English

Privacy Policy

Last Updated: 27.11.2025

INTRODUCTION

This Privacy Policy ( “ Policy ” ) explains how RED PANDA APP LLC ( “ Company ” , “ we ” , “ us ” , or “ our ” ) collects, uses, stores, discloses, and protects personal data when you access or use the FootballHub application ( “ Application ” ) and the services, features, and content made available through it (collectively, the “ Service ” ).

BY ACCESSING OR USING THE SERVICES, AND BY DOWNLOADING, INSTALLING, ACCESSING, OR USING THE APPLICATION, YOU ACKNOWLEDGE THAT YOU HAVE READ THIS PRIVACY POLICY AND THAT YOU UNDERSTAND YOUR RIGHTS IN RELATION TO YOUR INFORMATION AND HOW WE WILL COLLECT, USE AND PROCESS IT. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY IN GENERAL OR ANY PART OF IT, YOU SHOULD NOT USE THE SERVICES.

This Policy applies solely to the data collected through the Application and does not apply to any third-party websites, services, software development kits (SDKs), or platforms that may be linked to or integrated with the Application. Those third parties maintain their own privacy practices.

The Application is intended for individuals who are at least 13 years old, or the minimum age required to consent to the processing of personal data in their jurisdiction. We do not knowingly collect or process personal data from children under 13. If we become aware that data from a child under this age has been collected, we will take reasonable steps to delete it.

Your use of the Application is also governed by our Terms of Use, which form a binding agreement between you and the Company. In the event of a conflict between this Policy and the Terms of Use, the Terms of Use shall prevail to the extent permitted by applicable law.

Depending on your location, certain data protection laws, such as the European Union General Data Protection Regulation ( “ GDPR ” ) or the Brazilian Lei Geral de Prote çã o de Dados ( “ LGPD ” ), may grant you specific rights regarding your personal data. This Policy is intended to comply with such laws to the extent they apply to the Company.

INFORMATION YOU PROVIDE TO US

Account and Profile Information. When you create or manage your account within the Application, you may provide:

• username or display name;

• age or confirmation that you meet the minimum age requirement;

• selected football club;

• profile image or avatar;

• optional biography or profile description.

User-Generated Content (UGC). We collect any content you create, submit, or share within the Application, including:

• messages in group chats;

• private messages;

• images, fan symbols, or other media you upload;

• posts, reactions, and interactions;

• reports or complaints regarding other users or content.

Depending on the Application features, UGC may be visible to other users.

Communications With Us. If you contact our support team or communicate with us for any reason, we may collect:

• your name, email address, or contact details;

• the contents of your inquiry;

• attachments or supplemental information you choose to provide;

• device-level or diagnostic information relevant to your request.

Information Collected Automatically. When you access or use the Application, we automatically collect:

1. Device and Technical Data

• device type, model, and operating system;

• device settings and language;

• IP address;

• unique device or advertising identifiers (IDFA, GAID, or equivalents);

• mobile network information;

• crash logs and diagnostic data.

2. Usage Data

• interactions with in-application screens, menus, and features;

• fan-support actions (such as cheers, chants, flags, drums, or flares);

• gameplay activity and performance (including penalty challenges, rankings, and fan battles);

• progress, achievements, and virtual currency balances;

• timestamps, session duration, and navigation patterns;

• fraud indicators and security logs.

3. Cookies, SDKs, and Similar Technologies

We may use cookies, mobile identifiers, SDKs, and similar technologies for:

• enabling core functionality;

• analytics and performance measurement;

• advertising and campaign attribution;

• preventing misuse or fraudulent behaviour.

Information Related to Purchases

If you purchase virtual currency or other in-application items, we collect:

• transaction identifiers;

• purchase history;

• confirmation of payment from the relevant app store.

We do not collect or store credit card numbers or bank information. All financial data is processed by Apple App Store, Google Play, or other applicable platforms.

Information From Advertising Partners

When you view or interact with advertisements within the Application (if applicable), we may receive:

• advertising or device identifiers;

• ad impression and engagement data;

• information regarding whether you completed a rewarded ad;

• aggregated ad performance metrics;

• fraud-prevention signals provided by advertising networks.

