本隐私声明提供马来文和英文版本。以下为英文版本。

PRIVACY NOTICE & PERSONAL DATA PROTECTION

XI•OS | ELEVEN OS

Operated by Digital Block Solutions

Business Registration No.: 202103192947 (JR0123380-W)

Effective Date: 21 October 2026

1. Introduction

Welcome to XI•OS | ELEVEN OS ("XI•OS", "Platform" or "System"), a football academy management platform developed and operated by Digital Block Solutions ("we", "us" or "our").

We respect the privacy of academy owners, administrators, coaches, staff, parents, guardians and players.

This Privacy Notice explains how personal data is collected, used, processed, stored, disclosed and protected in accordance with Malaysia's Personal Data Protection Act 2010 (Act 709), as amended, and applicable regulations.

2. Data Protection Roles

Digital Block Solutions acts as a data controller for personal data where it determines the purposes and means of processing, including platform account administration, subscriptions and business operations.

For player, guardian, coach and academy operational records, the subscribing academy will generally act as the data controller, while Digital Block Solutions processes data on its behalf under applicable service agreements and lawful instructions.

Actual responsibilities depend on the relevant processing activities and contractual arrangements.

3. Personal Data We Process

Depending on the services and user roles, personal data may include:

• Identity and contact information: Names, dates of birth, contact details, addresses and profile photographs.
• Academy information: Academy affiliations, branches, teams, staff roles and coaching qualifications.
• Player information: Football profiles, training attendance, match participation, assessments, performance and development records.
• Guardian information: Parent or guardian relationships, emergency contacts, permissions and fee records.
• Sensitive information: Relevant health conditions, allergies, injuries and emergency medical information where necessary.
• Technical and transaction information: Account identifiers, IP addresses, device information, access logs, invoices and payment records.

4. Purposes of Processing

We process personal data to:

1. Register and administer platform accounts.
2. Deliver football academy management services.
3. Manage players, coaches, teams, branches and schedules.
4. Record attendance, match activities and player development.
5. Process subscriptions, invoices and payments.
6. Deliver service notifications and academy communications.
7. Provide technical support and maintain platform security.
8. Improve service reliability and functionality.
9. Fulfil legal and contractual obligations.
10. Conduct marketing activities where legally permitted.

5. Sources of Personal Data

Personal data may be obtained directly from users, authorized academies, parents, guardians, coaches, administrators, payment providers and platform interactions.

Any party submitting another individual's personal data must ensure that the collection and disclosure have a lawful basis.

6. Children's Data and Sensitive Information

XI•OS may process personal data relating to minors participating in football academy programmes.

Such data must be processed for legitimate academy purposes, with appropriate parental or guardian involvement and authorization where required.

Health and medical information must receive additional safeguards, including explicit consent where required by law.

Access should be limited to appropriately authorized individuals.

The use of children's photographs or videos for promotional purposes requires appropriate separate authorization.

7. Data Sharing and Disclosure

Personal data may be disclosed, where necessary and legally permitted, to:

• Authorized academy administrators and staff.
• Verified parents and legal guardians.
• Cloud hosting and technology infrastructure providers.
• Payment processing and communication service providers.
• Authorized technical support providers.
• Regulatory authorities and law enforcement agencies where required by law.

We do not sell personal data to third parties for marketing purposes without a lawful basis.

Sharing between separate academies is subject to appropriate authorization and access controls.

8. Data Security

We are committed to implementing reasonable technical and organizational safeguards appropriate to the risks involved.

These include appropriate account authentication, role-based access controls, protection of stored and transmitted information, security monitoring and incident response procedures.

No digital platform can guarantee absolute security.

Personal data breaches will be assessed, contained and notified in accordance with applicable legal requirements.

9. Data Retention and International Transfers

Personal data will be retained only for as long as reasonably necessary for legitimate processing purposes, subject to applicable legal, operational and contractual requirements.

Following account closure or subscription termination, information will be handled under the applicable retention and deletion arrangements.

Where personal data is processed or stored outside Malaysia, relevant cross-border data transfer requirements will apply.

10. Your Rights

Subject to applicable law, individuals may:

• Request access to their personal data.
• Request correction of inaccurate information.
• Withdraw consent where applicable.
• Request limitations on certain processing activities.
• Opt out of direct marketing.
• Request data portability where the relevant legal right applies.
• Submit privacy-related inquiries or complaints.

Identity or legal guardianship verification may be required.

Requests concerning academy-controlled data may be referred to the relevant academy.

11. Mandatory and Optional Information

Certain information is necessary to establish accounts and deliver XI•OS services.

Failure to provide mandatory information may prevent access to specific features or services.

Optional information and marketing preferences will be distinguished from information necessary for service delivery.

12. Cookies, Analytics and AI Features

XI•OS may use cookies and related technologies for account authentication, security, essential functionality and usage analytics.

Where artificial intelligence or advanced analytics features are introduced or enabled, relevant information about processing purposes and additional service providers will be provided as appropriate.

Any further processing outside the disclosed purposes must have a valid lawful basis.

13. Changes to This Notice

We may revise this Privacy Notice to reflect changes in our services, data processing practices or legal requirements.

Material changes will be communicated through appropriate channels.

14. Contact Information

For personal data access requests, corrections, complaints or privacy inquiries, please contact:

Digital Block Solutions

Business Registration No.: 202103192947 (JR0123380-W)

Business Address:

Phone: +60 19-895 5194

Email: digitalblocksolutions@gmail.com

Email Subject: XI•OS Privacy / PDPA Request

© 2026 XI•OS | ELEVEN OS — Digital Block Solutions.

All rights reserved.