Privacy Policy

1. Who we are

Pick-a-Playr is operated by **NEWLCO LIMITED**, a company registered in Scotland.

For the personal data described in this Privacy Policy, NEWLCO LIMITED is the data controller.

You can contact us about privacy or data-protection matters at:

**support@pickaplayr.com**

Website:

**https://www.pickaplayr.com/**

2. What this policy covers

This Privacy Policy explains how Pick-a-Playr collects, uses, stores, shares, and protects personal data when you:

- use the Pick-a-Playr mobile application;

- use Pick-a-Playr web services;

- create or manage a Pick-a-Playr account;

- take part in Pick-a-Playr lobbies and gameplay;

- use subscription or account-management features; or

- contact us for support.

3. Information we collect

3.1 Account and profile information

We may collect and store:

- your email address;

- your username;

- your date of birth;

- whether your account is treated as under or over 18 for feature eligibility;

- internal account identifiers;

- authentication identifiers associated with Auth0;

- whether you accepted the Pick-a-Playr Terms and Conditions and when that acceptance occurred;

- your account and gameplay preferences, such as scoring mode; and

- your advertising-consent preference and when it was last changed.

We use date of birth to apply age restrictions and age-appropriate functionality. Pick-a-Playr is not intended for children under 13.

3.2 Authentication information

Pick-a-Playr uses Auth0 to provide authentication, including passwordless email sign-in.

Auth0 may process information required to authenticate you, such as:

- your email address;

- an authentication/user identifier;

- authentication-session information; and

- technical information required to operate and secure the authentication service.

The mobile app may securely store authentication tokens on your device so that you can remain signed in.

We do not store your email one-time-code as a Pick-a-Playr account credential.

3.3 Gameplay and lobby information

When you use Pick-a-Playr, we may process information about your activity, including:

- lobbies you create or join;

- lobby membership;

- player selections;

- scoring mode and ruleset choices;

- leaderboard and gameplay state;

- match-related actions;

- consequences assigned during supported gameplay modes; and

- other information required to provide the game's features.

Your username and relevant gameplay information may be visible to other users participating in the same lobby.

3.4 Subscription information

Pick-a-Playr supports account tiers including Standard, Pro, and Lifetime access.

Where paid subscriptions are enabled, we may process subscription information such as:

- the subscription product you purchased;

- your subscription status;

- purchase or subscription identifiers;

- subscription start, renewal, cancellation, expiry, billing-issue, grace-period, or revocation state;

- whether the subscription is expected to renew;

- the applicable store environment, such as sandbox or production; and

- the date on which subscription information was last verified.

Pick-a-Playr does not receive or store your full payment-card details.

Payments are processed by the applicable app store, such as Google Play or the Apple App Store. RevenueCat is used to help Pick-a-Playr manage and reconcile subscription status across supported platforms.

3.5 Advertising preferences

Standard accounts may be supported by advertising.

We may store whether you have selected:

- non-personalised advertising; or

- personalised advertising, where you are eligible and have provided the required consent.

Users under 18 are restricted to non-personalised advertising.

At the date of this policy, the Pick-a-Playr mobile application does not have a live third-party advertising SDK connected. If a third-party advertising provider is introduced, this Privacy Policy and the relevant Google Play and Apple privacy disclosures will be updated before that provider is used to process user or device data.

3.6 Technical, security, and diagnostic information

When you use Pick-a-Playr, our systems and infrastructure providers may process technical information required to deliver and secure the service. This may include:

- IP address;

- request and response timestamps;

- device or browser information;

- operating-system or application-version information;

- network and request metadata;

- authentication and account identifiers associated with a request;

- error and diagnostic information; and

- security and abuse-prevention information.

We use this information to operate, troubleshoot, secure, and improve the service.

At the date of this policy, the Pick-a-Playr mobile application does not use a dedicated third-party analytics or crash-reporting SDK. If this changes, this policy and the relevant store disclosures will be updated.

4. How we collect information

We collect information:

- directly from you when you create or complete your account;

- when you use Pick-a-Playr features;

- when you change settings or preferences;

- from Auth0 when you authenticate;

- from RevenueCat and the applicable app store where subscription functionality is used;

- automatically through our servers and supporting infrastructure when the service is accessed; and

- when you contact us for support.

5. Why we use your information

We use personal data to:

- create and manage your Pick-a-Playr account;

- authenticate you securely;

- apply age restrictions and age-appropriate functionality;

- provide lobbies, player selection, scoring, leaderboards, and other gameplay features;

- remember your settings and preferences;

- provide and verify subscription entitlements;

- provide appropriate advertising behaviour where advertising is enabled;

- prevent misuse, fraud, unauthorised access, and security incidents;

- diagnose errors and maintain service reliability;

- respond to support and privacy requests;

- comply with legal obligations; and

- establish, exercise, or defend legal rights where necessary.

6. Lawful bases for processing

Where UK data-protection law applies, we rely on one or more of the following lawful bases:

Contract

We process information where it is necessary to provide the Pick-a-Playr service you request, including account management, authentication, gameplay, and subscription functionality.

Legitimate interests

We process information where necessary for legitimate interests such as:

- operating and improving Pick-a-Playr;

- maintaining service security and reliability;

- preventing abuse or fraud;

- troubleshooting technical problems; and

- protecting users and the service.

We consider the impact of this processing on your rights and interests.

Consent

Where required, we rely on your consent, for example for personalised advertising or other optional processing that legally requires consent.

You may withdraw consent for optional processing at any time through the available settings or by contacting us.

Legal obligations

We may process or retain information where necessary to comply with applicable legal or regulatory requirements.

7. Who we share information with

We do not sell your personal data.

We may share or make data available to the following categories of recipients where necessary.

Auth0

Auth0 provides authentication services for Pick-a-Playr and processes authentication-related information.

RevenueCat

Where subscription functionality is enabled, RevenueCat helps us manage subscription identity, entitlement, and lifecycle information.

Google Play and Apple App Store

The applicable app store processes purchases and subscription payments. Pick-a-Playr receives subscription and transaction-status information required to provide purchased access, but does not receive your full card details.

Infrastructure and network providers

Providers used to deliver, secure, route, or host Pick-a-Playr services may process limited technical data needed to provide those services. This includes services used for domain, network, API, or website delivery.

Other Pick-a-Playr users

Your username and gameplay information may be visible to other participants in the same lobby where this is required for the game's social and leaderboard features.

Authorities and legal recipients

We may disclose information where required by law, court order, or another valid legal process, or where reasonably necessary to protect users, Pick-a-Playr, or the rights of others.

8. Football data providers

Pick-a-Playr uses third-party football-data services, including SportMonks, to obtain fixtures, line-ups, players, scores, and match events.

These requests are made by the Pick-a-Playr backend. We do not intentionally send your Pick-a-Playr account profile, email address, date of birth, or authentication credentials to SportMonks as part of normal football-data requests.

9. International data transfers

Some service providers used by Pick-a-Playr may process information outside the United Kingdom.

Where UK data-protection law requires safeguards for an international transfer, we take steps intended to ensure an appropriate lawful transfer mechanism or other permitted safeguard is in place.

10. How long we keep information

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing your account, maintaining security, meeting legal obligations, and resolving disputes.

In general:

- account and profile information is retained while your account remains active;

- gameplay and lobby information is retained for as long as required to provide and operate the relevant functionality;

- subscription records may be retained where needed to verify purchases, resolve billing or entitlement issues, prevent fraud, or meet legal requirements;

- security and diagnostic records may be retained for a limited period appropriate to their operational purpose; and

- where backups are used, deleted information may remain in protected backups until those backups are overwritten or expire through the normal backup cycle.

We may retain limited information after account deletion where we have a legal obligation or another lawful reason to do so. Where this applies, the information will not be retained for longer than necessary for that purpose.

11. Account and data deletion

You can request deletion of your Pick-a-Playr account and associated personal data.

An account-deletion option is provided through Pick-a-Playr account settings. We also provide a public web route for users who no longer have access to the app.

You may also contact:

**support@pickaplayr.com**

When an account is deleted, we aim to delete the Pick-a-Playr account and associated personal data that we are not legally required to retain. This includes requesting deletion from relevant service providers where necessary and applicable.

Deleting a Pick-a-Playr account does not automatically cancel an active subscription billed by Google Play or Apple. You should cancel any active store subscription through the relevant store account if you do not want future renewals.

Where we must retain limited information for legal, fraud-prevention, security, or dispute-resolution purposes, we will retain only what is necessary and only for as long as required.

12. Your data-protection rights

Depending on the circumstances and applicable law, you may have the right to:

- ask for access to your personal data;

- ask us to correct inaccurate or incomplete data;

- ask us to delete your personal data;

- ask us to restrict processing;

- object to certain processing;

- request data portability;

- withdraw consent where processing is based on consent; and

- complain to a data-protection regulator.

To exercise your rights, contact:

**support@pickaplayr.com**

We may need to verify your identity before completing certain requests.

13. Children and age restrictions

Pick-a-Playr is not intended for children under 13, and users must provide a date of birth during profile completion.

Users aged 13 to 17 are restricted to age-appropriate functionality. In particular:

- Drinks mode is not available to users under 18; and

- users under 18 are not eligible for personalised advertising.

If we become aware that an account has been created by a child under 13, we may take steps to remove the account and associated data.

14. Security

We use reasonable technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure.

These measures include authenticated access controls, secure transport for network communications, restricted access to server-side credentials, and secure device storage for supported authentication information.

No internet-connected service can be guaranteed to be completely secure.

15. Cookies and similar technologies

The Pick-a-Playr website and web application may use cookies or similar technologies required for authentication, session management, security, and operation of the service.

Where optional advertising or other non-essential technologies require consent, we will provide appropriate controls.

The mobile application does not rely on browser cookies for its normal authenticated API session, but third-party platform services may use their own identifiers or storage as described in their respective privacy information.

16. Changes to this Privacy Policy

We may update this Privacy Policy when Pick-a-Playr changes, when we add or remove service providers, or when legal or store requirements change.

The latest version will be published on the Pick-a-Playr website with an updated date.

If a change materially affects how we use personal data, we will take appropriate steps to inform users where required.

17. Complaints

If you have a concern about how Pick-a-Playr handles your personal data, please contact us first at:

**support@pickaplayr.com**

You also have the right to complain to the UK Information Commissioner's Office (ICO).

Information about the ICO is available at:

**https://ico.org.uk/**