the organization and the active payment provider connected for the Event; and
* payment-provider and accounting references.

The Organizer may choose **Mollie** or **Stripe** as its active online payment provider. The provider processes payment credentials under its own terms and privacy information. Ultie does not receive or store full card or bank-account credentials.

### Communications and support

* service, security, and Organizer-directed messages;
* recipient, delivery, and bounce information;
* support correspondence;
* privacy requests, identity or authority checks, and outcomes; and
* records needed to investigate an incident, complaint, or dispute.

### Device, consent, analytics, and diagnostic information

* IP address;
* browser, device, operating system, and language;
* request and page information;
* cookie or similar-technology choices and evidence;
* product-usage events;
* error and performance information.

Our Cookie Policy explains the technologies currently used and how to control optional categories.

## 5. Where Information Comes From

We receive information:

* directly from you;
* from a Family manager, parent, or legal guardian acting for a child;
* from Team managers, Club managers, Organizers, and Event staff;
* from another user who is authorized to add or manage a Club, Team, or Event record;
* from Google or Facebook when you choose a supported sign-in method;
* from the active payment provider when a payment record changes;
* automatically from your browser, device, and use of Ultie; and
* from providers that help us deliver hosting, backups, email, maps, consent controls, authentication, embedded media, diagnostics, and support.

If a person gives Ultie information about someone else, they must be authorized to do so and must provide any privacy information required for their activity.

## 6. Why Ultie Uses Information

This table describes the main purposes for which ULTIE LTD acts as controller.

| Purpose                                                                        | Examples of information                                                                                      | Main legal basis under UK/EEA law                                                                                                             |
| ------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------ | --------------------------------------------------------------------------------------------------------------------------------------------- |
| Create an Account and provide requested Account features                       | Identity, email, sign-in details, settings                                                                   | Contract                                                                                                                                      |
| Authenticate users and protect Accounts                                        | Sign-in, session, device, and security records                                                               | Contract for authentication; legitimate interests in preventing unauthorized access and protecting Ultie and its users                        |
| Operate Global profiles and Family relationships                               | Profile fields, date of birth, gender (used for Division eligibility and roster rules), Family relationships | Contract for requested features; legitimate interests in providing an age-appropriate service                                                 |
| Operate Club profiles and membership                                           | Membership applications, invitations, current status, Club roles                                             | Contract for the membership you request; legitimate interests in operating group features                                                     |
| Connect an Account and Global profile with Club, Team, and Event participation | Profile links, roles, and participation references                                                           | Contract for requested Account features; legitimate interests in operating and improving the platform                                         |
| Maintain the published historical sports record                                | Name, Team, Games, results, and statistics, subject to Section 7 safeguards                                  | Legitimate interests in preserving the integrity, accuracy, and continuity of competitive sports results                                      |
| Secure, maintain, and troubleshoot Ultie                                       | IP address, device data, logs, errors, and Account reference                                                 | Legitimate interests in protecting, maintaining, and improving the service; legal obligation where applicable                                 |
| Send requested or essential platform messages                                  | Contact details, message type, and delivery status                                                           | Contract for service messages; legitimate interests for security and service-administration notices                                           |
| Keep Ultie's own financial and compliance records                              | Limited transaction, invoice, payment, and acceptance information                                            | Legal obligation; legitimate interests in accurate business records                                                                           |
| Handle disputes, incidents, and legal claims                                   | Relevant payment, acceptance, support, security, and dispute information                                     | Legitimate interests in resolving disputes and establishing, exercising, or defending legal claims; legal obligation where applicable         |
| Provide support                                                                | Contact details, correspondence, verification, and outcome                                                   | Contract where the request concerns the service; legitimate interests in supporting users and improving Ultie                                 |
| Handle privacy requests and complaints                                         | Contact details, correspondence, verification, and outcome                                                   | Legal obligation; legitimate interests in documenting and managing requests                                                                   |
| Operate strictly necessary storage and access technologies                     | Device, session, security, and choice information                                                            | Contract where necessary for a requested feature; legitimate interests in security and service operation; applicable storage/access exemption |
| Use optional storage and access technologies                                   | Consent identifier, category choices, device and usage information                                           | Consent where required                                                                                                                        |
| Publish a Global profile under the applicable country-specific visibility rule | The public profile fields listed in Section 7                                                                | Legitimate interests in providing a public sports profile, subject to the enhanced safeguards in Section 7                                    |
| Keep evidence of a privacy or cookie choice                                    | Version, choice, Account or pseudonymous reference, and time                                                 | Legal obligation and legitimate interests in demonstrating the action taken                                                                   |

Where Ultie processes Event information only on the Organizer's instructions, the Organizer determines the applicable legal basis and must explain it in its own privacy information.

