Privacy Policy - Soccer Predictions (Wise Prediction) Mobile App

Privacy Policy

Last updated: November 14, 2025

This Privacy Policy explains how Loheden AI Solutions AB ("Wise Prediction", "we", "us", or "our") collects, uses, and shares information about you when you use the Soccer Predictions (Wise Prediction) mobile application, related APIs, and support channels (collectively, the "Service").

We only collect the personal data you provide during sign-up (your email address plus a password or the identifier supplied by Google or Apple), your optional display name, age-gate status, measured consent choices, saved prediction preferences, and the subscription state tied to your device. We do not collect government IDs, payment card data, bank details, advertising identifiers, or behavioral analytics.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Application means the software program provided by the Company downloaded by You on any electronic device, named Wise Prediction

  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Loheden AI Solutions AB, Vretavägen 26, 71993, Vintrosa, Sweden.

    For the purpose of the GDPR, the Company is the Data Controller.

  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

  • Country refers to: Sweden

  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Do Not Track (DNT) refers to a browser setting that requests websites disable cross-site tracking. Our Service does not request advertising identifiers or use ad-network SDKs, so DNT signals do not change data collection because no behavioral tracking occurs.

  • Personal Data is any information that relates to an identified or identifiable individual.

    For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

    For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information to another business or a third party for monetary or other valuable consideration.

  • Service refers to the Application.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. In practice this includes Firebase Authentication, Cloud Firestore, Firebase Cloud Messaging, Google Cloud hosting and support tools, RevenueCat, Apple App Store, Google Play Billing, and Resend, each of which is bound by their posted privacy terms (see the "Operational Service Providers" section below).

  • Third-party Sign-In Service refers exclusively to Google or Apple sign-in providers through which a User can log in to use the Service.

  • Usage Data refers to limited diagnostic information (timestamps, device model, operating system version, anonymized error codes, and request metadata) that is generated automatically when the Service encounters an error or needs to protect against abuse.

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

    Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data You Provide

We collect only the data that is necessary to create and maintain your account and subscriptions:

  • Account data: email address, hashed password when you sign up directly with us, optional display name, and the identifier issued by Google or Apple if you use their sign-in options.
  • App-specific data: age-gate outcome (eligible or blocked) plus the birth-year band you self-report, consent flags, saved prediction preferences, and the device token required to send push alerts.
  • Subscription data: RevenueCat receipt identifiers, product tier, renewal status, and expiration dates so we can determine your entitlements. We never store your payment card, bank account, or government ID information.
  • Support requests: copies of the messages and attachments you send to [email protected] so that we can investigate and respond.
  • Optional marketing contact data: if you leave your email to receive product tips or promotional updates, we store that email plus the opt-in timestamp so we can honor your consent. You may unsubscribe at any time using the link in each message or by contacting us.

Anonymous sessions contain no personally identifiable information and exist only on the device.

Data We Do Not Collect

We do not request or store phone numbers, physical addresses, bank or card details, passport scans, biometric identifiers, advertising IDs (IDFA/AAID), or behavioral analytics. Payments are handled by Apple and Google, and all crash/diagnostic telemetry is limited to security logging.

Usage Data

When the Service encounters an error or suspicious activity, we log a timestamp, device model, operating system version, truncated IP address, and anonymized error code. These operational logs are stored in Firebase support services and RevenueCat webhook logs solely to secure the platform. We do not build behavioral profiles or run third-party analytics SDKs.

Information from Third-Party Sign-In Services

You may authenticate with Google or Apple. When you do, we receive your verified email address and the provider's user identifier to prevent duplicate accounts.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to deliver predictions you request and to keep subscription entitlements in sync.

  • To manage Your Account: to register you as a user, enforce age-gating, and surface the correct content for your subscription tier.

  • For the performance of a contract: to deliver paid features and renewals you buy through Apple App Store or Google Play.

  • To contact You: To respond to support requests, send transactional notices (for example, major policy updates or subscription reminders), and—only if you opted in—to deliver occasional product tips or promotional updates via Resend. Every optional marketing email includes an unsubscribe link and can be disabled by emailing us.

