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Effective July 17, 2026
This Coach–Student Communication and Safe Messaging Policy ("Policy") establishes the standards, procedures, and safeguards governing communications between Starting XI — College Soccer Recruiting LLC ("Company," "SXI") coaches and staff and student athletes, particularly minor student athletes. This Policy codifies Company's intentional design choice of direct student–coach communication with parent oversight, defines the boundaries of parent monitoring, and establishes Company's youth-protection framework.
This Policy applies to all Company staff, contractors, coaches, and administrators who communicate with student athletes through the SXI platform or otherwise in connection with SXI services. This Policy is incorporated by reference into the Client Service Agreement, the Terms of Service, and the Liability Waiver and Disclaimer Addendum.
Approximately 90% of SXI users are under the age of 18, and a meaningful subset is under 13. This Policy is drafted with that user base as the primary consideration.
All Coaches and Company Staff who communicate with student athletes must comply with the following code of conduct:
3.1 Professional Tone and Content
3.2 Prohibited Behaviors
3.3 Written Acknowledgment. Every Coach and Company Staff member must sign a written acknowledgment of this Code of Conduct at hire and re-execute it annually. Signed acknowledgments are retained in the personnel file for the greater of seven (7) years or the duration of employment plus three (3) years.
4.1 Current Posture. As of the effective date of this Policy, Company operates with its founding team only and has not yet implemented the formal three-part background-check program described in Sections 4.4 through 4.8. Company's founding team members have self-disclosed any information that would be disqualifying under the standards described in this Section 4.
4.2 Program Trigger — Team Expansion. Prior to onboarding any additional Coach or Company Staff member who will communicate directly with minor student athletes beyond the founding team, Company will implement the three-part background-check program described in Sections 4.4 through 4.8. The Compliance Officer designated under Section 2 is responsible for administering and documenting the program upon that trigger.
4.3 Interim Baseline — Reserved. Company reserves the right to implement portions of the program described below (for example, Center for SafeSport certification and NSOPW sex-offender registry checks) on an interim basis for the founding team before the full program is triggered under Section 4.2. Any interim baseline actually implemented is documented in the Compliance Officer's file and available upon regulatory or insurance inquiry.
4.4 Center for SafeSport Certification. Upon the Section 4.2 trigger, every Coach and Company Staff member who communicates directly with minor student athletes shall complete the Center for SafeSport online training and certification (or an equivalent recognized youth-protection training program). Certification is completed prior to first contact with any minor student athlete and refreshed annually. A dated completion certificate is retained in the personnel file.
4.5 National Criminal Background Check. Upon the Section 4.2 trigger, every Coach and Company Staff member shall undergo a national criminal background check administered by a reputable third-party vendor (for example, Sterling Talent Solutions, HireRight, JDP, or Checkr, subject to Company selection). The check includes a national criminal history search covering all counties of residence for the preceding seven (7) years plus a federal criminal history search. Results are reviewed by the Compliance Officer against Company's written disqualification matrix. Rechecks are performed at hire and at three-year intervals thereafter, or upon any known adverse event.
4.6 Sex-Offender Registry Check. Upon the Section 4.2 trigger, every Coach and Company Staff member shall be checked against the U.S. Department of Justice National Sex Offender Public Website (NSOPW) and the sex-offender registry for each state in which the individual has resided in the preceding ten (10) years. Any hit on any registry is an automatic disqualification. Rechecks are performed at hire and at annual intervals thereafter.
4.7 Disqualification Matrix. Upon the Section 4.2 trigger, Company will maintain a written disqualification matrix used by the Compliance Officer to evaluate background-check results. Automatic disqualifications will include: any felony conviction; any conviction involving a minor (regardless of severity or age of conviction); any conviction involving violence, sexual misconduct, exploitation, or endangerment; any sex-offender registry hit; and any material misrepresentation on the background-check consent or application. Other convictions will be evaluated on a case-by-case basis by the Compliance Officer with documented rationale. The disqualification matrix will be an internal document not subject to disclosure to Coaches or applicants.
4.8 Documentation and Retention. Upon the Section 4.2 trigger, all background-check documentation (SafeSport certificates, background-check reports, sex-offender registry results, Compliance Officer review notes, and disqualification determinations) will be retained in each Coach's personnel file for the greater of seven (7) years or the duration of the Coach's tenure plus three (3) years. Documentation will be available for review by Company counsel in the event of any incident, regulatory inquiry, or litigation.
