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PRIVACY POLICY

Effective Date: February 5, 2026

1. Introduction

Prognozza ("we," "our," "us," or the "Company") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application Prognozza (the "App"), available on iOS and Android platforms.

By using our App, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this policy, please do not use our App.

This Privacy Policy complies with applicable data protection regulations, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant privacy laws.

2. Information We Collect

2.1 Information You Provide Directly

  • Account Information: When you create an account, we collect your email address, username, and authentication credentials
  • Profile Information: Optional information you provide such as display name, profile picture, and preferences
  • Payment Information: When you make purchases, payment processing is handled by third-party payment processors (RevenueCat, Google Play, Apple App Store). We do not store credit card details
  • Communications: Information you provide when you contact us for support or feedback
  • User Content: Any content you create, share, or interact with in the App, including forum posts, comments, and betting strategies

2.2 Information Collected Automatically

  • Device Information: Device type, operating system, unique device identifiers, mobile network information, and device settings
  • Usage Data: Features used, interactions with predictions, time spent in the App, click data, and navigation patterns
  • Performance Data: Crash reports, performance metrics, and other diagnostic data
  • Analytics Data: We use Firebase Analytics and Google Analytics to collect aggregated usage statistics
  • Advertising Identifiers: Mobile advertising IDs (IDFA on iOS, AAID on Android) for advertising purposes, when you have not opted out

2.3 Information from Third Parties

  • Authentication Providers: When you sign in using Google or Apple Sign-In, we receive your email address and basic profile information
  • Sports Data Providers: We receive sports statistics and match data from TheSportsDB and other sports data APIs
  • Payment Processors: Transaction confirmations and subscription status from RevenueCat and app stores

Special Note on AI Predictions: Our AI-generated predictions are created using publicly available sports data and do not incorporate your personal information. The AI models analyze historical match data, team statistics, and performance metrics to generate predictions.

3. How We Use Your Information

3.1 Primary Purposes

  • Service Delivery: To provide AI-powered sports predictions, maintain your account, and deliver core App functionality
  • Personalization: To customize your experience, remember your preferences, and provide relevant content
  • Communications: To send service-related notifications, updates about predictions, and respond to your inquiries
  • Transactions: To process subscriptions, verify purchases, and manage your premium access
  • Analytics: To understand usage patterns, improve our predictions accuracy, and enhance App performance

3.2 Legal Bases for Processing (GDPR)

We process your personal data based on the following legal grounds:

  • Contract Performance: To provide the services you requested when you created an account
  • Legitimate Interests: To improve our services, ensure security, and operate our business efficiently
  • Legal Obligations: To comply with applicable laws and regulations
  • Consent: For marketing communications and certain data processing activities where required

3.3 Marketing and Advertising

  • We may send promotional emails about new features, special offers, or other products (with your consent where required)
  • Display personalized advertisements through Google AdMob
  • You can opt-out of marketing communications at any time through App settings or unsubscribe links

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information in the following circumstances:

4.1 Service Providers

  • Cloud Services: Firebase/Google Cloud Platform for data storage and processing
  • Analytics: Google Analytics, Firebase Analytics for usage analytics
  • Payment Processing: RevenueCat, Google Play, Apple App Store for subscription management
  • Advertising: Google AdMob for displaying ads (non-personalized ads available in settings)
  • Authentication: Google and Apple for sign-in services
  • AI Services: OpenAI for generating predictions (no personal data is shared)

4.2 Legal Requirements

  • To comply with legal obligations, court orders, or government requests
  • To protect our rights, privacy, safety, or property, and that of our users
  • To investigate and prevent fraud, security issues, or illegal activities

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.

4.4 Aggregated Information

We may share aggregated, anonymized data that cannot identify you personally for research, marketing, or other purposes.

5. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy:

Data Category Retention Period
Account Information Until account deletion + 30 days (for recovery purposes)
Transaction Records 7 years (for tax and legal compliance)
Usage Analytics 26 months (Google Analytics default)
User Content Until deletion by user or account termination
Marketing Preferences Until withdrawal of consent
Security Logs 12 months

6. Data Security

We implement industry-standard security measures to protect your personal information:

  • Encryption: Data is encrypted in transit using TLS/SSL and at rest using AES-256 encryption
  • Access Controls: Limited access to personal data on a need-to-know basis
  • Authentication: Secure authentication methods including OAuth 2.0 and biometric authentication where available
  • Infrastructure: Hosted on Google Cloud Platform with enterprise-grade security
  • Regular Audits: Security assessments and vulnerability testing
  • Incident Response: Established procedures for handling security incidents

Security Notice: While we strive to protect your information, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, but we continuously work to improve our security practices.

7. Your Rights and Choices

7.1 Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal data:

  • Access: Request a copy of the personal information we hold about you
  • Rectification: Correct inaccurate or incomplete personal information
  • Deletion: Request deletion of your personal information (subject to legal requirements)
  • Portability: Receive your data in a structured, machine-readable format
  • Restriction: Limit how we process your personal information
  • Objection: Object to certain processing of your personal information
  • Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

7.2 How to Exercise Your Rights

  • In-App: Access account settings to manage your data and preferences
  • Email: Contact us at support@prognozza.com with your request
  • Account Deletion: Use the "Delete Account" option in settings or contact support

7.3 Opt-Out Options

  • Marketing Emails: Click "unsubscribe" in any marketing email or adjust settings in the App
  • Push Notifications: Disable in your device settings or App notification preferences
  • Personalized Ads: Opt-out through App settings or device advertising preferences
  • Analytics: Disable analytics collection in App privacy settings

7.4 California Privacy Rights (CCPA)

California residents have additional rights under the CCPA:

  • Right to know what personal information is collected, used, shared, or sold
  • Right to delete personal information (with certain exceptions)
  • Right to opt-out of the sale of personal information (we do not sell personal information)
  • Right to non-discrimination for exercising privacy rights

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws than your country.

We ensure appropriate safeguards are in place for international transfers:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions where applicable
  • Privacy Shield certification for US-based service providers where applicable

9. Children's Privacy

Our App is not intended for children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children under these ages.

If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information promptly.

Parents or guardians who believe their child has provided personal information to us should contact us immediately at support@prognozza.com.

10. Third-Party Services and Links

Our App may contain links to third-party websites, services, or advertisements that are not operated by us. We are not responsible for the privacy practices of these third parties.

Key third-party services integrated with our App:

  • Google Services: Subject to Google's Privacy Policy
  • Apple Services: Subject to Apple's Privacy Policy
  • RevenueCat: Subject to RevenueCat's Privacy Policy
  • OpenAI: Used for predictions (no personal data shared)

We encourage you to review the privacy policies of any third-party services you interact with through our App.

11. Cookies and Tracking Technologies

While our mobile App does not use traditional web cookies, we use similar technologies:

  • Local Storage: To save your preferences and session information
  • Analytics SDKs: Firebase Analytics and Google Analytics for usage tracking
  • Advertising SDKs: Google AdMob for serving advertisements
  • Device Identifiers: To recognize your device and provide consistent experience

You can manage these through your device settings and App privacy preferences.

12. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

When we make material changes:

  • We will update the "Effective Date" at the top of this policy
  • Provide notice through the App or via email for significant changes
  • Obtain consent where required by applicable law

Continued use of the App after changes indicates acceptance of the updated Privacy Policy.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Data Controller: Prognozza

Email: support@prognozza.com

Response Time: We aim to respond to all privacy inquiries within 30 days

Data Protection Officer

For GDPR-related inquiries, you may contact our Data Protection Officer at the email address above.

Supervisory Authority

EU residents have the right to lodge a complaint with their local supervisory authority if they believe their rights under GDPR have been violated.

14. Region-Specific Provisions

European Union (GDPR)

  • Legal basis for processing is detailed in Section 3.2
  • Data subject rights are outlined in Section 7
  • International transfer safeguards in Section 8

United States

  • California residents: See Section 7.4 for CCPA rights
  • Nevada residents: We do not sell personal information
  • Do Not Track: Our App does not respond to Do Not Track signals

Other Jurisdictions

If you are located in other jurisdictions, you may have additional rights under local laws. Please contact us for information specific to your location.