  • To provide You with reliable alerts, such as push notifications you explicitly enable in the app.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For security and fraud prevention: To detect malicious requests, investigate abuse, and protect the Service and its users.

  • For compliance: To satisfy legal obligations, respond to lawful requests, and maintain accurate transaction records.

We may share Your personal information in the following situations:

  • With Service Providers: We share only the data needed for them to perform contractual tasks, such as Firebase (authentication, hosting, messaging), Google Cloud (email and infrastructure), RevenueCat (subscription entitlements), and Resend (optional marketing email delivery). Each provider handles data under their posted privacy policies.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share information with subsidiaries under common control subject to this Privacy Policy.
  • With business partners: We only share data when it is necessary to fulfill a feature you enable (for example, receiving a push alert).
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

We do not embed advertising SDKs, analytics SDKs, or data brokers. The third parties below process data strictly to operate the Service:

Operational Service Providers

Payments

All purchases are handled by Apple App Store and Google Play Billing. RevenueCat receives the corresponding receipt identifier and subscription metadata, and we use that metadata to enforce entitlements. We never see payment card numbers, bank statements, or other financial credentials, and we do not accept bank transfers.

Refund-Related Data Sharing with Apple App Store Customers:

When you purchase a subscription or other in-app content through the Apple App Store or Google Play and subsequently request a refund, the store may ask us to confirm whether the subscription was used. By using Wise Prediction and completing an in-app purchase, you consent to the following data-sharing practice:

  • Data shared: strictly limited "consumption data," such as the RevenueCat receipt identifier, product tier, and timestamped entitlements showing when premium content was accessed.
  • Purpose: exclusively to help Apple or Google verify refund eligibility and prevent misuse of the refund process.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

Within the last twelve (12) months we collected only the categories below:

  • Category A: Identifiers.

    Examples: Email address, hashed password, Firebase installation ID, truncated IP address, device token, app-specific receipt identifiers.

    Collected: Yes.

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

    Examples: Display name you optionally provide and subscription history. We do not collect government ID numbers, payment cards, or physical addresses.

    Collected: Yes.

  • Category D: Commercial information.

    Examples: Records of the subscription tier purchased, renewal status, and expiration date.

    Collected: Yes.

  • Category F: Internet or other similar network activity.

    Examples: Timestamped API failures, device model, and operating system version captured for diagnostics (without advertising identifiers).

    Collected: Yes.

All other CCPA categories (C, E, G, H, I, J, K) are not collected.

Under CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.
  • Indirectly from You. For example, from observing Your activity on our Service.
  • Automatically from You. For example, through essential cookies or device storage used for authentication, security, and session management while You navigate the Service.
  • From Service Providers. For example, third-party vendors that authenticate users, deliver push notifications, sync subscriptions, or otherwise enable the Service features You request.

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

  • To operate our Service and provide You with our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale or Sharing of Personal Information

Loheden AI Solutions AB does not sell or share personal information as defined under the CCPA/CPRA, and we have not done so in the previous twelve (12) months. Because we neither sell data nor use it for cross-context behavioral advertising, the opt-out right is not applicable.

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
    • The categories of personal information We collected about You
    • The categories of sources for the personal information We collected about You
    • Our business or commercial purpose for collecting or selling that personal information
    • The categories of third parties with whom We share that personal information
    • The specific pieces of personal information We collected about You
    • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
      • The categories of personal information categories sold
      • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). While we do not sell or share personal information, you may still contact us if you have questions about our practices.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

Because we do not sell or share personal information or use targeted advertising, there is no separate opt-out mechanism. You can still contact us if you have questions about how your data is handled.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not change its behavior when it receives a Do Not Track signal because we do not track users across third-party websites, request advertising identifiers, or personalize ads. You may still enable DNT in your browser for other websites.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify You of any significant changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We may also provide notice through the App or via email if appropriate. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: