This Privacy Policy explains how Predict Games ("we", "us", "our"), registered in the Netherlands (KvK number: 42096328), collects, uses, shares, stores, and protects your personal data when you use the PredictAbility app and website (collectively, the "Service"). It also describes privacy rights that may apply to you under laws including the GDPR, Turkiye's KVKK, and applicable U.S. state privacy laws.
The Service is intended only for users aged 18 years or older.
1. Data We Collect
We collect only the data reasonably necessary to operate, secure, support, and improve the Service:
- Email address — used for account creation, authentication, and transactional emails (e.g. password reset, email verification, rewards delivery).
- Username — a public display name you choose. Do not use your real name if you prefer to remain anonymous.
- Emoji avatar — a single emoji you select to represent yourself on leaderboards.
- Prediction and rewards data — your score predictions, points earned, prediction history, and rewards history.
- Device data — device type, operating system, and app version, collected automatically for crash reporting and performance monitoring via Firebase.
- Advertising and device data — our advertising mediation platform, Unity LevelPlay, and participating advertising networks may process information such as your device's advertising identifier (where permitted), IP address, device and operating system information, app information, approximate location derived from IP address, and advertising interaction data. On iOS, access to the IDFA is subject to your App Tracking Transparency (ATT) choice.
We do not collect your real name, phone number, payment details, or physical address.
Our website does not use cookies except those technically necessary for operation.
2. How We Use Your Data
- To create and manage your account.
- To operate the prediction and points system.
- To send transactional emails (password reset, email verification, email change notifications) via our email provider, Sender.net.
- To receive your support request via our provider, EmailJS; and respond to it.
- To display leaderboards using your username and emoji avatar.
- To process gift card redemptions (your email address is used to deliver rewards).
- To display, measure, and manage advertisements through Unity LevelPlay and participating advertising networks, which help fund the free Service.
- To monitor app performance and fix bugs via Firebase Performance Monitoring.
- To send push notifications about your predictions, streak reminders, and leaderboard results (you can disable these in your device settings at any time).
3. Legal Basis for Processing
We process your personal data on the following legal bases under the General Data Protection Regulation (GDPR):
- Contract performance — processing your email, username, and prediction data is necessary to provide the Service you signed up for.
- Legitimate interests — crash reporting, performance monitoring, and fraud prevention.
- Consent — where required by applicable law, for personalised advertising and related advertising technologies. On iOS, tracking across apps and websites is also subject to your App Tracking Transparency (ATT) choice. You may withdraw or change your consent choices at any time through the mechanisms provided in the Service or your device settings, as applicable.
4. Data Sharing
We do not sell your personal data to data brokers. We share personal data with service providers and advertising partners where necessary to operate, secure, support, or monetise the Service, or where otherwise permitted by applicable law.
- Google Firebase / Firestore — authentication, database, push notifications, and performance monitoring. Data stored in Google's infrastructure. Subject to Google Cloud Cloud Data Processing Addendum.
- Unity LevelPlay — advertising mediation used to manage and deliver in-app advertising. Depending on availability, location, consent choices, and mediation configuration, advertisements may be provided by participating advertising networks including ironSource Ads, Unity Ads, and Yandex Ads. These providers may process device and advertising information for purposes such as delivering and measuring advertisements, frequency management, fraud prevention, and, where permitted, personalised advertising. Their processing is subject to their respective privacy policies and applicable consent choices.
- Sender.net — transactional email delivery. Subject to Sender.net Privacy Policy.
- EmailJS — contact webform submissions. Name and email address are transmitted via EmailJS to deliver your support message to us. Subject to EmailJS Data Processing Agreements.
We require our service providers and advertising partners to handle personal data in accordance with applicable data-protection laws and their contractual obligations to us. Advertising providers may process information independently for purposes described in their own privacy policies and subject to applicable consent and privacy choices.
5. Data Retention
- Your account data is retained for as long as your account is active.
- If you delete your account, your personal data (email, username, avatar) is permanently deleted within 30 days.
- Prediction history and points records may be retained in anonymised form for statistical purposes.
- Push notification records are deleted after delivery.
6. Your Rights (GDPR)
If you are located in the European Union or European Economic Area, you have rights under the GDPR regarding your personal data, subject to applicable legal limitations:
- Right of access — request a copy of the data we hold about you.
- Right to rectification — correct inaccurate data (you can update your email address in the app).
- Right to erasure — request deletion of your account and personal data (you can request deletion of your account in the app).
- Right to restriction — request that we limit how we process your data.
- Right to data portability — receive your data in a structured, machine-readable format, such as CSV or JSON.
- Right to object — object to processing based on legitimate interests.
- Right to withdraw consent — withdraw consent for personalised advertising at any time through the consent mechanisms provided in the Service, where applicable. On iOS, you can separately change your tracking permission in Settings → Privacy & Security → Tracking.
To exercise any of these rights, contact us at privacy@predictability.app. We will normally respond within one month. Where permitted by law, this period may be extended by up to two additional months depending on the complexity and number of requests. We may request information reasonably necessary to verify your identity before fulfilling a request.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.
