Minors — applicable rules

The threshold is the one set in Italy pursuant to Article 8 GDPR: a child who has reached the age of fourteen may consent independently in relation to information society services; below that age consent must be given by the holder of parental responsibility.

The Controller has chosen not to allow accounts to be created below the age of fourteen, rather than to build a mechanism for collecting parental consent. That choice is deliberate: a consent mechanism that is never actually completed affords no protection, whereas the prohibition operates automatically.

The date of birth is required because, without it, the rule set out in the preceding paragraph could not be verified. The same item is used to apply the prohibition on publishing minors’ images on shareable cards.

The data is processed for protective and not for profiling purposes: it is not used for advertising, it is not made visible to anyone outside the team and it is not disclosed to third parties.

A child under the age of fourteen does not have an account; their record is nonetheless entered and managed by the team’s staff, in the same way as for any registered player who does not use the application. The data processed relate to call-ups, attendance and goals and, where the team uses those modules, to dues and to the expiry of the medical examination.

The application’s privacy notice applies to that processing, in particular the chapter on data entered by the team. The holder of parental responsibility may exercise the relevant rights by writing to privacy@panka.app, with no need for an account.

Shareable cards are images intended for sharing in the team’s chat. A minor’s image is never shown on a card: this is not a preference left to the user but a control applied server-side, which the application cannot override.

Names remain permitted in the form of a nickname. A prohibition extending to names would prevent a youth team from sharing anything at all, whereas showing only a nickname does not allow the minor to be visually identified.

Reports may be sent to privacy@panka.app. A holder of parental responsibility may request the removal of a child’s data from Panka: the Controller will act on the request directly, without any need to approach the sports club.