All communications between Coaches or Company Staff and minor student athletes must occur through the SXI platform, including but not limited to messaging, chat, video-conferencing initiated through the platform, and email drafted and sent through the SXI email infrastructure.
5.1 Off-Platform Contact — Prohibited. Off-Platform Contact between Company Staff and minor student athletes is prohibited except in the narrow exceptions in Section 5.2. Prohibited Off-Platform Contact includes personal text messages, personal email addresses, personal social media (Instagram, TikTok, Snapchat, or similar), private messaging applications (WhatsApp, Signal, Discord DMs, or similar), phone calls not initiated through the platform, and in-person contact outside a Company-organized event.
5.2 Narrow Exceptions. Off-Platform Contact is permitted only in the following circumstances, and each instance must be logged and reported to the Compliance Officer within 24 hours:
5.3 Enforcement. A Coach or Company Staff member who initiates or accepts prohibited Off-Platform Contact with a minor student athlete is subject to disciplinary action up to and including immediate termination and referral to law-enforcement authorities where the conduct suggests suspected abuse or endangerment. A single documented violation of Sections 5.1 or 5.2 is grounds for termination; no progressive-discipline process is required.
In addition to the code-of-conduct restrictions in Section 3, the following communications are strictly prohibited between Company Staff and minor student athletes, whether on-platform or (if permitted under Section 5.2) off-platform:
7.1 California Child Abuse and Neglect Reporting Act (CANRA). California's Child Abuse and Neglect Reporting Act, Cal. Penal Code §§ 11165–11174.3 ("CANRA"), designates certain individuals as "mandated reporters" who are required by law to report known or suspected child abuse or neglect to a designated law-enforcement or child-protective-services agency. Whether a specific Coach or Company Staff member is a mandated reporter under CANRA depends on their individual qualifications and employment context (for example, coaches employed by youth-services organizations may be mandated reporters under Cal. Penal Code § 11165.7(a)(20)).
Regardless of individual mandated-reporter status, Company treats all Coaches and Company Staff as subject to internal reporting obligations under this Policy. Any Reportable Concern must be escalated to the Compliance Officer within 24 hours of the Coach or Company Staff member becoming aware of it.
7.2 Internal Escalation Path. The internal escalation path for any Reportable Concern is:
7.3 Cooperation with Law Enforcement. Company cooperates fully with law-enforcement and child-protective-services inquiries regarding any Coach or Company Staff conduct. Company will preserve all relevant platform communications, personnel records, and internal documentation in response to a valid legal request and will consult counsel before responding.
Company's coaching model provides for direct communication between the student athlete and Company coaches. The parent- or guardian-linked account provides monitoring, notification, and control functions but does not participate as the student athlete in coach communications. This Section 8 codifies the boundaries.
8.1 Parent Rights Through the Linked Account. The parent has the six enhanced controls set forth in Privacy Policy Section 4.6: email notification of coach communications, message review, coach-specific restrictions on written request to Company, session termination on written request to Company, complete communication log export, and right to prohibit AI feature use. Operational procedures for each control are set forth in the Minor Data Handling Policy Section 7A.
8.2 Parent Restrictions. The parent or legal guardian shall not:
8.3 Consequences of Impersonation. Repeated impersonation defeats the coaching architecture that Company's service model relies upon. Where impersonation is detected, Company will notify the parent in writing, request that the practice cease, and provide reminder of the parent-account monitoring and control features available for legitimate oversight. Persistent impersonation is grounds for termination of Company services under CSA Exhibit B Section 8 (Termination by Company).
8.4 Direct Parent–Company Communications. Nothing in this Section restricts the parent's right to communicate directly with Company Staff or the Compliance Officer through the parent's own account or through Getstarted@sxirecruiting.com. Concerns, questions, and requests should be directed through those channels rather than through impersonation of the student.
Company's coaching model provides for direct communication between the student athlete and the assigned Coach. Company has adopted this design because effective recruiting coaching depends on developing the student athlete's ability to communicate directly with college coaches — the recruiting process itself requires direct communication skills. Coaching this skill requires modeling and practice through direct student–coach dialogue during the SXI engagement.
