Polityka prywatności

1. Who We Are (Data Controller)

Data Controller: Amun Interactive Limited
Registered office: Arch. Makarios III & Evagorou, 1–7, Mitsi 3, Floor 1, Flat 102, 1065 Nicosia, Cyprus
Contact email: ask@footballteam2.support

2. Summary of Key Points

• We provide a football manager game with online features, virtual items, and optional in-app purchases.
• You can sign in using Apple or Google.
• We use limited analytics and marketing technologies to understand App performance and to promote the App.
• You can request access to or deletion of your data (see Section 13 and Section 15).
• If you are in the EEA/UK or California, you have additional legal rights (see Section 16).

3. Information We Collect

We collect information you provide to us, information we collect automatically, and information we receive from third parties.

3.1 Information You Provide (Account and Support)

When you create an account, sign in, contact support, or participate in promotions, we may collect:

• email address (including Apple "Hide My Email" relay addresses);
• username / nickname / profile name;
• support communications (messages, attachments, and information you provide);
• optional information you submit in surveys, contests, or community activities.

We do not collect or store your Apple ID password or Google password.

3.2 Information We Collect Automatically (App, Device, and Usage)

When you use the App, we may automatically collect certain technical information, including:

• device type, operating system, and version;
• unique device identifiers (such as the Identifier for Advertisers (IDFA) on iOS, subject to your App Tracking Transparency choice, or the Android Advertising ID);
• app version and usage data;
• IP address;
• coarse location derived from IP address (e.g., country or region level);
• crash reports and performance data.

We do not collect or process precise location data (such as GPS location) through the App.

3.3 Gameplay and Progression Data

To operate the game and save your progress, we process gameplay data such as:

• match results, progression, achievements, and gameplay events;
• squad/team setup and in-game actions;
• virtual currency balances, virtual items inventory, and server/account identifiers.

3.4 Transactions and In-App Purchases

In-app purchases are processed by Apple or Google. We do not receive your payment card details.

We may receive or generate transaction-related information such as:

• purchase/transaction identifiers;
• purchase timestamps;
• items or virtual currency purchased;
• validation/receipt status from Apple/Google to confirm delivery.

3.5 Random Rewards and Virtual Items

The App may offer virtual items or rewards that are granted through randomised mechanics:

• records of random rewards granted;
• logs of virtual items granted (whether via purchases or gameplay events).

We use these logs to deliver rewards correctly, handle disputes/complaints, prevent fraud, and maintain fair play.

3.6 Marketing, Attribution, and Advertising Data

We may use marketing and analytics tools to measure the effectiveness of campaigns and understand how users engage with the App. Not all data points described below are necessarily collected at any given time; collection depends on the tools currently in use and applicable legal requirements.

Depending on your settings and where legally permitted, we may collect device identifiers such as the Identifier for Advertisers (IDFA) on iOS or the Android Advertising ID for advertising attribution and campaign measurement purposes.

On iOS devices, collection of the Identifier for Advertisers (IDFA) requires your prior consent through Apple's App Tracking Transparency (ATT) prompt. If you do not grant permission, we do not access the IDFA.

Where used and permitted by law, we may use hashed email lists for customer match or custom audience purposes to measure or improve marketing performance.

Where required, we obtain consent before engaging in personalised advertising.

3.7 Information We Receive from Third Parties

We may receive certain information from third parties in the following circumstances:

• when you sign in using Apple or Google authentication services;
• if and when optional social media integrations are made available in the App and you choose to connect your account.

At present, the App does not require connection to external social media platforms beyond authentication providers (Apple or Google).

4. Why We Use Your Information

We use personal information for the following purposes:

4.1 Provide the App and Its Features

To create accounts, authenticate users, save progress, enable gameplay features, enable multiplayer/competitive features (where applicable), deliver virtual items, and provide requested services.

4.2 Delivery of Purchases

To process in-app purchases, deliver virtual items, and maintain related transaction records.

4.3 Customer Support and Communication

To respond to your requests, investigate issues, resolve complaints, and send service messages (e.g., security notices, account-related messages).

4.4 Improve and Maintain the App

To debug, monitor performance, understand feature usage, conduct analytics, and improve gameplay balance and stability.

4.5 Security, Fraud Prevention, and Fair Play

To protect users and the App against cheating, fraud, misuse, and security incidents and to enforce our Terms.

4.6 Marketing, Newsletters, and Promotions

Where permitted, we may:

• send newsletters and product updates (new servers, updates, promotions);
• run marketing campaigns on platforms such as Google and Meta;
• measure the effectiveness of marketing campaigns;

We may record newsletter engagement (opens and clicks) to improve communications.

4.7 Competitions, Promotions, and Surveys

To administer competitions/promotions and surveys, including eligibility checks, prize fulfilment, fraud prevention, and compliance.

4.8 Social Media and Community Interactions

If you interact with us on social media or community channels, we may process the information you share with us and your public profile data (as provided by the platform) to respond, moderate, and manage community interactions.

5. Legal Bases (EEA/UK)

Where the GDPR / UK GDPR applies, we process your personal data under the following legal bases:

5.1 Performance of a Contract

We process personal data as necessary to perform our contract with you, including to:

• provide and operate the App;
• create and manage user accounts;
• enable gameplay and in-app purchases;
• deliver purchased or earned virtual items;
• provide customer support related to your account.

5.2 Legitimate Interests

We process personal data where it is necessary for our legitimate interests, provided that such interests are not overridden by your rights and freedoms. These interests include:

• securing the App and preventing fraud, abuse, and cheating;
• maintaining and improving the App's performance and stability;
• handling disputes and enforcing our Terms;
• measuring the effectiveness of marketing campaigns (using aggregated or pseudonymised data where possible).

5.3 Consent

We rely on your consent where required by law, including:

• sending marketing emails or promotional push notifications (where required);
• using tracking technologies or advertising identifiers;
• personalised advertising (where implemented in the future).

You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5.4 Legal Obligation

We process personal data where necessary to comply with legal obligations, including:

• accounting and tax requirements;
• responding to lawful requests from public authorities.

6. Cookies and Similar Technologies

Like most online services, we and our partners use cookies and similar technologies to operate, improve, measure, and market the App and related services.

In the App

Mobile applications do not use browser cookies in the same way as websites. However, we and our partners may use similar technologies such as SDKs, device identifiers, and local storage to:

• remember preferences and settings;
• measure performance and usage;
• attribute installs and measure marketing effectiveness;
• prevent fraud and abuse.

On Our Website

Our website and landing pages may use cookies and similar technologies. For more information, please see our Cookie Declaration.

Your Choices

You can control certain tracking technologies by:

• adjusting in-app privacy settings (where available);
• adjusting device settings (e.g., iOS/Android advertising settings);
• using platform controls provided by Apple, Google, or Meta;
• adjusting browser settings (for website cookies).

Restricting certain technologies may impact functionality.

7. Third-Party Services

We use selected third-party service providers to operate, secure, improve, and market the App. Depending on configuration and availability, these may include:

• Platform providers (e.g., Apple, Google) for authentication and in-app purchases;
• Analytics and measurement providers (e.g., Google Analytics);
• Advertising and attribution partners (where enabled and legally permitted);
• Infrastructure and hosting providers (cloud storage, servers, content delivery networks);
• Security and fraud prevention providers;
• Customer support and communication tools;
• Email service providers (where newsletters or updates are used).

Each third party processes personal data under its own privacy policy and applicable agreements. Where required, we implement appropriate contractual safeguards.

8. Marketing and Advertising (Details)

We may use certain marketing and advertising tools to promote the App and measure campaign performance.

Not all tools described in this section are currently active. This section describes tools that we use or may use in the future, depending on configuration and legal requirements.

8.1 Facebook/Meta Ads (Custom Audiences)

We may use Meta advertising tools that allow us to upload a hashed list of email addresses to determine whether those users have accounts on Meta platforms and to show our advertisements to them. You can manage ad preferences through Meta's settings.

8.2 Google Ads (Customer Match)

We may use Google Ads Customer Match by uploading a hashed list of email addresses to Google to show advertisements to matched users. You can manage ad preferences through Google's ad settings and/or opt-out mechanisms.

8.3 Google Analytics and Remarketing

We may use Google Analytics and similar measurement tools to understand how users engage with our App and marketing campaigns. Where required, we will obtain consent.

8.4 Opt-Out / Withdrawal

You can object to or withdraw your consent for marketing communications at any time by:

• using the unsubscribe link in marketing emails (where applicable);
• disabling push notifications in your device settings;
• adjusting your device's privacy settings (e.g. iOS or Android settings related to advertising identifiers), where interest-based advertising is used in the future;
• contacting us directly.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

8.5 Push Notifications

We may send push notifications to your device to provide:

• service-related updates;
• important account or security information;
• gameplay-related information;
• promotional messages (where permitted by applicable law).

You can manage or disable push notifications at any time through your device settings.

9. Who We Share Information With

We may share information with:

• platform providers (Apple, Google) for authentication and purchases;
• service providers (hosting, storage, security, analytics, customer support);
• marketing and advertising partners (campaign measurement and audience tools);
• professional advisors (legal, accounting) where necessary;
• authorities where required by law.

