Effective Date: February 2026

FairWhistle, Inc. ("FairWhistle," "we," "our," or "us") is committed to safeguarding the privacy, safety, and dignity of children and minor participants who use our Services.

This Minor Policy explains how we process personal information relating to individuals under the age of eighteen (18) in connection with our websites, applications, digital match reporting tools, messaging systems, analytics features, AI-assisted tools, integrations, and related services (collectively, the "Services").

FairWhistle operates primarily as a technology service provider to leagues, associations, governing bodies, and other sports organizations ("Customers") and processes personal information in accordance with Customer instructions, contractual obligations, and applicable law.

This Minor Policy supplements and is incorporated into FairWhistle's Data Privacy Policy and Terms of Service (collectively, the "Governing Policies"). In the event of any conflict, the Governing Policies shall control, except that where this Minor Policy provides greater protection for minor participants, the provisions of this Minor Policy shall govern.

1. Scope and Minor Designation

This Minor Policy applies to:

• Children under thirteen (13)

• Minors under eighteen (18)

• Youth officials participating in league-authorized programs

FairWhistle provides its Services to Customers in a business-to-business capacity. FairWhistle relies on the applicable Customer to designate whether a participant is a minor and to provide accurate age classification information. FairWhistle does not independently verify participant age and processes minor data in reliance on information provided by the Customer.

Customers are responsible for determining eligibility of participants and ensuring that minor participants are authorized to access the Services.

2. Children Under 13 (COPPA Compliance)

FairWhistle complies with the Children's Online Privacy Protection Act ("COPPA") and applicable state child privacy laws. FairWhistle acts as a service provider to its Customers and processes information regarding children under thirteen (13) only at the direction of and on behalf of the Customer.

FairWhistle does not knowingly collect personal information directly from children under thirteen (13) without verified parental or legal guardian consent obtained by the Customer.

"Verified parental consent" means consent obtained through a mechanism that provides reasonable assurance that the person providing consent is the child's parent or legal guardian, consistent with requirements under COPPA and applicable state law. Acceptable verification mechanisms may include, without limitation, signed consent forms, credit card or government ID verification, video call confirmation, or other methods approved by the Federal Trade Commission. Customers are solely responsible for implementing and documenting a compliant verification method.

FairWhistle does not operate youth registration systems and does not independently solicit information from children.

Customers are solely responsible for:

• Obtaining, documenting, and maintaining legally required parental or guardian consents

• Providing appropriate notices to parents or guardians

• Ensuring minor accounts are authorized prior to activation

• Ensuring that data provided to FairWhistle has been lawfully collected

FairWhistle processes such information in reliance upon the Customer's representation that appropriate consent has been obtained.

For children under 13:

• Access must be authorized by a Customer

• Personal information is used solely for officiating development, match administration, safeguarding, and league compliance

• Data will not be publicly displayed unless expressly authorized by the governing league and permitted by law

• Data will not be sold, rented, sublicensed, or commercially exploited

• Parents or guardians may request access to, correction of, or deletion of their child's information by contacting privacy@fairwhistle.com, subject to applicable law and league recordkeeping obligations
  

3. Minors Under 18

Users under eighteen (18) may access the Services only with parental or guardian permission and under league supervision.

Minor data collection is limited to what is reasonably necessary for officiating evaluation, assignment, discipline tracking, safeguarding, compliance, and development.

For California residents, additional protections apply to minors under sixteen (16) pursuant to the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). FairWhistle does not sell or share personal information of minors under sixteen (16) without opt-in consent. The California Youth Data Addendum in Section 12 governs in the event of any conflict with the general provisions of this section.

Minor personal information is not:

• Sold

• Monetized

• Resold or sublicensed

• Used for advertising

• Used for cross-context behavioral advertising

• Used for behavioral profiling or targeted marketing

AI-generated summaries or analytics involving minors are informational only and are not used to make automated disciplinary, employment, certification, or advancement decisions.

Visibility of minor data is determined by the applicable Customer. FairWhistle provides configurable visibility controls but does not independently publish minor performance data.

FairWhistle may restrict, suspend, or remove accounts where safeguarding concerns, misuse of the platform, or violations of youth protection standards are identified.

4. Youth Development Data Purpose

FairWhistle processes minor participant data solely for legitimate youth sports administration and development purposes.

The collection and use of youth officiating data is intended to support:

• Education and development of officials

• Match administration and assignment management

• Constructive feedback and performance improvement

• Safeguarding and referee protection

• League governance and operational oversight

Minor data is not collected or used for employment screening, commercial profiling, targeted advertising, or unrelated commercial purposes.

FairWhistle may also use aggregated, de-identified minor data for internal platform improvement and product development consistent with Section 10 of the Data Privacy Policy, provided such data cannot reasonably identify any individual minor.

FairWhistle's platform is designed to support positive developmental environments for youth officials and to assist leagues in promoting respectful and safe sporting communities.

5. Artificial Intelligence and Minor Data

AI tools may assist with summarizing evaluations, improving tone, or generating analytics. AI outputs are informational only and are designed to support constructive communication and administrative efficiency.

For minor users, AI-assisted features are configured to default to the most privacy-protective settings available. FairWhistle has conducted and will maintain Data Protection Impact Assessments (DPIAs) for AI features that process minor data, consistent with obligations under the California Age-Appropriate Design Code Act (AADCA).

Customers may authorize expanded AI feature access for minor users only to the extent permitted by applicable law and consistent with the governing league's safeguarding obligations. Any such authorization must be documented and maintained by the Customer.

