1. General Information

This policy describes how SERWIN collects, uses and protects your personal data in accordance with EU Regulation 2016/679 (GDPR), the California Consumer Privacy Act (CCPA/CPRA) and applicable international privacy laws.

It is important to read this policy before using the service. By using SERWIN, you agree to the practices described in this document.

2. Data Controller

SERWIN — Sports Prediction Simulator
Headquarters: Italy
Email: privacy@serwin.net
Website: www.serwin.net

Infrastructure: hosting and storage services located within the European Economic Area (EEA)

Note for international users:
This service complies with the GDPR (European Union), CCPA/CPRA (California) and other privacy laws applicable in your country of residence.

3. Data Collected

Data provided by the user:

• Name (username)
• Email address
• Password (stored in encrypted form, never in plain text)
• Country of residence and time zone
• GDPR consents (privacy, terms, marketing) with timestamp and IP address

Data collected automatically:

• IP address at the time of registration
• Device type, operating system and app version
• Usage data: predictions created, interactions, reactions
• Performance statistics: accuracy, credits, tipster level
• Device token for push notifications
• System logs for security and debugging
• App version and operating system (iOS/Android) — automatically detected at login
• Viewed match state history (anonymous technical data, retained for 30 days)

Data we do NOT collect:

• Payment details (handled exclusively by Google Play / App Store)
• Sensitive data (ethnic origin, political opinions, health data)
• Information relating to criminal convictions or offences

4. Purposes and Legal Basis for Processing

Performance of a contract:

• Account creation and provision of the service
• Management of virtual credits and leaderboards

Legitimate interest:

• App security and prevention of misuse
• Anonymous statistical analysis to improve the service
• Performance monitoring and error correction

Explicit consent:

• Push notifications
• Marketing communications
• Personalised advertising (Google AdMob)
• Profiling for relevant advertising

Legal obligations:

• Compliance with tax obligations or requests from competent authorities

5. Third-Party Services

• Hosting and storage services: technical infrastructure used for the backend, database and user content
• Expo Push Notifications: push notifications via anonymous device tokens
• PHPMailer / SMTP: transactional emails (account verification, password reset)
• Google Sign-In: optional authentication via a Google account. When used, SERWIN receives from Google the account's unique identifier and verified email address required to authenticate and link the SERWIN account
• Google AdMob: in-app advertising — requires explicit consent on first launch
• Google Play / App Store: in-app purchases and subscriptions — SERWIN never accesses payment details
• Sports data providers: external services used to provide sports data and information — no users' personal data is shared for such requests

The service may contain links or references to third-party websites and services. SERWIN is not responsible for the privacy practices of such external services.

6. Advertising and Profiling

SERWIN uses Google AdMob to display advertisements. Consent is requested on first launch via a dedicated banner.

Subject to your explicit consent, we may carry out anonymous profiling of your activity within the service in order to display more relevant advertisements. Such profiling does not allow for the direct identification of the individual.

You may opt out of advertising profiling at any time:

• By contacting privacy@serwin.net
• Via your device's privacy settings
• iOS: Settings → Privacy → Advertising
• Android: Settings → Privacy → Ads

7. Transfer of Data Outside the EU

Data managed directly by SERWIN is stored using infrastructure located within the European Economic Area (EEA).

The use of certain third-party services, such as Google AdMob and the Google/Apple app stores, may involve the transfer of certain data outside the European Economic Area. Where required, such transfers are carried out using the safeguards provided for under applicable data protection law.

In the event of a merger, acquisition or sale of the business, user data may be transferred to the new data controller, who will be bound by this policy and must ensure the same level of protection.

8. Cookies and Tracking Technologies

We use tracking technologies for:

• Essential functionality: login, app security, session management
• Preferences: language, time zone, UI settings
• Push notifications: anonymous device token (Expo)
• Advertising: Google AdMob — only with your explicit consent

You can manage your preferences via the consent banner when you first launch the app or via your profile settings.

9. Data Retention

• Account data: until the user requests deletion
• Bet history: 125 days
• Security logs: 12 months
• Operational logs: 7–14 days
• Notifications: 20–60 days depending on status

Deletion requests are processed within 30 days of receipt. We may retain certain data for a longer period where required by legal or regulatory obligations.

10. User Rights (GDPR & CCPA)

For all users:

• Right of access: to know what data we hold
• Right to rectification: to correct inaccurate data
• Right to erasure: to have your account and associated data deleted
• Right to data portability: to receive your data in a structured format
• Right to object: to object to processing for marketing or profiling purposes
• Right to withdraw consent: withdraw consent at any time
• Right to restriction: request restriction of processing
• Account deletion: directly from the app (Profile → Settings → Delete Account) or by writing to privacy@serwin.net

For users in California (CCPA/CPRA):

• Right to opt out of the sharing of data for behavioural advertising
• Right not to be discriminated against for exercising your rights

To exercise any of these rights: privacy@serwin.net

11. Data Security

• Passwords stored in encrypted form (bcrypt hash)
• Encrypted communications via HTTPS/TLS
• Authentication using dual JWT tokens (auth_token + refresh_token)
• Rate limiting on all APIs to prevent abuse
• Access logs and audit trails to detect anomalous activity

In the event of a data breach, we will notify affected users and the relevant authorities within the timeframes set out in applicable legislation.

12. Protection of Minors

SERWIN is intended for adults (18+). We do not knowingly collect data from minors. If a parent discovers that their child has created an account, they may contact us to request its immediate deletion at privacy@serwin.net.

13. Simulated Nature of the Service

SERWIN is a sports prediction SIMULATOR.

• We do NOT handle real-money betting
• Credits are VIRTUAL and have no monetary value
• Service provided for educational and entertainment purposes
• No connection with bookmakers or real betting sites
• League prizes consist exclusively of virtual credits with no real monetary value
• Premium/VIP subscriptions are managed via Google Play / App Store

Predictions, statistics, AI predictions, AI Picks and other content available on SERWIN are informational and support tools and do not guarantee any result.

Any use of such information outside SERWIN to place real-money bets with bookmakers, betting platforms or other external services is an independent decision made by the user and is undertaken at the user's sole responsibility. SERWIN accepts no responsibility for any winnings, losses or other consequences resulting from such use.

14. Changes to the Policy

We reserve the right to amend this policy. Users will be notified of significant changes via an in-app notification. Continued use of the service following the publication of changes constitutes acceptance of the new policy.