Information From Analytics and Anti-Fraud Providers. We may receive information from third-party analytics, attribution, or anti-fraud services, such as:

• aggregated performance statistics;

• crash and stability reports;

• device-level diagnostic information;

• data used to identify automated or abusive behaviour;

• marketing attribution results.

Sensitive Data. We do not intentionally collect sensitive categories of personal data, such as:

• government ID numbers;

• financial account details;

• precise geolocation;

• biometric data;

• health information.

If you choose to disclose such information in chats or UGC, you do so at your own risk.

Data Concerning Children. The Application is intended for users aged 13 and older , or the minimum lawful age for data processing in their jurisdiction. We do not knowingly collect personal data from children under 13. If we become aware that such data has been collected, we will take reasonable steps to delete it.

HOW WE USE YOUR INFORMATION

We use the personal data we collect for the following purposes, and only to the extent permitted by applicable law:

To Provide and Operate the Service. We process your data to deliver the core functionality of the Application, including:

• creating and maintaining your account;

• enabling fan-support actions (cheers, chants, flags, drums, flares);

• calculating scores, rankings, progress, and achievements;

• enabling participation in fan battles and penalty games;

• managing virtual currency balances and in-application purchases;

• displaying your profile, club selection, and activity to other users.

To Enable Communication Features. We use your information to support interactions with other users, such as:

• group chats;

• private messages;

• fan Community features;

• reporting tools and content moderation.

To Ensure Safety, Integrity, and Fair Use. We use technical and behavioural data to:

• detect and prevent fraud, cheating, automation, or misuse;

• protect the Application from harmful activities;

• enforce our Terms of Use;

• investigate or respond to reports, violations, or harmful behaviour;

• maintain the reliability and fairness of rankings and fan competitions.

To Improve and Personalise the Application. We process analytics and technical information to:

• understand how users interact with the Application;

• identify technical issues and improve performance;

• develop new features and gameplay mechanics;

• personalise content, recommendations, and in-application experiences.

To Process Purchases and Manage Transactions. We use certain data to:

• validate purchase requests;

• confirm transactions with the app stores;

• deliver virtual currency or items you purchased;

• maintain purchase history for legitimate business purposes.

For Advertising and Marketing (if applicable). We may use identifiers and analytics to:

• deliver and measure non-personalised advertising;

• limit the number of times you see the same ad;

• verify completion of rewarded ads;

• assess the effectiveness of marketing campaigns;

• prevent invalid traffic and advertising fraud.

We do not use personal data to provide interest-based or behavioural advertising where prohibited by law or platform policies.

To Comply With Legal Obligations. We may process your information to:

• comply with applicable laws and regulations;

• respond to lawful requests, investigations, or court orders;

• maintain records required for tax, audit, or regulatory compliance.

For Other Legitimate Business Purposes. Where permitted by law, we may process data to:

• protect the rights and safety of the Company, users, or third parties;

• support business operations such as backup, security, and storage;

• facilitate potential business transactions (e.g., merger, acquisition).

LEGAL BASES FOR PROCESSING

Where required by applicable law, such as GDPR and LGPD, we process personal data on the following legal bases:

Performance of a Contract. We process personal data as necessary to provide and operate the Application, including:

• creating and managing accounts;

• enabling gameplay features, rankings, and fan competitions;

• managing virtual currency and purchases;

• operating communication features;

• providing

customer support.

Legitimate Interests. We may process personal data where necessary for our legitimate business interests, provided such interests are not overridden by your rights. These interests include:

• ensuring the security and integrity of the Application;

• detecting and preventing fraud, abuse, or prohibited conduct;

• analysing and improving the Application;

• protecting our legal rights;

• moderating UGC and user interactions;

• running non-personalised advertising and measuring its performance.

Compliance With Legal Obligations. We may process personal data where necessary to comply with laws, regulations, or lawful requests, including:

• respon

ding to government authorities;

• meeting tax, accounting, or regulatory requirements;

• complying

with enforcement requests.

Consent. In certain cases, we may rely on your consent, including:

• optional permissions (such as camera or photo gallery access, if applicable);

• participation in optional surveys or feedback requests;

• receiving certain types of marketing communications (if and where required).

When processing is based on consent, you may withdraw your consent at any time, without affecting the lawfulness of processing carried out before such withdrawal.