FairWhistle does not:

• Use identifiable minor data to train public AI models

• Use identifiable minor data to train external commercial AI systems

• Use AI to make automated decisions that produce legal, disciplinary, employment, or certification effects

AI processing involving minor data is limited to assisting authorized Users in understanding evaluations and trends.

6. SafeSport Alignment and Safeguarding

FairWhistle is designed to support constructive and safe officiating environments consistent with youth safeguarding principles, including those promoted by the U.S. Center for SafeSport and similar youth protection frameworks.

FairWhistle does not accept designation as a mandatory reporting authority and does not undertake obligations as a mandated reporter under state or federal law. FairWhistle does not replace league safeguarding programs and does not serve as the reporting authority for SafeSport matters.

Customers remain solely responsible for compliance with all mandatory reporting obligations applicable to their organization and personnel.

Customers remain responsible for:

• SafeSport compliance

• Mandatory reporting obligations

• Background screening requirements

• Youth protection program administration

• Investigations and disciplinary actions

The platform supports safeguarding by:

• Encouraging constructive feedback practices

• Prohibiting harassment, intimidation, or retaliation

• Allowing review of communications when reasonably necessary to investigate safety concerns

• Providing tools that may assist leagues in monitoring behavior and protecting officials

7. League Governance and Decision Authority

FairWhistle provides technology tools that support evaluation, reporting, and development processes. FairWhistle does not determine referee assignments, advancement, discipline, certification, or employment decisions.

All governance decisions relating to participants, including minors, remain solely within the authority of the applicable Customer or governing body. FairWhistle does not serve as an adjudicator of disputes between participants, leagues, or governing bodies.

8. Safeguarding Incident Reporting and Investigations

Where the Services include communication or reporting tools, FairWhistle may review content when reasonably necessary to:

• Investigate suspected harassment, abuse, or safeguarding concerns

• Comply with legal obligations

• Assist Customers in responding to safety incidents

FairWhistle may preserve relevant platform data to assist Customers or appropriate authorities in safeguarding investigations where required by law or contract. FairWhistle does not independently conduct disciplinary proceedings related to safeguarding matters.

9. Data Minimization, Retention, and Security

FairWhistle collects and processes minor data only to the extent reasonably necessary to provide the Services and support officiating development, administration, and safeguarding.

Minor personal information is retained only as long as reasonably necessary to fulfill the purposes described in this Minor Policy, satisfy league recordkeeping obligations, or comply with applicable law.

Upon a verified deletion request from a parent, guardian, or eligible minor, FairWhistle will delete or de-identify minor data unless retention is required by applicable law or an active Customer contract. Requests may be submitted to privacy@fairwhistle.com.

Aggregated or de-identified data derived from minor data may be retained for benchmarking and product improvement and will not reasonably identify individual minors.

Minor data is encrypted in transit and at rest. Access to minor data is restricted to authorized league administrators and personnel. While industry-standard safeguards are implemented, no system can guarantee absolute security.

10. No Sale or Commercial Exploitation

FairWhistle does not:

• Sell minor personal information

• Share minor data for targeted advertising

• Engage in cross-context behavioral advertising involving minors

• Commercially monetize individual-level minor performance metrics

Aggregated and de-identified data may be used for internal analytics and product improvement consistent with the Data Privacy Policy.

11. Third-Party Data Sources and Integrations

FairWhistle may receive participant information, including minor data, from Third-Party Services at the direction of a Customer. These services may include scheduling systems, assignment platforms, registration systems, payment processors, federation databases, or other authorized integrations.

FairWhistle processes such information:

• As a service provider to the Customer

• In reliance upon the Customer's representation that it has obtained required legal authority and parental consents

• For the limited purposes described in this Minor Policy and the Governing Policies

FairWhistle does not independently verify:

• Age designations

• Parental consent status

• The legality of Third-Party data collection practices

Notwithstanding the foregoing, where FairWhistle receives data from a Third-Party Service that expressly designates a participant as a minor, FairWhistle will apply the protections set forth in this Minor Policy to such participant regardless of whether independent verification was conducted.

Customers are solely responsible for ensuring integrations comply with youth protection, child privacy, labor, and safeguarding laws. FairWhistle is not responsible for the privacy practices or compliance posture of Third-Party Services.

12. California Youth Data Addendum

This section applies to residents of California under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and the California Age-Appropriate Design Code Act (AADCA).

FairWhistle processes minor personal information as a service provider and does not sell or share personal information of minors under sixteen (16).

Minor personal information is not used for targeted advertising or cross-context behavioral advertising.

To the extent minor data constitutes "Sensitive Personal Information" under California law, it is used only as necessary to provide the Services and for safeguarding and compliance purposes.

For AI-assisted features involving minor users, FairWhistle defaults to the most privacy-protective settings available and conducts Data Protection Impact Assessments consistent with the AADCA.

California residents under 18, or their parents or guardians, may request:

• Access to personal information

• Correction of inaccurate information

• Deletion of personal information

• Limitation of use of sensitive personal information

All requests are subject to legal and league recordkeeping requirements. Requests may be submitted to privacy@fairwhistle.com.

13. Dispute Resolution and Governing Law

This Minor Policy is governed by and incorporated into the dispute resolution, arbitration, limitation of liability, and governing law provisions set forth in the Terms of Service.

14. Updates

We may update this Minor Policy periodically to reflect changes in law, our practices, or the Services. Material changes will be communicated to Customers in advance where practicable. Continued use of the Services constitutes acceptance of the updated Policy.

15. Contact Us

FairWhistle, Inc.
406 11th Ave N, Suite 250
Nashville, TN 37203
privacy@fairwhistle.com