We do not use consent where another legal basis is the real reason for processing. You may withdraw consent at any time without affecting processing that was lawful before withdrawal.

Ultie does not perform solely automated decision-making that produces legal or similarly significant effects for a person.

## 7. Public Profiles and Sports History

A public Global profile may show only:

* first and last name;
* profile photo;
* Event participation history;
* Club memberships;
* all-time sports statistics shown by the product, including Games and average Points, Goals, and Assists; and
* award counts shown by the product, including first, second, and third place and Spirit of the Game.

Email, date of birth, gender, contact details, waivers, forms, payments, and security information are never public through a Global profile.

Ultie applies a country-specific minimum age for making a Global profile visible. The country recorded on the profile determines the applicable age. Before the person reaches it, the Global profile is always hidden and neither the person nor a Family manager can make it visible. A person under 13 also has no profile photo.

At or above the applicable age and under 18, a new Global profile starts hidden. A self-managed player controls their own visibility; a Family manager controls visibility for a managed profile. The authorized person may make the profile visible through a separate affirmative action and may hide it again at any time. Reaching the applicable age does not make a hidden profile visible automatically. If a country change raises the applicable age above the person's age, Ultie hides the profile and locks the visibility setting. If it lowers the age, the profile remains hidden until the authorized person makes it visible.

A Global profile created for a person aged 18 or older is visible by default, and the adult may hide it or make it visible again. If a hidden profile reaches age 18, it stays hidden until the adult changes the setting manually. The visibility setting is a privacy safeguard and is not treated as consent to publication. A hidden profile shows only `Hidden Profile` and does not expose the fields above.

The published historical Event record is maintained under legitimate interests as described in Section 6. It is separate from the Global profile and does not depend on Account eligibility, a visibility setting, or consent.

A Global profile and an Event player profile are separate records. Hiding a Global profile removes the person's profile details from public view and removes the person from current public Club member listings. It does not end the underlying Club membership and does not rewrite completed Games, results, or the historical Event record. Final Account deletion ends active Club memberships and removes the person from current public Club member listings, but does not rewrite historical Event Rosters, results, or statistics. Section 16 explains how to ask for a correction, a restriction, or the `Player Unknown` replacement for a historical record.

After Account or managed-child-profile deletion becomes final, the historical Event record normally retains the person's name, Team, Games, results, and statistics. The photo becomes a neutral placeholder. The deleted Global profile cannot be opened from the historical record.

A neutral placeholder also replaces the Event-scoped photo on every historical surface when a photo-removal request is upheld. A photo-removal request concerning a child is upheld by default. Hiding a Global profile does not change photos in historical Event records.

Where keeping a name creates a credible safety or privacy concern, or an applicable objection or erasure request is upheld, Ultie can replace the name across public historical surfaces with the shared label `Player Unknown` while preserving Team, Game, result, and statistic relationships. A request concerning a person who was under 18 at the time of the Event is upheld by default. The public replacement is permanent through ordinary product controls, is not a user setting, and is not available to an Organizer; it is applied case by case and is not a default rewrite of sports history. If a replacement is later shown to have been obtained by fraud or applied in error, Ultie corrects it through the documented review route.

Spirit of the Game scores are administered by the relevant Organizer, which can correct a submitted score through the Event scoring flow; contact the Organizer first about a score.

Contact <privacy@ultie.org> if public information is inaccurate or creates a safety or privacy concern. Ultie will assess the request, give particular weight to a child's rights and safety, and apply the relevant correction, restriction, objection, or erasure rules.

## 8. Children and Family Accounts

Ultie supports child and teen profiles so young players can participate with age-appropriate adult involvement.

### Players below the minimum self-managed Account age

The minimum age to control an Ultie Account is 13 by default and 14 in Spain. A player below the applicable threshold cannot create or access an Ultie Account and has no login, session, or direct interaction path. An authenticated adult Family manager creates and manages the child profile and performs every supported action in the adult's session.

