Privacy Policy
This Privacy Policy explains how OliveOdds (“we”, “us”, “our”) collects, uses, and protects your personal data when you use the OliveOdds mobile application (“App”). It is drafted in compliance with the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.
This version replaces the version of 20 March 2026, primarily to describe the paid subscriptions and passes introduced in the App. A summary of changes is at the end of this policy.
1. Who We Are (Data Controller)
The data controller responsible for your personal data is:
Vedado UG (haftungsbeschränkt)
Bossestraße 6B
10245 Berlin, Germany
Represented by: Eros Garcia Ponte (Geschäftsführer)
Contact email: eros902002@googlemail.com
2. What Data We Collect
2.1 Account Data
When you first open the App, an anonymous account is created for you automatically via Firebase Authentication. It consists of a random user identifier and contains no name, email address, or other directly identifying information. It is used to store your data (such as logged bets) under your installation and to deliver your purchased access.
Email accounts (email address and password, via Firebase Authentication) are currently created by OliveOdds administrators; self-registration in the App is disabled by default. If you have an email account, your email address is used solely to identify you and secure your access.
2.2 Purchase and Subscription Data
Subscriptions and passes are sold exclusively through Apple’s App Store (In-App Purchase). Payment is processed by Apple. We never receive your name, billing address, or payment details; Apple acts as an independent controller for the payment transaction under its own privacy policy.
In connection with purchases we process:
- Transaction data provided by Apple’s StoreKit framework and by Apple’s App Store Server Notifications: purchased product, purchase and expiry dates, transaction identifiers, and subscription status (e.g. renewed, cancelled, in billing retry). We use this to activate and deactivate your access.
- A purchase token: a random identifier (UUID) generated on your device and attached to your purchases, which links your App Store transactions to your account so that your access can be delivered and restored. It contains no personal information by itself.
Legal basis: contractual necessity (Art. 6(1)(b) GDPR).
2.3 Usage Data
We collect pseudonymized usage-event data via Firebase Analytics, including: sign-in events, screens and features accessed, prediction and match-detail views (sport, match, plan tier), bet-logging and bet-status events, and ad interaction events (impressions, clicks, load success/failure) by placement. This data is used to understand how the App is used, improve features, and measure advertising performance.
2.4 Performance and Crash Data
Firebase Performance Monitoring collects technical performance metrics (app startup time, network request latency) and Firebase Crashlytics collects crash reports. This data is linked to pseudonymous installation identifiers, not directly to your identity.
2.5 Bet Tracking Data
Bets you choose to log in the App (sport, match, market, side, odds, your stake, model probability, status, and derived figures such as the suggested stake at the time of logging) are stored in Firebase Realtime Database under your user ID. The database instance is hosted in the European Union (europe-west1). Your bankroll amount itself is stored only locally on your device and is not uploaded; individual logged bets may include stake and bankroll-derived values at the time of logging.
2.6 Advertising Identifiers
The free tier of the App shows banner advertising. If you grant consent via the App Tracking Transparency (ATT) prompt and the Google User Messaging Platform (UMP) consent form, your device’s IDFA may be collected and shared with Google AdMob and its mediation partners (Unity Ads and Liftoff/Vungle) to serve personalised advertisements. If you decline, no IDFA is accessed and any ads shown are non-personalised.
While you have any active paid subscription or pass, the App shows no advertising, and no ad-related data is collected for you.
2.7 Consent Records
Your advertising consent choices (UMP consent state) are stored locally on your device and synchronised with Google’s consent infrastructure to honour your preferences across sessions.
2.8 In-App Messages
We may show announcements or messages inside the App, delivered via Firebase Remote Config and Firebase In-App Messaging. Targeting, where used, relies on the pseudonymous identifiers described above.
3. Legal Basis for Processing (GDPR Article 6)
| Processing activity | Legal basis |
|---|---|
| Account creation and authentication | Contractual necessity (Art. 6(1)(b)) |
| Purchase, subscription and entitlement processing | Contractual necessity (Art. 6(1)(b)) |
| Bet data storage and retrieval | Contractual necessity (Art. 6(1)(b)) |
| Firebase Analytics usage events | Legitimate interests (Art. 6(1)(f)) — improving the App |
| Performance monitoring and crash reporting | Legitimate interests (Art. 6(1)(f)) — maintaining quality and stability |
| Personalised advertising (IDFA) | Consent (Art. 6(1)(a)) — only with your explicit ATT/UMP consent |
| Non-personalised advertising | Legitimate interests (Art. 6(1)(f)) — funding the free tier |
Where we rely on legitimate interests, you have the right to object (see Section 9).