The parent or legal guardian, by executing the Client Service Agreement, accepts this design in exchange for the enhanced monitoring, notification, review, restriction, session-termination, log-export, and AI-opt-out controls set forth in Privacy Policy Section 4.6 and the operational procedures in Minor Data Handling Policy Section 7A.
The parent retains the right at any time to (a) review any communication, (b) restrict any Coach, (c) terminate any session, (d) export the full communication log, and (e) escalate any concern to the Compliance Officer.
Communication tone, complexity, and content standards vary across the student athlete age bands. Coaches must adjust accordingly:
10.1 Under 13. For students under 13, Coaches must (a) use vocabulary and concepts appropriate for the student's developmental stage, (b) avoid discussion of financial or scholarship topics beyond high-level acknowledgment (defer detailed discussion to parent-included conversations), and (c) actively encourage parental involvement. Where an under-13 user has enrolled through the Zoom-based COPPA consent process (Minor Data Handling Policy Section 4.2), Authorized Staff coordinate with the parent on message review on a case-by-case basis.
10.2 Ages 13 to 15. For students aged 13 to 15, Coaches use age-appropriate content while introducing the student to the direct-communication skills required for later recruiting outreach. Scholarship and financial-aid discussions may occur but should be framed in a general educational context, with parents encouraged to participate for detailed financial planning.
10.3 Ages 16 to 17. For students aged 16 to 17, Coaches engage in the direct student–coach communication model that mirrors college recruiting practice. Scholarship, financial-aid, and admissions topics may be discussed substantively. Parent oversight remains active per Section 8.
10.4 Age 18 and Older. For adult student athletes (18+), the direct-communication model applies without the enhanced parental control overlay described in Privacy Policy Section 4.6, unless the adult student expressly elects to retain parent access through account settings.
All Platform Communications between Coaches or Company Staff and student athletes are logged in the ordinary course of business under the service documentation provisions of CSA Exhibit B Section 3 (or the standalone Refund Policy Section 3). Retention follows the Privacy Policy Section 9 schedule.
Parents may request full export of the communication log at any time under Privacy Policy Section 4.6(e), following the operational procedure in Minor Data Handling Policy Section 7A.6.
For potential regulatory review or litigation, Company will preserve communication logs pursuant to a written legal hold once notified of any actual or reasonably anticipated proceeding.
Incidents involving alleged violation of this Policy, alleged coach misconduct, off-platform contact attempts, or student safety concerns are handled under the following escalation procedure:
12.1 Intake. Reports may be submitted by the student athlete, parent or legal guardian, another Coach or Company Staff member, or any third party. Reports are received by the Compliance Officer at Getstarted@sxirecruiting.com or by phone.
12.2 24-Hour Acknowledgment. The Compliance Officer acknowledges every report in writing within 24 hours of receipt.
12.3 5-Business-Day Preliminary Review. The Compliance Officer conducts a preliminary review within 5 business days, including interviews with the reporter, the involved Coach, and any relevant witnesses. Communication logs, background-check documentation, and other records are reviewed as appropriate.
12.4 Interim Suspension. Where the report alleges Coach misconduct with a minor or off-platform contact prohibited by Section 5, the Compliance Officer immediately suspends the involved Coach from client contact pending review. Suspension is not a determination of misconduct.
12.5 30-Day Final Determination. The Compliance Officer issues a final written determination within 30 days of the initial report, or notifies the parent and (where appropriate) the student in writing of the reason for extended review. Extended review may not exceed 60 days without written justification.
12.6 Cooperation with Law Enforcement and CPS. Where the incident involves suspected abuse, neglect, or endangerment of a minor, or where CANRA mandated-reporter obligations attach, Company cooperates fully with law-enforcement and child-protective-services inquiries. External reporting is not delayed for internal review.
12.7 Documentation and Retention. Every incident intake, review step, and final determination is documented and retained for at least seven (7) years, for potential regulatory review and litigation preservation.
Client, on behalf of Client and the student athlete, acknowledges the following:
This Policy is reviewed and updated at least annually and upon any material change to Company's Coach staffing, background-check program, technology architecture, or applicable law. The most current version of this Policy is available at the SXI platform Legal / Policies section and is provided to every Client upon execution of the Client Service Agreement.
Questions, reports, or requests regarding this Policy may be directed to: