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

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)

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

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.