10. International Transfers

Your personal information may be transferred to and processed in countries outside your country of residence, including outside the European Economic Area (EEA) or the United Kingdom.

In particular, some of our service providers (such as analytics, infrastructure, or customer support providers) may be located in countries such as the United States or other jurisdictions that may not provide the same level of data protection as your home country.

Where required by applicable law, we rely on appropriate safeguards for such transfers, including the European Commission's Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms.

You may request further information about the safeguards we use for international data transfers by contacting us.

11. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy and to comply with applicable legal obligations.

As a general guideline:

• Account and gameplay data are retained for the duration of your account. If you delete your account, such data is deleted or anonymised within up to 90 days, unless retention is required by law or for legitimate interests (e.g., fraud prevention or dispute resolution).
• Transaction and payment records are retained for up to 6 years, as required by accounting and tax regulations.
• Analytics and diagnostic data are retained for up to 24 months.
• Marketing preferences and related data are retained until you withdraw consent or delete your account.
• Support communications may be retained for up to 3 years to handle follow-up requests and protect against legal claims.
• Marketing attribution and campaign measurement data is retained for up to 24 months, or as determined by the retention settings of the relevant platform provider.

Where required, we may retain certain information for longer periods to comply with legal obligations, resolve disputes, enforce our agreements, or protect against fraud and abuse.

12. Security

We implement appropriate technical, administrative, and organisational measures designed to protect the personal information we process from loss, unauthorised access, misuse, disclosure, alteration, and destruction. These measures may include access controls, encryption where appropriate, monitoring, and the use of secure infrastructure and vendor services.

13. Account Deletion and Data Deletion

You can request deletion of your personal data and closure of your FootballTeam2 account.

How to request deletion:

• If available in the App: go to Settings → Delete Account; or
• Contact us via email at ask@footballteam2.support from the email address associated with the account.

Information to include (if requested by email):

• your account name, Game ID, and server;
• the email address associated with the account;
• a clear statement requesting deletion.

Grace period: After submitting a deletion request, you may have a short withdrawal/grace period to prevent accidental deletion.

Timeline: After the grace period, we will block the account and complete deletion within a reasonable timeframe (typically within 30 business days, subject to technical and legal constraints).

Exceptions: We may retain limited information where required by law (e.g., transaction records), to resolve disputes, or to prevent fraud.

14. Age Limitation (Children)

The App is intended for users aged 16 and older.

We do not knowingly collect personal information from individuals under the age of 16.

In jurisdictions where a lower age threshold applies for data protection purposes (such as the United States, where the minimum age under COPPA is 13), we comply with applicable local laws. The App is not directed to children under 13.

If we become aware that we have collected personal information from a child below the applicable minimum age, we will take reasonable steps to delete such information.

Where required by applicable law, parental or guardian consent may be necessary for the processing of personal data.

15. Your Rights and How to Exercise Them

You may have rights depending on your location. These may include the right to:

• access your personal information;
• correct inaccurate or incomplete information;
• request deletion of your information;
• object to certain processing (including marketing);
• restrict processing;
• request data portability;
• not be subject to automated decision-making, including profiling, where applicable;
• lodge a complaint with a supervisory authority.

To exercise your rights, contact us at ask@footballteam2.support.

We will respond to your request within 30 days, in accordance with applicable data protection laws. In certain cases, this period may be extended where legally permitted.

16. Region-Specific Disclosures

16.1 EEA & UK (GDPR / UK GDPR)

If you are in the EEA or UK, you have the rights described above and can also complain to your local data protection authority. Where we rely on consent, you can withdraw it at any time.

16.2 United States – California (CCPA/CPRA)

If you are a California resident, you may have the right to:

• request details about categories and specific pieces of personal information we collected;
• request deletion;
• opt out of the "sale" or "sharing" of personal information for cross-context behavioural advertising;
• not be discriminated against for exercising your rights.

Opt-out: You can submit an opt-out request by contacting us at ask@footballteam2.support (subject line: "California Privacy – Opt Out"). We may need to verify your request.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

16.3 Rest of the World

Depending on your location, you may have additional rights under local laws. We will respond to requests as required by applicable law.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice through the App and/or by other appropriate means.

18. Contact Us

If you have questions about data protection, or if you have any requests related to your personal data, we encourage you to primarily contact us through the support features available in the App, so we can respond more quickly. Alternatively, you may contact:

Name of the controller:
Amun Interactive Limited

Address:
Arch. Makarios III & Evagorou, 1–7
Mitsi 3, Floor 1, Flat 102
1065 Nicosia
Cyprus

Attn: Privacy

Email: ask@footballteam2.support

Cookie Declaration