Photos are not supported for children under 13 anywhere in Ultie; a neutral placeholder appears on every surface instead.

The adult provides the child's information and confirms that they are authorized to act for the child. This is an authority confirmation, not a representation that the child has accepted this Policy or entered a contract with Ultie.

Ultie is a general-audience sports platform and is not designed as a child-directed service.

### Minors at or above the self-managed Account threshold

A player who is at or above the applicable threshold and under 18 may control their profile through their own Account or remain managed by a Family manager until the supported handoff is completed. Where the player controls an Account, they may use only the features and actions made available through that route. Other actions depend on the relevant Event role and flow.

Account eligibility is not determined by a national age of digital consent. National consent rules are applied only to processing that actually relies on consent, such as optional cookie technologies or marketing if introduced. Global-profile visibility follows the legitimate-interests basis and safeguards in Sections 6 and 7.

For a Minor waiver, the Family manager signs where the waiver is assigned through the Family-managed route; otherwise a parent or another legally authorized adult may sign through the supported external flow. The signer confirms their authority, and Ultie records the evidence described in Section 4. Turning 18 after signing does not by itself require a new signature before the Event.

### Family manager actions and rights

A Family manager may manage multiple child profiles and delete an individual child profile. Deleting the Family manager's own Account also deletes all linked managed-child profiles after a clear warning. Historical sports records and evidence that must be retained follow Sections 7 and 13.

Children and teenagers have privacy rights of their own. An adult may exercise rights for a child where the law allows, but Ultie may consider the child's age, understanding, wishes, and the adult's authority.

## 9. Event Payments

Organizers that enable online Event payments choose Mollie or Stripe. Only one provider may be active for a payment configuration at a time. Connecting the other provider replaces the current provider for future payment attempts. The Organizer uses its own connected provider account, receives participant funds through it, decides refund eligibility, and performs an approved refund through the provider that processed the original payment.

Ultie provides the connection, payment interface, provider-status synchronization, and Event accounting records. Ultie does not hold participant funds, receive full payment credentials, or initiate or approve an online-provider refund. Switching providers does not rewrite a completed payment or its original provider reference.

When a Family manager pays an assigned Event fee from a managed child profile, the Family manager remains the payer and every receipt is issued and delivered in the Family manager's name. The child profile identifies the fee but is not the payer.

Ultie may receive changes to payment status, the current net amount, and chargeback or dispute status needed to maintain the Event record. In a Tournament or League, a refund or chargeback does not automatically remove a player from a Roster or erase completed participation or sports history. In a Hat, a confirmed full refund or chargeback removes the corresponding Hat application.

## 10. Cookies, Analytics, Maps, and Embedded Services

Ultie uses storage and access technologies for service operation and security, analytics, selected functional features, and embedded media.

Where a technology requires consent, it is not used before the required choice is made, and the choice can be changed through `Cookie Settings`. `Cookie Settings` remains available through the persistent footer link. Some third-party features may receive ordinary request information when you choose to use them.

See the Cookie Policy for current technology categories, providers, when they load, preference controls, and relevant retention.

## 11. Recipients and Service Providers

We disclose personal information only where needed for the purposes described in this Policy. Recipients may include:

* the relevant Organizer and authorized Event staff;
* Team managers and Club managers within their role and access scope;
* Family managers, parents, legal guardians, and external adult waiver signers where a flow requires it;
* other users and the public for public Global profiles and Event records;
* the Organizer's active payment provider (Mollie or Stripe) and other independent services that you choose to use;
* hosting, backup, security, email, diagnostics, consent-management, map, sign-in, embedded-media, and documentation providers;
* professional advisers, auditors, and corporate service providers; and
* courts, regulators, law-enforcement bodies, or other recipients where disclosure is required or permitted by law.

Our providers fall into these categories: hosting and infrastructure, backup storage, network delivery and security, transactional email, error and performance diagnostics, consent management, maps and geocoding, sign-in services, embedded media, documentation, and payment services (Mollie or Stripe). The authoritative list of providers that process personal information for an Organizer is in the Organizer Data Processing Agreement. Not every provider receives every category of information, and a provider may have a different legal role for different activities.

## 12. International Transfers

ULTIE LTD is established in the United Kingdom. Primary services, databases, and backups are hosted in the European Economic Area.