HOW WE SHARE YOUR INFORMATION

We may share your personal data with the categories of recipients described below. We do not sell your personal data. We share data only as necessary to operate the Application, comply with the law, protect our interests, or perform legitimate business functions.

Service Providers. We may share personal data with third-party vendors, contractors, and service providers who assist in the operation of the Application, including:

• cloud hosting and storage providers;

• analytics and performance measurement services;

• advertising networks and attribution partners;

• anti-fraud and security vendors;

• customer support and moderation services;

• payment and transaction processors (through app stores).

These parties process data on our behalf and only in accordance with our instructions.

Other Users of the Application. Certain information may be visible to other users by design, including:

• your username or display name;

• your selected football club;

• your profile picture or avatar;

• your rankings, scores, and gameplay achievements;

• messages in group chats and fan community spaces;

• any User-Generated Content you choose to share publicly.

Private messages are visible only to the participants, but may still be reviewed by the Company in accordance with this Policy and our Terms of Use when necessary for enforcement, safety, or legal reasons.

Advertising Partners. If the Application displays ads or rewarded videos, we may share:

• advertising identifiers (IDFA, GAID);

• device information;

• ad engagement metrics;

• signals used to detect fraud or invalid traffic.

We do not share personal data that directly identifies you (such as your name or email) with advertising networks.

Analytics, Attribution, and Anti-Fraud Services. We may share data with third-party analytics or anti-fraud providers to:

• analyse performance and usage patterns;

• detect suspicious or harmful behaviour;

• improve gameplay mechanics and reliability;

• attribute app installs and marketing campaigns;

• maintain the integrity of fan battles, rankings, and competitions.

These services may access technical and behavioural data solely for the purposes described above.

Legal and Compliance Purposes. We may disclose personal data when required by law or when necessary to:

• respond to lawful requests, subpoenas, court orders, or government inquiries;

• comply with regulatory obligations;

• protect the rights, property, or safety of the Company, our users, or others;

• detect, prevent, and address fraud, security breaches, or illegal activities.

Business Transfers. We may share personal data in connection with:

• mergers, acquisitions, or sales of assets;

• restructuring, financing, or reorganisation;

• due diligence

processes relating to potential corporate transactions.

Personal data will continue to be protected under this Policy unless otherwise stated.

With Your Consent. We may share personal data with third parties when you provide your explicit consent or when you intentionally direct us to share such information.

YOUR RIGHTS

Depending on your location and applicable data protection laws, you may have certain rights regarding your personal data. These rights may include the following:

Right of Access. You may request confirmation of whether we process your personal data and, if so, receive a copy of such data.

Right to Correction. You may request that we correct inaccurate, incomplete, or outdated personal data.

Right to Deletion. You may request deletion of your personal data, subject to certain exceptions, such as where processing is required to:

• comply with legal or regulatory obligations;

• detect or prevent fraud, abuse, or security incidents;

• resolve disputes or enforce our Terms of Use;

• maintain necessary business or transaction records.

Deleting your account does not automatically remove content that has already been shared with other users (for example, messages in group chats), unless required by applicable law.

Right to Withdraw Consent. Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the legality of processing conducted before the withdrawal.

Right to Data Portability. In certain circumstances, you may request a copy of the personal data you provided to us in a structured, commonly used, and machine-readable format.

Right to Restrict Processing. You may request that we restrict processing of your personal data where permitted by law, such as while verifying its accuracy.

Right to Object. You may object to the processing of your personal data where processing is based on our legitimate interests. We may continue processing where permitted by law.

Rights Under LGPD (Brazil). If you are located in Brazil, you may also have the following rights under the Lei Geral de Prote çã o de Dados (LGPD):

• confirmation of processing;

• anonymisation, blocking, or deletion of unnecessary or excessive data;

• information about third parties with whom your data is shared;

• information about the possibility of denying consent and the consequences of such denial.

Verification of Identity. We may require you to verify your identity before responding to a request, including by providing certain account or device information.

Submitting a Request. To exercise your rights, you may contact us using the details provided in the Contact Information section of this Policy.
We may decline a request where permitted by law, including when a request is unfounded, excessive, or infringes on the rights of others.

DATA RETENTION

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law. Different categories of data may be retained for different periods depending on the nature of the data and the reasons for which it is processed.

