Privacy Policy: PashaPredict and the PashaPredict Shop
Version: 2026-10-30 · Effective date: 30 October 2026 · Language: English (binding together with the Romanian version)
Changes since version 2026-10-28: new section 4 separates service (transactional) e-mails from marketing; marketing is sent only with separate, unticked opt-in consent, and buyers whose consent is unknown receive none; retention periods are stated as final.
1. Who is responsible (controller)
- Controller: PashaPredict, Timișoara 300001, Romania, registration and VAT details available on request at support@pashapredict.com.
- Contact for privacy questions: support@pashapredict.com (PashaPredict and physical-goods orders).
- Data protection officer: not appointed
2. What data we collect
2.1 When you buy through our Shopify store
Your name, e-mail address, billing details, country, order details, the products bought, amounts and currency, and payment status. Card details are entered on Shopify's checkout and handled by Shopify Payments and its payment partners. We do not receive or store your full card number.
2.2 When you subscribe to PashaPredict
- Account: e-mail address, Client ID, a one-way cryptographic hash of your Access Code (we never store the code itself), language and display preferences.
- Subscription: plan, subscription state (active, cancelled, payment failed, paused, ended), paid-through date, renewal date, payment amounts and currency, and the Shopify order, customer and subscription references needed to link your payments to your account.
- Immediate-access acknowledgement: policy version, date and time, plan, country / market and whether you ticked the acknowledgement (see Digital Access & Withdrawal).
- Use of the service: saved matches, followed teams, notification settings and push-notification subscriptions, if you enable them.
- Sessions and security: session records, device or browser type, sign-in times, IP-derived country, and security and audit logs (for example sign-ins, access-code resets, administrative actions).
- E-mail delivery: delivery status of the e-mails we send you (sent, delivered, delayed, bounced, complaint).
- Support: messages you send to support@, contact@ or access@pashapredict.com.
- Marketing choice: whether you opted in to marketing e-mails. This choice is kept separately from your PashaPredict account and never affects your access.
We do not use advertising trackers or sell your data. We do not collect special categories of data.
3. Why we use your data, and the legal basis
| Purpose | Legal basis (GDPR art. 6) |
|---|---|
| Creating your account, giving access, managing your subscription, renewals and cancellations | Performance of the contract (6(1)(b)) |
| Taking payments and keeping accounting records | Contract; legal obligation (6(1)(c)) for tax and accounting records |
| Sending service (transactional) e-mails: activation and credentials, order and subscription notices, renewal and payment-failure notices, cancellation confirmations, security notices, support replies (section 4) | Contract (6(1)(b)); for security notices also legitimate interest (6(1)(f)) |
| Recording the immediate-access acknowledgement | Legal obligation and our legitimate interest in proving it (6(1)(c), 6(1)(f)) |
| Security, fraud prevention, enforcing the single-session and no-sharing rules, abuse detection | Legitimate interest (6(1)(f)) |
| Answering support requests and complaints | Contract; legitimate interest |
| Marketing e-mails (newsletters, promotions, launch announcements, sales and feature campaigns) | Only with your separate consent (6(1)(a)); see section 4 |
| Service improvement using aggregated, non-identifying statistics | Legitimate interest |
4. E-mails we send: service messages and marketing
Service (transactional) e-mails are part of the service you bought. We send them to the e-mail address used for the purchase, whether or not you agreed to marketing:
- activation and sign-in credentials (Client ID, Access Code) and access-code resets;
- order and subscription notices, such as payment confirmations and billing information;
- renewal and payment-failure notices;
- cancellation confirmations;
- security notices, for example about sign-ins, sessions or a reset of your Access Code;
- replies to your support requests and complaints, and notices of material changes to our terms.
Marketing e-mails are newsletters, promotions, launch announcements, sales campaigns and feature campaigns. They are optional:
- we send them only if you have given separate consent, for example by ticking an opt-in box that is never pre-ticked;
- buying a subscription, or having bought one in the past, is never treated as consent;
- customers whose marketing consent is unknown, including earlier buyers, receive no marketing;
- you can use PashaPredict fully without agreeing to marketing;
- you can withdraw consent at any time, through the unsubscribe link in any marketing e-mail or by writing to support@pashapredict.com; service e-mails continue.
5. Who processes data for us (processors)
| Provider | What they do | Data involved |
|---|---|---|
| Shopify (incl. Shopify Payments) | Online store, checkout, payment processing, order records | Order, customer and payment data |
| Seal Subscriptions | Recurring billing, subscription portal, renewal and cancellation management | Customer e-mail and name, subscription and billing data |
| Resend | Sending transactional e-mails (EU region) | E-mail address, e-mail content (including credentials), delivery events |
| Google Cloud (App Engine, Firestore, Cloud Storage; EU regions) | Hosting the PashaPredict application and database | All PashaPredict account, subscription, security and usage data described above |
| Squarespace / Mailgun | Domain and e-mail forwarding of support@, contact@ and access@pashapredict.com to our mailbox | Messages you send us |
| Google (Gmail) | Our support mailbox | Messages you send us |
Our football-data provider receives no customer data. Payment providers and banks also process data under their own responsibility. Each processor acts on our instructions under a data processing agreement or its standard terms.
6. International transfers
- Where data is stored. We host PashaPredict in the European Union. Some providers (Shopify, Seal, Resend, Google) are, or have affiliates, outside the EEA, for example in Canada or the United States.
- Safeguards. Transfers rely on an adequacy decision (for example Canada, or the EU–US Data Privacy Framework for certified companies) or on the European Commission's Standard Contractual Clauses.
- Copies. You can ask us for information about these safeguards.
7. How long we keep data
| Data | Retention |
|---|---|
| Account and subscription data | While your account is active, and for 3 years after your last subscription ends (for support, returning customers and legal claims), then deleted or anonymised |
| Order, payment and invoicing records | As long as Romanian accounting and tax law requires (currently up to 10 years) |
| Immediate-access acknowledgement records | For the life of the contract plus 3 years |
| Security and audit logs | Up to 12 months, longer only if needed for an investigation |
| Technical server logs | Up to 30 days |
| E-mail delivery events | Up to 12 months |
| Support messages | Up to 3 years after the matter is closed |
| Backups | Rolling backups kept for up to 14 days |
8. Security
- Encryption. Data is sent over HTTPS and stored encrypted by our hosting provider.
- Access codes. Stored only as one-way hashes.
- Secrets. Kept in a dedicated secret store.
- Access controls. Administrative access is restricted and logged.
- Signed events. Payment and subscription events are accepted only when cryptographically signed by Shopify or Seal.
- No absolute guarantee. No system is perfectly secure; we will notify you and the authorities of a personal-data breach where the law requires it.
9. Your rights
You have the right to:
- access your data;
- rectify it;
- have it erased;
- restrict its processing;
- data portability;
- object to processing based on legitimate interest;
- withdraw consent at any time.
To exercise them, write to support@pashapredict.com. We reply within one month. You may also complain to the Romanian data-protection authority, ANSPDCP (www.dataprotection.ro), or to the authority in your EU country of residence.
10. Cookies and local storage
See the Cookie Policy. PashaPredict uses only strictly necessary cookies and browser storage.
11. Children
PashaPredict is not intended for anyone under 18. We do not knowingly collect data from minors.
12. Changes
We publish the current version with its date at the top. Material changes are announced to active subscribers by e-mail or in the app.