7. Your Rights in Turkiye — KVKK
If you are located in Turkiye, your personal data may also be subject to Turkiye's Personal Data Protection Law No. 6698 ("KVKK"), where the KVKK applies to our processing activities.
Subject to the conditions and exceptions provided by applicable law, you may have the right under Article 11 of the KVKK to:
- learn whether your personal data is being processed;
- request information about the processing of your personal data;
- learn the purpose of processing and whether your personal data is being used in accordance with that purpose;
- know the third parties to whom your personal data is transferred, in Turkiye or abroad;
- request correction of incomplete or inaccurate personal data;
- request deletion or destruction of personal data where the legal conditions are met;
- request notification of correction, deletion, or destruction to third parties to whom the relevant personal data has been transferred, where required by law;
- object to a result arising against you from the analysis of your processed personal data exclusively by automated systems, where the applicable legal conditions are met; and
- request compensation for damage arising from unlawful processing of your personal data.
To exercise applicable KVKK rights, you may contact us at privacy@predictability.app. We may request additional information to verify your identity and may require a request to be submitted through an applicable formal procedure where required by KVKK.
Requests under the KVKK will be handled within the periods and according to the procedures prescribed by applicable Turkish law.
8. Your Privacy Rights in the United States
If you are located in the United States, you may have additional privacy rights under applicable federal and state privacy laws. The rights available to you depend on your state of residence and whether a particular law applies to Predict Games and the relevant processing activity.
Depending on applicable law, these rights may include the right to:
- know or access the personal information we collect about you;
- request correction of inaccurate personal information;
- request deletion of personal information, subject to applicable exceptions;
- obtain a copy of certain personal information in a portable format;
- opt out of certain forms of targeted advertising, sale, or sharing of personal information, where applicable;
- opt out of certain profiling or automated decision-making activities, where applicable; and
- receive equal treatment for exercising applicable privacy rights.
Where a U.S. state privacy law applies to us, we will provide the rights and disclosures required by that law. You may contact us at privacy@predictability.app to exercise applicable privacy rights.
For California residents, additional rights may apply under the California Consumer Privacy Act ("CCPA") and its implementing regulations where the CCPA applies to our business. These may include rights to know, delete, correct, and obtain certain personal information, as well as rights to opt out of certain sales or sharing of personal information and certain uses of sensitive personal information.
We do not sell your personal information to data brokers. However, certain advertising-related disclosures or transfers may be treated differently under applicable U.S. privacy laws. Where an applicable law gives you a right to opt out of a particular form of advertising-related processing, we will provide the required mechanism for exercising that right.
9. Automated Decision-Making
Certain features of the Service, such as score calculations, leaderboard rankings, streak tracking, and multiplier outcomes, are processed automatically. However, we do not make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects concerning you within the meaning of Article 22 of the GDPR.
10. Advertising & Tracking
PredictAbility is free to use and is supported by advertising. We use Unity LevelPlay as our advertising mediation platform. Depending on factors such as your location, platform, consent choices, and ad availability, advertisements may be provided by advertising networks including ironSource Ads, Unity Ads, and Yandex Ads.
Advertising providers may process device and advertising information to deliver and measure advertisements, manage ad frequency, detect fraud and abuse, and, where you have provided the required consent, personalise advertising.
On iOS, where tracking as defined by Apple is requested, PredictAbility will ask for your permission through Apple's App Tracking Transparency (ATT) framework. You may decline this request. Declining ATT permission does not prevent you from using PredictAbility, and you may still receive non-personalised or contextual advertisements.
Where required by applicable privacy law, we obtain consent before using personal data or device identifiers for personalised advertising. You may withdraw your consent at any time.
We do not sell your personal data to data brokers.
11. Children
The Service is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a minor has registered, please contact us immediately at privacy@predictability.app and we will delete the account.
12. Security
We use appropriate technical and organisational security measures including encryption, authentication, and access controls. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
13. International Data Transfers
Predict Games is registered in the Netherlands, and some of our service providers and advertising partners may process personal data outside the country or region in which you reside.
Where the GDPR applies and personal data is transferred outside the European Economic Area, we rely on an applicable adequacy decision, the EU-U.S. Data Privacy Framework where applicable, Standard Contractual Clauses, or another lawful transfer mechanism recognised under applicable data-protection law.
Where the KVKK applies and personal data is transferred outside Turkiye, we rely on an applicable mechanism permitted under Turkish law, which may include an adequacy decision, appropriate safeguards such as applicable standard contractual clauses, or another transfer mechanism permitted under Article 9 of the KVKK and its implementing regulations.
The availability of a particular transfer mechanism depends on the destination country, service provider, type of processing, and applicable law.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes to the Service, our data-processing practices, or applicable legal requirements. We will notify you of significant changes via email, an in-app notice, or another appropriate means where required by applicable law. The date at the top of this page reflects the most recent update.