To: Arabia Sports Network (ASN), the Organizers of Gen Alpha League

From: Parents and Legal Guardians of Children Participating in Gen Alpha League

Subject: Objection to Mandatory Facial Recognition and Collection of Children Facial Data as a Condition of Participation

Dear Arabia Sports Network and Gen Alpha League Organizers,

We, the undersigned parents and legal guardians of children participating in Gen Alpha League, are writing to respectfully share our concerns regarding the requirement to submit multiple facial photographs of our children, including front-facing and side-facing images, as part of the registration and onboarding process on the Arabia Sports Network platform.

We fully appreciate the importance of verifying participants' identities, ensuring fair competition, managing attendance, and maintaining the safety and integrity of sporting activities. We support these objectives and value the organizers' efforts to run a well-organized and secure competition.

However, we do not believe that mandatory facial recognition or the collection and processing of children's facial data should be imposed as a condition of participation in a youth football competition, particularly without a clear explanation of its necessity, proportionality, data retention, and available alternatives.

We have reviewed the published Terms of Use and Privacy Policy of Arabia Sports Network (15 October 2026) and recently updated on 21 October 2026 with minor modifications and would welcome further clarification on how children's facial data and identity documents are collected and used.

Our Concerns

1. Protection of children's privacy
Children's facial images and identity information are particularly sensitive in the context of an online platform. Parents should be able to understand precisely what information is collected, how it is processed, who can access it, and how long it is retained.

2. Necessity and proportionality
We question whether collecting multiple facial images and using facial recognition for sign-in and attendance is necessary for participation in a football competition when less intrusive alternatives may be available.

Identity verification and attendance management can potentially be achieved through conventional methods without requiring children to undergo facial recognition.

Similarly, requiring parents and legal guardians to undergo facial recognition in order to sign in to the app and view their child's details is not only unnecessary but also risky. Facial data is highly sensitive and, unlike a password, cannot be changed if it is leaked, misused, or accessed without authorization. Collecting it unnecessarily exposes both parents and children to avoidable privacy and security risks. Secure access to a parent account can be ensured through standard methods such as a password, a one-time code sent by SMS or email, or two-factor authentication, without collecting parents' facial data.

3. Transparency and informed parental choice
The published policies do not adequately clarify all aspects of the facial recognition process, including the precise nature of the technology used, the handling of any biometric templates generated, the retention periods for the original photographs and derived data, and the availability of alternative verification methods.

Parents should receive clear and comprehensive information before their children's facial data is collected and processed.

4. Data protection and accountability
The collection and processing of children's personal data should be justified, limited to what is necessary, appropriately secured, and conducted in accordance with applicable Lebanese law, including Law No. 81/2018 on Electronic Transactions and Personal Data especially the part related to  notifying the Ministry of Economy and Trade about the company's activities and obtaining the permit if needed.

We believe that these matters warrant clarification before facial recognition is made a mandatory requirement for participation.

Our Collective Requests

In light of these concerns, we respectfully request that Arabia Sports Network and the Gen Alpha League organizers:

1. Remove mandatory facial recognition as a condition of participation.
No child should be required to submit facial images for automated identification or attendance recognition as a prerequisite for registering or participating in Gen Alpha League.

2. Provide a non-biometric alternative.
Where identity verification or attendance tracking is necessary, parents and children should be offered an effective alternative, such as manual identity verification, team registration records, conventional check-in procedures, or another method that does not rely on facial recognition.

3. Clarify the handling of previously collected data.
Please explain what happens to the facial photographs, any derived facial templates, and identity document images already submitted by parents and children who do not wish to participate in facial recognition.
We request that unnecessary facial data be deleted upon request, subject to any applicable legal retention requirements, and that the company explain how deletion is implemented.

4. Provide transparent information about data processing.
Please provide a clear written explanation of the purposes of collecting facial images and identity documents, the technologies used, the applicable retention periods, any third-party service providers involved, the locations in which data is stored or processed, and the procedures available to parents to exercise their data protection rights.

5. Confirm that children will not be disadvantaged for refusing facial recognition.
We request written confirmation that children whose parents decline facial recognition will not be excluded from the competition, penalized, or otherwise disadvantaged, provided that they satisfy the legitimate registration, eligibility, and identity verification requirements through an available alternative procedure.

6. Remove the facial recognition requirement for parents and legal guardians.
Facial recognition of parents and legal guardians is not necessary to sign in to the app or to access their child's details. We request that parents be able to log in and view their child's information using conventional secure authentication methods, such as a password, one-time code, or two-factor authentication, without submitting facial images.

Our Position

This petition is not an objection to identity verification, legitimate security measures, or the use of technology to improve the organization of sporting activities.

It is an objection to making facial recognition and the associated collection of children's facial data a mandatory condition for participation when the necessity of this approach has not been adequately established and less intrusive alternatives may be available.

We believe that children should be able to participate in football competitions without being required to surrender unnecessary personal information or undergo facial recognition as a condition of playing the sport.

We therefore ask Arabia Sports Network and the Gen Alpha League organizers to review the current registration process, engage constructively with parents, and implement an effective non-biometric alternative.

We respectfully request a written response prior to the registration deadline set by Gen Alpha League, addressing the requests set out above and explaining the alternative registration arrangements that will be made available.

We hope this matter can be resolved constructively, in the best interests of the children, while preserving the integrity and accessibility of the competition.

Yours faithfully,

The undersigned parents and legal guardians of children participating in Gen Alpha League