Account and Profile Data. We retain your account information for as long as your account remains active. If you choose to delete your account, we will delete or anonymise your personal data within a reasonable period, unless retention is required for legal, regulatory, or legitimate business purposes.

User-Generated Content (UGC). UGC, such as messages, posts, images, and fan symbols, may be retained:

• while your account remains active;

• after account deletion to the extent it has been shared with other users or is necessary for security, moderation, fraud prevention, or legal purposes.

We may also retain backup copies for a limited period.

Communication Data. Customer support communications, reports, and moderation records may be retained as necessary for:

• resolving issues;

• enforcing our Terms of Use;

• maintaining security;

• defending

legal claims.

Gameplay, Ranking, and Virtual Currency Data. Data related to gameplay, achievements, fan battles, and virtual currency balances may be retained while the account is active. After deletion, such data may be anonymised for analytics and operational purposes.

Technical and Analytics Data. Log files, diagnostics, and analytics data may be retained for a limited period needed to:

• ensure

security and functionality;

• analyse performance and usage patterns;

• detect and prevent fraud or abuse.

Legal and Regulatory Retention. We may retain certain data as necessary to:

• comply with tax, audit, or accounting obligations;

• meet legal or regulatory retention requirements;

• resolve disputes or enforce our rights.

Backup Copies. Data stored in backups may continue to exist for a limited time after deletion procedures have been initiated. Backups are automatically deleted according to our internal retention schedule.

DATA SECURITY

We implement technical and organizational measures designed to protect personal data from unauthorized access, loss, misuse, alteration, or disclosure. These measures may include encryption, access controls, secure data storage, network safeguards, and internal policies limiting access to personal data to authorized personnel only.

However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal data. You use the Application at your own risk.

We encourage you to take steps to protect your own information, including:

• keeping

your device secure;

• using strong passwords;

• avoiding sharing account credentials with others;

• being mindful of the information you choose to share in chats or User-Generated Content.

If we become aware of a security incident that may have compromised your personal data, we will take reasonable steps to investigate the issue and, where required by applicable law, notify affected users and relevant authorities.

INTERNATIONAL DATA TRANSFERS

We may process and store personal data in countries other than the one in which you are located. These countries may have data protection laws that differ from those of your jurisdiction and may not provide the same level of protection.

By using the Application, you acknowledge and agree that your personal data may be transferred to, stored in, or processed in countries where the Company, its service providers, or its affiliates operate.

Where required by applicable law, we implement appropriate safeguards to protect personal data during international transfers, which may include:

• standard contractual clauses approved by regulatory authorities;

• contractual obligations requiring service providers to maintain appropriate data protection standards;

• other lawful transfer mechanisms permitted under applicable data protection laws.

These safeguards do not guarantee that the level of protection will be identical to that provided in your home jurisdiction, but they are intended to ensure that your personal data receives an adequate level of protection.

If you are located in the European Economic Area ( “ EEA ” ), the United Kingdom, or Brazil, you may request additional information about international data transfers and the safeguards applied by contacting us using the details set out in the Contact Information section of this Policy.

ADVERTISING AND ANALYTICS

The Application may use third-party advertising, analytics, attribution, and anti-fraud technologies. These technologies help us operate, improve, and support the Service, as well as measure the performance of marketing and advertising campaigns.

Advertising. If the Application displays advertisements or rewarded ads, we may allow advertising partners to collect or receive certain data, such as:

• advertising identifiers (e.g., IDFA, GAID);

• device and technical information;

• information about ad impressions, views, or interactions;

• signals used for fraud prevention, frequency capping, and non-personalised ad delivery.

We do not share information that directly identifies you (such as your name, email address, or profile data) with advertising networks.

Depending on your device settings, advertising identifiers may be reset or limited at any time through your operating system.

Non-Personalised Advertising. Where required by law or platform policy, advertisements displayed in the Application may be:

• contextual, based on in-app activity;

• non-personalised, based on general device information;

• limited to users under applicable age thresholds.

We do not use personal data to provide behavioural or interest-based advertising in jurisdictions where such processing is restricted.

Analytics and Attribution. We use third-party analytics and attribution providers to:

• measure usage patterns and performance;

• understand how users interact with the Application;

• identify stability or technical issues;

• attribute app installs and marketing campaigns;

• prevent fraud, abuse, or unauthorised activity.

These partners may collect:

• device identifiers;

• technical data;

• aggregated usage statistics;

• crash reports;

• diagnostics.

Analytics data is used only to support the operation and improvement of the Application.

Anti-Fraud and Security Tools. We may share certain technical and behavioural signals with anti-fraud partners for the purpose of:

• detecting cheating, automation, or exploit attempts;

• securing fan-battles, rankings, and competitive features;

• preventing invalid traffic in advertising;

• protecting the Application and users from harmful behaviour.

Third-Party Privacy Practices. Advertising, analytics, and attribution partners maintain their own privacy policies, which govern how they process data. We are not responsible for the privacy practices of third-party services.

CHILDREN ’ S PRIVACY

The Application is intended for individuals who are at least 13 years old , or the minimum age required to consent to the processing of personal data in their jurisdiction. We do not knowingly collect, use, or process personal data from children under 13.

If we become aware that personal data has been collected from a child under the applicable minimum age, we will take reasonable steps to delete such data, which may include deleting the associated account.

Parents or legal guardians who believe that their child has provided personal data without their consent may contact us using the details provided in the Contact Information section of this Policy.

Users under the age of 18 should use the Application only if permitted under local law and with any consents required by such law.

USER-GENERATED CONTENT

The Application allows users to create, submit, upload, share, or transmit content, including messages, images, fan symbols, profile information, reactions, and other materials ( “ User-Generated Content ” or “ UGC ” ). You should assume that any UGC you share within public or group areas of the Application may be viewed by other users.

Public and Semi-Public Content. UGC posted in group chats, fan communities, or other shared areas is public or semi-public.
Other users may read, copy, store, or use such content.
We are not responsible for the actions of users who access or interact with your UGC.

Private Messages. Private messages are visible only to participating users.
However, we may access, review, or disclose private messages where permitted or required by law, or when reasonably necessary to:

• enforce our Terms of Use;

• investigate violations, harmful behaviour, or safety concerns;

• respond to reports or user complaints;

• protect the security or integrity of the Service.

We do not monitor private messages on a continuous basis.

Content Moderation. We may review, remove, restrict, or disable access to any UGC at our discretion, including when the content:

• violates the Terms of Use;

• infringes intellectual property rights;

• is harmful, abusive, or unlawful;

• threatens safety or disrupts the Application.

Moderation may include automated tools, human review, or a combination of both.

UGC Remains Visible After Account Deletion. UGC that has been shared with others (e.g., in group chats) may remain visible even after:

• you

delete your account;

• we delete your account for violation of the Terms;

• you request the deletion of personal data.

This is necessary to preserve the integrity of conversations, community history, and gameplay features.

Responsibility for UGC. You are solely responsible for any UGC you share and for any consequences arising from such sharing.
We do not endorse or assume responsibility for the accuracy or legality of UGC.

Sensitive Information. You should not share personal, sensitive, or confidential information through UGC or chats.
If you choose to do so, you do so at your own risk.

THIRD-PARTY LINKS AND SERVICES

The Application may contain links to third-party websites, applications, services, or content that are not owned or controlled by us. The Application may also integrate third-party technologies such as analytics tools, advertising networks, attribution providers, and social or communication features.

We are not responsible for the privacy practices, content, security, or operations of any third-party websites, applications, or services. Your interactions with third-party services are governed by their own terms and privacy policies, not by this Privacy Policy.

We encourage you to review the privacy policies of any third-party services you choose to interact with.
Your use of third-party services is entirely at your own risk.

We do not endorse, monitor, or assume responsibility for any third-party content or activities, and we do not guarantee that third-party services will be available, accurate, or secure.

CHANGES TO THIS PRIVACY POLICY

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, the Application, or applicable laws. Any updated version will be posted within the Application and will indicate the date of the latest revision.

Your continued use of the Application after a revised Policy has been posted constitutes your acceptance of the updated Policy. If you do not agree with the updated terms, you must discontinue use of the Application.

CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our processing of personal data, you may contact us by this email: [email protected] .

We will take reasonable steps to respond to inquiries and requests in accordance with applicable data protection laws.