Privacy Policy

Last updated: April 2026 · In accordance with GDPR

1. Data Controller

The data controller within the meaning of the GDPR is the operator listed in the Legal Notice (Impressum):

Yasar Sengül · Am Mühlfeld 29 · 91522 Ansbach · Germany
Contact: yasar.senguel@proton.me

2. What Data Is Processed?

2.1 Data Stored Locally on Your Device

Data	Purpose	Storage Location
Bankroll amount	Kelly Criterion calculation	Device (SharedPreferences)
Disclaimer acceptance	One-time confirmation	Device (SharedPreferences)
Kelly multiplier setting	Stake calculation preference	Device (SharedPreferences)

2.2 Data Stored on the Server (Betting Diary)

Data	Purpose	Storage Location
Match name, market, odds	Betting diary	Private VPS (Germany, EU)
Stake, result, profit/loss	ROI calculation	Private VPS (Germany, EU)
Bet date	Statistics	Private VPS (Germany, EU)

No personal data (name, email, IP address, location) is stored. The betting diary contains only betting data without any personal reference.

3. Purpose of Data Processing

Providing app features (diary, statistics, ROI tracking)
No sharing with third parties
No advertising, no tracking, no profiling

4. Legal Basis

Data processing is based on Art. 6(1)(b) GDPR (performance of a contract) for providing the app features, which the user has agreed to by accepting these terms.

5. Retention Period

Betting diary data is stored until the user deletes it or requests deletion. There is no automatic deletion period.

6. Third-Party Services

Provider	Purpose	Privacy Policy
IONOS SE (VPS Hosting)	Server hosting for the betting diary, located in Germany	ionos.de/privacy
The Odds API	Sports odds data (no user data transmitted)	the-odds-api.com
Football-Data.co.uk	Historical match data (no user data)	football-data.co.uk

7. No Cookies, No Tracking

The app and this website use no cookies, no Google Analytics, no advertising networks, and no other tracking technologies.

8. Data Transfer to Third Countries

All servers are located on a private VPS in Germany (EU). No user data is transferred to countries outside the EU. All data transmission is encrypted via HTTPS/TLS.

9. Your Rights (GDPR)

You have the right at any time to:

Access — request information about data stored about you
Rectification — correct inaccurate data
Erasure — request complete deletion of your data
Objection — object to processing
Data portability — export your data

To exercise your rights, contact the address listed in the Legal Notice. Requests will be responded to within 30 days.

You also have the right to lodge a complaint with the competent data protection supervisory authority.

10. Data Security

All data transmissions between the app and server are encrypted via HTTPS/TLS. No passwords or payment data are processed.

11. Changes to This Policy

This privacy policy may be updated in the event of significant changes. The date of the last update is shown above.