Privacy Policy

GlassHouse UK Group Ltd (“GlassHouse Group”, “we”, “us”, “our”), trading as 360Engage, operates two fan-facing products on a shared 360ENGAGE backend: GameDay Companion, a matchday voice and chat concierge. The Services may be accessed through different channels, including, where applicable, a QR code, website, mobile application or telephone. The information collected and the manner in which it is stored may vary depending on the access channel used. Where supported, a text-only transcript of a session may be stored locally on the user’s device to assist with troubleshooting and service improvement. Such transcripts are not stored on our servers and remain on the user's device until the relevant app or browser data is cleared or the application is uninstalled. Where the Service is accessed through a channel that does not support local storage, no local transcript will be stored on the user's device. Because they share the same backend and data handling, one policy covers all of them, this policy explains what information the Services collect, how it's used, and your rights over it.

The Services are developed on our behalf by our technology delivery partners. Questions about this policy, or requests concerning your data, can be sent to connect@glasshouse-group.co.uk.

1. Information we collect

The Services have no user accounts or sign-in. We don't collect your name, email address, physical address, or payment details through the Services themselves.

Voice audio

When you use either Service's voice concierge, your microphone audio is captured and streamed in real time so it can understand your question and speak a response back to you. This audio is processed live by the third-party providers listed in Section 3.

Text chat messages

When you use the text-based concierge chat, the messages you type are sent to our third-party provider to generate a response.

Fan data we extract and keep

Building a picture of what fans want is central to what the Services do. From your conversation, we extract and store structured details about you, linked to a random session identifier rather than your name. This can include things like: who you're attending with, where you're travelling from, how often you attend, seating and food preferences, and what you're interested in buying. We keep this to personalise your experience, and to help the club understand and serve its fans better.

Session transcripts (stored on your device only)

Where the Service is used through the app or a browser, it keeps a local, text-only transcript of each session, to help us debug issues and improve response quality. We automatically redact anything that looks like an email address, phone number, payment card number, or booking code before it's written, though this doesn't reliably catch names or spoken addresses. These transcripts stay on your device and are deleted if you clear the app's storage or uninstall it. [To be confirmed: how this applies where the voice companion is accessed by phone, with no local device storage.]

Call and session metadata (stored on our servers)

To run and monitor the voice service, our server records, per call: a call ID and session identifier (not tied to your identity), which club's concierge you spoke with, the AI model used, and technical details like connection status and timestamps. This does not include the content of what you said.

QR code redirect

(GameDay Companion only) Scanning a GameDay Companion QR code opens the app on our domain. We don't log anything from this beyond serving you the page.

2. How we use this information

We use the information above to:

• provide the voice and chat concierge, and generate the responses you ask for
• build up what we call the Fan Graph: a picture of your engagement and preferences that helps personalise your experience and helps the club understand its supporters
• [describe here if this data is also used for sponsor or partner offers — see note at the end of this document]
• keep the voice service reliable, and fix bugs using the redacted, on-device transcripts

We do not sell your information.

3. Third-party processors

To provide the concierge experience, audio or text from your session is sent to the following providers for processing:

• Google Gemini Live API

These providers may process data outside the UK or EEA (including the US). Where that happens, we rely on their own safeguards, such as standard contractual clauses.

4. Data retention

• Voice audio is streamed for the session and not retained afterwards.
• Fan Graph data is kept for [X months/years, to be confirmed] to build up a useful picture over time, then deleted.
• Call/session metadata is kept only as long as needed to run and monitor the service, then deleted.
• Local transcripts stay on your device until you clear the app's data or uninstall it, where applicable.
• Fan Graph data is retained for as long as reasonably necessary to provide and improve the Services, personalise the fan experience, understand patterns of engagement and preferences, and support the relevant club in understanding and serving its supporters.
• Unless a longer retention period is required or permitted by applicable law, Fan Graph data linked to a session identifier will be retained for a maximum period of [12/24] months from the date of collection, following which it will be deleted or irreversibly anonymised.
• We may use Fan Graph data to help the relevant club understand its supporters and improve its services, communications and fan experience.
• We may also use aggregated or anonymised information derived from Fan Graph data for reporting, research, analytics, commercial planning and other legitimate business purposes.
• We will not disclose Fan Graph data identifying an individual fan to a sponsor or commercial partner for that party's own direct marketing or profiling purposes unless we have a lawful basis to do so and, where required by applicable law, have obtained the fan’s consent or otherwise provided the fan with the applicable choice or opt-out mechanism.
• Where sponsor or partner activity is undertaken using information derived from the Fan Graph, we will, wherever reasonably practicable, use aggregated or anonymised information so that individual fans are not directly identified.
• Where a fan affirmatively chooses to receive an offer, communication or service from a sponsor or other commercial partner, the information necessary to fulfil that request may be shared with the relevant sponsor or partner. In such circumstances, the sponsor or partner may process that information in accordance with its own privacy notice, which will be made available to the fan at the relevant point of collection or interaction.

5. Security

Audio and chat data are transmitted using encrypted connections (HTTPS/WSS). Voice sessions use short-lived, single-use tokens rather than persistent credentials.

6. Children's privacy

The Services are not directed at children, and we don't knowingly collect personal information from children. Because the Services are used at football grounds and can capture household details such as who you're attending with, we take extra care here.

The Services are intended for use by adults and are not directed at children. We do not knowingly seek to collect personal information directly from children or knowingly permit children to create accounts or provide personal information through the Services.

The Services may nevertheless be used in a family or group setting, including at football grounds and other venues where children may be present.

An adult user may voluntarily provide information about the people attending an event with them, including information indicating that a child is part of their group. Where such information is provided by an adult user, we process it as part of the information associated with that user's session and do not use it for the purpose of identifying, profiling or directly marketing to the child.

If you believe a child has used either Service and shared personal information, contact us at connect@glasshouse-group.co.uk.

7. Your rights

If you're in the UK or EEA, you have the right to:

• ask what we hold about you
• ask us to correct or delete it
• object to or restrict certain uses
• get a copy in a portable format
• complain to the ICO (ico.org.uk) or your local authority

Because there's no account, we can generally only find your Fan Graph or session data using your session ID or an approximate time and club. Local transcripts are entirely in your control — you can delete them any time by clearing the app's storage, where applicable.

To use any of these rights, contact us at connect@glasshouse-group.co.uk.

8. Changes to this policy

We may update this policy as the Services change. Continued use after an update means you accept the revised version.