Covered transfers from the EEA to the United Kingdom may rely on the European Commission's adequacy decision for the United Kingdom while it remains in force. Other international transfers may rely on:

* an applicable adequacy decision or regulation;
* the European Commission's Standard Contractual Clauses;
* the UK International Data Transfer Agreement or UK Addendum; or
* another lawful transfer mechanism.

The mechanism depends on the provider, activity, countries, and applicable law. Contact <privacy@ultie.org> for information about the safeguard relevant to your information.

## 13. Retention

Ultie keeps information only for as long as needed for its purpose, including applicable legal, accounting, security, dispute, and record-keeping requirements.

| Information                                                                             | Usual period or criterion                                                                                                                                                                                                                             |
| --------------------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| Active Account and Global profile                                                       | Until Account deletion or another documented retention or deletion rule applies; Ultie does not delete an Account solely because it is inactive                                                                                                       |
| Active Club membership                                                                  | Until the person leaves the Club, is removed, or final Account deletion ends the membership; no standalone historical Club-membership record is retained                                                                                              |
| Temporary Event staff access                                                            | Ends no later than 30 calendar days after the Event end date recorded by the Organizer, or sooner when authorization ends                                                                                                                             |
| Personal Event CSV access                                                               | Available for one calendar year after the Event end date recorded by the Organizer; downloading is blocked for every role, including Owner and Admin, when that window ends                                                                           |
| Generated personal-data export file                                                     | Not stored on Ultie's servers; delivered only in the authorized requester's session                                                                                                                                                                   |
| Event applications, custom forms, surveys, attachments, and nonpublic personal fields   | Available to the Owner and an authorized Admin within assigned permissions for one calendar year after the Event end date recorded by the Organizer; after that, display is blocked for every role and the data is deleted or irreversibly anonymized |
| Cancelled Event personal data                                                           | The recorded cancellation date is treated as the Event end date and starts the ordinary 30-calendar-day staff-role and one-calendar-year operational windows                                                                                          |
| Published historical sports record                                                      | While Ultie supports the record, subject to Section 7 safeguards and applicable rights                                                                                                                                                                |
| Adult waiver and signing evidence                                                       | 6 years after the Event end date recorded by the Organizer                                                                                                                                                                                            |
| Minor waiver and signing evidence                                                       | Until the later of 6 years after the Event end date recorded by the Organizer or the player's 21st birthday                                                                                                                                           |
| Payment and financial records, including financial CSV data                             | 6 years from the end of the financial year to which they relate, unless a documented legal hold applies; the one-year ordinary personal-data window does not shorten this period                                                                      |
| Transactional email content                                                             | No more than 30 days after sending                                                                                                                                                                                                                    |
| Transactional email delivery metadata                                                   | No more than 90 days after sending                                                                                                                                                                                                                    |
| Terms, Payment Terms, Event Refund Policy, Organizer Terms, and DPA acceptance evidence | 6 years after the relevant version stops applying to the person or the related operation ends, whichever is later                                                                                                                                     |
| Support correspondence                                                                  | No more than 2 years after the matter closes, unless linked to an incident, dispute, or legal hold                                                                                                                                                    |
| Privacy-request content                                                                 | No more than 3 years after closure                                                                                                                                                                                                                    |
| Minimal privacy-request result record                                                   | No more than 6 years after closure                                                                                                                                                                                                                    |
| Ordinary server, authentication, application, and security logs                         | No more than 90 days, unless isolated for a documented incident or legal requirement                                                                                                                                                                  |
| Sentry error and performance diagnostic events                                          | No more than 90 days, unless isolated for a documented incident or legal requirement                                                                                                                                                                  |
| Cookie-choice evidence                                                                  | While the choice is current and for up to 6 years after replacement or withdrawal                                                                                                                                                                     |
| Ordinary backups                                                                        | Automatically overwritten within a hard maximum of 90 days                                                                                                                                                                                            |

Event periods run from the Event end date recorded by the Organizer, not the last Game or a later edit to a public date. Owner and authorized Admin roles do not expire automatically. Once the one-calendar-year operational window ends, ordinary personal or other non-public sensitive Event data is no longer displayed and ordinary personal-data CSV downloads are blocked for every role, including Owner and Admin. The historical panel then shows only the published sports record and records with their own retention periods; deleted personal information is not restored to that panel.

Deleted production information may remain in protected backups until automatic overwrite, for no more than 90 days. During that period it is beyond ordinary use and is not queried or repurposed. If a backup is restored, deletion instructions are reapplied before restored information becomes permanent production data.

A documented legal hold applies only to the specific records needed for the identified obligation or claim. It does not extend the ordinary backup cycle.

## 14. Account and Child-Profile Deletion

Deleting an Account immediately ends sessions, sign-in, and ordinary access and removes the active Global profile from view. For 30 calendar days you may ask support to restore the Account; support will verify your identity before restoration. There is no self-service restoration flow. When that window ends, deletion becomes permanent and cannot be reversed.

Deleting a Family manager's Account also deletes every linked managed-child profile after the displayed warning. A managed child profile may also be deleted separately, with the same 30-day support restoration window controlled by the Family manager.

When Account deletion becomes final, active Club memberships end and the person is removed from current Club member listings.

Deletion does not automatically rewrite completed Games or published results. The limited historical record follows Section 7. Payment, waiver, acceptance, security, complaint, and dispute evidence follows its specific retention period.

## 15. Security

Ultie uses technical and organizational measures designed to protect personal information against unauthorized access, loss, alteration, or disclosure.

These include role-based least-privilege access, confidentiality controls, prompt offboarding, multi-factor authentication for privileged and provider Accounts, protected secret storage, TLS encryption in transit, protected backups, monitoring, retention controls, provider management, and incident handling.

No online service can eliminate every risk. Contact <support@ultie.org> if you believe an Account or information is at risk.

## 16. Your Privacy Rights and Complaints

Depending on the law and the reason for processing, you may have the right to:

* receive information about processing;
* access your personal information;
* correct inaccurate or incomplete information;
* request deletion;
* restrict processing;
* receive certain information in a portable format;
* withdraw consent where consent is used; and
* object to processing based on legitimate interests.

To object to the historical sports record, tell us which record concerns you and why. We will assess the circumstances and any overriding legitimate grounds. We may correct the record, restrict or remove a field, replace a photo with the neutral placeholder, use `Player Unknown`, or delete information where required.

You may update some information directly in Ultie. For other requests, email <privacy@ultie.org>. We may request information reasonably needed to confirm identity and authority.

We respond to a rights request within one month. Where a request is complex or we receive several requests from the same person, we may extend the period by up to two further months and will explain the extension within the first month.

If an Organizer controls the information, we may route the request to it or assist it with the response. This does not prevent you from contacting the Organizer directly.

Rights are not absolute. Where the law allows or requires us to refuse or limit a request, we will explain the outcome.

You may complain to the UK Information Commissioner's Office at [ico.org.uk](https://ico.org.uk/). If EU or EEA data-protection law applies, you may also complain to the supervisory authority where you live or work or where you believe an infringement occurred.

You may complain directly to Ultie at <privacy@ultie.org>. We will acknowledge the complaint, investigate it, and provide the outcome without undue delay and within any period required by law.

### United States residents

We use one privacy-request process for all United States residents. You may ask us to confirm whether we process your personal information, give you access to it, correct it, delete it, provide a portable copy, or review an earlier decision about your request. Applicable law may provide additional rights or exceptions.

You or an authorized agent may submit a request to <privacy@ultie.org>. We may take proportionate steps to verify identity, residency, and the agent's authority. If applicable law gives you a further appeal or complaint route, we will explain it with our response.

Ultie does not sell personal information, share it for cross-context behavioral advertising, use it for targeted advertising, or use automated profiling to make decisions that produce legal or similarly significant effects. If those practices change, we will update this Policy and provide any required notice, consent, or control before the affected processing begins.

## 17. Changes to This Policy

We may update this Policy when the service, processing, providers, or law changes. The date of the latest update will be displayed with the Policy.

If a change materially affects how we use personal information or a person's rights, we will give at least 14 days' advance notice where practicable. Processing that requires consent will not begin until the required consent is captured.

This Policy is privacy information, not a contract that becomes lawful because a person clicks `Accept`. A banner or notice provides transparency and is not acceptance.

## 18. Contact Us

For privacy questions, requests, or complaints, email <privacy@ultie.org>.

For ordinary product support, email <support@ultie.org>.

You may also write to:

ULTIE LTD\
124–128 City Road\
London, England\
EC1V 2NX\
United Kingdom