4. Third-Party Data Processors
We share data with the following processors, each bound by data-processing agreements and, where applicable, EU Standard Contractual Clauses or an adequacy mechanism:
| Processor | Purpose | Privacy policy |
|---|---|---|
| Google Firebase (Authentication, Realtime Database, Analytics, Crashlytics, Performance, Remote Config, In-App Messaging) | Core infrastructure, authentication, data storage, analytics, stability | Google Privacy Policy |
| Google AdMob | Ad serving and mediation (free tier only) | Google Ads Privacy Policy |
| Unity Ads | Ad demand partner via AdMob mediation | Unity Privacy Policy |
| Liftoff (Vungle) | Ad demand partner via AdMob mediation | Liftoff Privacy Policy |
Apple (Apple Distribution International Ltd. / Apple Inc.) processes your payment and App Store account data as an independent controller, not as our processor.
We do not sell your personal data to any third party.
5. International Data Transfers
Your bet data and account data are stored in the EU (Firebase Realtime Database, region europe-west1). Some processors listed in Section 4 process data in the United States (e.g. analytics, crash reporting, ad serving). These transfers rely on the EU–US Data Privacy Framework where the processor is certified, and otherwise on Standard Contractual Clauses approved by the European Commission. Details are in each processor’s privacy documentation linked above.
6. Advertising and Consent Management
On app start we use Google’s User Messaging Platform (UMP) to check whether advertising consent is required and, for users in the EEA/UK, display a consent form where necessary. Afterwards, we request permission via Apple’s App Tracking Transparency framework if you have not previously made a choice.
- Consent granted: personalised ads may be served using your IDFA.
- Consent declined: non-personalised ads are served; your IDFA is not accessed.
- Change or withdraw consent at any time: Settings → Manage Privacy Preferences in the App, or your device’s Settings → Privacy & Security → Tracking.
- Subscribers: no ads are shown while any plan is active.
7. Data Retention
| Data category | Retention period |
|---|---|
| Account data (Firebase Auth) | Lifetime of your account, plus up to 30 days after a deletion request |
| Bet tracking data | Lifetime of your account, plus up to 30 days after a deletion request |
| Purchase and entitlement records | As long as needed to deliver your access, and thereafter as required by statutory commercial and tax retention duties |
| Firebase Analytics events | Up to 14 months (Google’s standard retention) |
| Crash and performance data | Typically 90 days (Firebase defaults) |
| Advertising consent state | Until you change your preference or uninstall the App |
After the applicable period, data is deleted or anonymized so that it can no longer be linked to you.
8. Account and Data Deletion
You can request deletion of your account and data at any time via Settings → Account → Delete Account in the App (which opens a pre-filled email to us) or by emailing eros902002@googlemail.com from the address associated with your account. See Account deletion for exactly what is deleted, what is retained, and how long it takes. Purchases are managed by Apple; deleting your account does not cancel an active subscription (cancel in your device’s Settings → Apple Account → Subscriptions).
9. Your Rights Under GDPR
If you are in the EEA, you have the following rights regarding your personal data. To exercise any of them, contact us at eros902002@googlemail.com.
- Access (Art. 15) — request a copy of the personal data we hold
- Rectification (Art. 16) — request correction of inaccurate data
- Erasure (Art. 17) — request deletion (“right to be forgotten”)
- Restriction (Art. 18) — restrict processing in certain circumstances
- Data portability (Art. 20) — receive your data in a machine-readable format
- Objection (Art. 21) — object to processing based on legitimate interests
- Withdraw consent (Art. 7(3)) — withdraw advertising consent at any time
We will respond within 30 days and may need to verify your identity.
You also have the right to lodge a complaint with a supervisory authority. The authority competent for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59–61, 10555 Berlin, Germany; you may also complain to the authority of your own EU member state.
10. Children’s Privacy
OliveOdds is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.
11. Local Storage
The App does not use browser cookies. It uses Apple’s UserDefaults system to store, locally on your device: your advertising consent state, app preferences, your bankroll amount, cached prediction data, onboarding state, and the purchase token described in Section 2.2.
12. Changes to This Privacy Policy
We may update this policy to reflect changes in the App or in legal requirements. Material changes will be announced via an in-app notice. The effective date and version at the top of this page always identify the current revision; previous versions remain available at the bottom of this page.
13. Contact
For any questions, requests, or complaints related to your privacy:
Email: eros902002@googlemail.com
Summary of changes vs. version 2026-03: added Section 2.2 (purchase and subscription data, Apple as independent controller, purchase token); noted the anonymous account created on first launch; added Crashlytics and In-App Messaging to the processor list; documented the EU (europe-west1) location of the database; added the ad-free effect of subscriptions; named the competent supervisory authority (Berlin); added Section 8 on account deletion with a dedicated page; completed the contact email that was left as a placeholder in the previous version.