Privacy Policy

Sur Sports USA · Effective date: 22 September 2026

Sur Sports USA is a trade name and brand operated by Sur International LLC, a Wyoming limited liability company that is registered as a foreign limited liability company authorized to transact business in Massachusetts, with its principal office at 9 School Ave, Waltham, Massachusetts 02453 (“Sur Sports USA,” “we,” “us,” or “our”). We respect the privacy of student-athletes, applicants, parents, guardians, and other individuals who use our website or services. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information in connection with our student-athlete evaluation, educational placement, athletic recruitment, and related consulting services.

By using our website or submitting information to Sur Sports USA, you acknowledge the practices described in this Privacy Policy.

1. Information we collect

We may collect personal information directly from applicants, parents or guardians, educational institutions, coaches, references, or other persons involved in an applicant’s educational or athletic placement.

Depending on the services requested, the information we collect may include:

• name, date of birth, age, gender, nationality, and contact information;
• parent or guardian names and contact information;
• school information, grade level, graduation year, transcripts, grades, GPA, test scores, academic achievements, and educational history;
• athletic information, including sport, position, team, competition history, statistics, awards, rankings, athletic measurements, and performance information;
• photographs, athletic videos, highlight reels, portfolios, or other media submitted for evaluation or recruitment;
• information about colleges, universities, programs, scholarships, or athletic opportunities in which the applicant is interested;
• communications with Sur Sports USA, including emails, messages, application responses, and consultation notes;
• information contained in documents voluntarily submitted in connection with an application or placement process; and
• technical information generated through use of our website, such as IP address, browser type, device information, pages visited, and similar website-usage information.

We ask applicants not to submit sensitive personal information that is unnecessary for the services requested.

2. How we use personal information

We may use personal information for the following purposes:

• evaluating an applicant’s academic and athletic profile;
• identifying educational, athletic, scholarship, recruitment, or placement opportunities in the United States;
• preparing or assisting with student-athlete profiles, applications, recruiting materials, and related documents;
• communicating with applicants, parents or guardians, coaches, schools, universities, and other relevant parties;
• presenting applicants to potentially interested educational institutions or athletic programs;
• coordinating with service providers or partners assisting with the application or placement process;
• responding to inquiries and providing consulting or placement services;
• maintaining business, administrative, accounting, security, and compliance records;
• protecting the security and integrity of our website, systems, and services; and
• complying with legal or regulatory obligations.

We will not use personal information for materially unrelated purposes without providing appropriate notice or obtaining consent where required.

3. When we share personal information

Personal information may be disclosed when reasonably necessary to provide the services requested by the applicant or the applicant’s parent or guardian.

This may include disclosure to:

• high school, college, and university coaches;
• school, college, and university admissions offices;
• colleges and universities, including institutions affiliated with the NCAA, NAIA, or NJCAA;
• educational or athletic programs that may be relevant to the applicant;
• trusted consultants, contractors, technology providers, or other service providers assisting Sur Sports USA in providing its services;
• persons specifically authorized by the applicant or parent/guardian; and
• government authorities, regulators, courts, or other persons when disclosure is required by law or reasonably necessary to protect legal rights or safety.

We do not sell personal information, and we do not disclose applicant information to third parties for their independent advertising or marketing purposes.

4. Student-athlete profiles and recruiting materials

As part of the services requested, an applicant may authorize Sur Sports USA to prepare or distribute an academic or athletic profile containing information such as the applicant’s name, school, graduation year, sport, position, athletic statistics, academic achievements, photographs, videos, and contact or recruiting information.

Such information may be provided to coaches, educational institutions, admissions personnel, or other appropriate recipients for legitimate recruitment or placement purposes.

Applicants or parents/guardians should understand that information intentionally distributed to colleges, universities, coaches, or other independent organizations may thereafter be handled according to those organizations’ own privacy practices.

5. Applicants under 18

Applicants under the age of 18 should submit personal information with the knowledge and authorization of a parent or legal guardian.

Where Sur Sports USA determines that parental or guardian consent is required by applicable law, we may request confirmation or additional consent before collecting, using, or disclosing information relating to a minor.

Our services are not intended to collect personal information directly from children under 13 without legally required parental consent. If we learn that we have collected personal information directly from a child under 13 in circumstances requiring parental consent, we will take appropriate steps to obtain such consent or delete the information.

6. Applicants under 13

Sur Sports USA does not permit children under 13 to submit an online application or personal information directly. If an applicant is under 13, a parent or legal guardian must complete and submit the application on the child’s behalf. Sur Sports USA does not knowingly collect personal information online directly from a child under 13 without any verifiable parental consent required by applicable law.

7. International applicants and cross-border transfers

Sur Sports USA may provide services to applicants located outside the United States.

Applicants should understand that information submitted to Sur Sports USA may be transferred to, stored in, or processed in the United States and may be disclosed to educational institutions, coaches, service providers, or other appropriate recipients located in the United States or other countries.

Where applicable law requires additional protections for international transfers of personal information, Sur Sports USA will take reasonable steps to implement appropriate safeguards.

8. Data retention

We retain personal information for as long as reasonably necessary to:

• provide the services requested;
• complete an applicant’s recruitment, admissions, or placement process;
• maintain appropriate business and client records;
• resolve disputes;
• enforce agreements; and
• comply with legal, tax, accounting, or regulatory obligations.

When personal information is no longer reasonably necessary, we may securely delete, destroy, or anonymize it, subject to applicable legal and record-retention requirements.

9. Information security

Sur Sports USA uses reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction.

These measures may include access controls, password protection, secure storage, restricted access to applicant information, appropriate service-provider controls, and other safeguards appropriate to the nature of the information maintained.

No method of electronic transmission or storage is completely secure, however, and we cannot guarantee absolute security.

To the extent Sur Sports USA owns or licenses “personal information” concerning Massachusetts residents, Sur Sports USA maintains a written information security program (WISP) that includes administrative, technical, and physical safeguards appropriate to the size, scope, and type of its business, the resources available to it, and the nature and sensitivity of the Massachusetts personal information it owns, licenses, stores, or maintains, in accordance with applicable Massachusetts regulations (201 CMR 17.00). The designated coordinator of that program is Selin Şentürk.

10. Service providers

We may use third-party providers for website hosting, cloud storage, communications, document management, application processing, analytics, or other legitimate business functions.

The categories of providers we currently rely on include:

• database and application backend services (Supabase);
• website hosting and serverless functions (Netlify);
• business email services (Titan);
• cloud storage and document management;
• electronic signature services;
• payment processing services; and
• customer relationship management (CRM) services.

We seek to provide such providers only the information reasonably necessary for their services and expect them to handle information consistently with applicable confidentiality and data-security obligations.

11. Cookies and website technologies

Our website may use cookies or similar technologies for basic website functionality, security, analytics, or performance.

Where required by applicable law, users will be provided with appropriate notice or choices regarding non-essential cookies or similar technologies.

The specific cookies and similar technologies used on our website are as follows:

• Google Analytics 4 and Google Tag Manager — measurement of website usage and performance;
• Meta Pixel — measurement of advertising performance;
• essential local storage — remembering your language preference and your cookie choice so the consent banner is not shown again.

Analytics and advertising technologies are loaded in a restricted mode until you make a choice in our cookie banner, and they are enabled only if you accept. Essential local storage is required for the website to function and is not used for advertising.

12. Your choices and requests

Subject to applicable law and legitimate business or legal requirements, an applicant or parent/guardian may contact Sur Sports USA to:

• request access to personal information maintained about the applicant;
• request correction of inaccurate or incomplete information;
• request deletion of information that is no longer required;
• withdraw consent for future processing where processing is based on consent; or
• ask questions about how information is used or disclosed.

Withdrawal of consent will not affect processing or disclosures lawfully made before the withdrawal and may limit Sur Sports USA’s ability to continue providing placement or recruitment services.

13. Third-party websites and institutions

Our website or communications may contain links to colleges, universities, athletic organizations, application portals, or other third-party websites.

Sur Sports USA does not control the privacy practices of independent third parties. Applicants should review the privacy policies of those organizations before submitting personal information directly to them.

14. Data breaches and legal compliance

Sur Sports USA will respond to suspected unauthorized access to or disclosure of personal information in accordance with applicable law.

If Sur Sports USA discovers a breach of security involving covered personal information relating to a Massachusetts resident, or otherwise knows or has reason to know of the unauthorized acquisition or use of such personal information, Sur Sports USA will notify each affected individual and the applicable government authorities, including the Massachusetts Office of the Attorney General and the Massachusetts Office of Consumer Affairs and Business Regulation, as soon as practicable and without unreasonable delay, in accordance with the Massachusetts data breach notification law, G.L. c. 93H, and any other applicable breach-notification law. Notice will be provided in the manner and within any timeframes required by applicable law.

15. Changes to this privacy policy

We may update this Privacy Policy from time to time to reflect changes in our services, technology, business practices, or applicable law.

The updated policy will be posted on our website with a revised Effective Date. Where required by law or appropriate because of a material change, we may provide additional notice.

16. Contact us

Questions, requests, or concerns regarding this Privacy Policy or the handling of personal information may be directed to:

Sur Sports USA
Sur International LLC
9 School Ave
Waltham, Massachusetts 02453 USA
Attn: Privacy Requests – Selin Şentürk

Email: hello@sursportsusa.com
Telephone: +1 339 223 4349