Privacy
Policy.

01 Controller

Permtech GmbH, Robert-Bosch-Weg 52, 63165 Mühlheim am Main, Germany.
Email: [email protected] · Phone: +49 162 9601261

02 This Website

This website is purely informational. It has no contact form, no newsletter signup and no account area, so we collect no personal data from you here.

Our hosting provider automatically records technical server log data (IP address, requested page, browser and operating system, time of request) in order to deliver the site securely. We do not use cookies for tracking or analytics.

All fonts, icons and scripts are served from our own server. No content delivery network or third-party provider is contacted when you open a page, so your IP address is not passed to anyone else.

03 The Entrenaro App

To play Entrenaro you need an account. In the app we process:

• Account data — your email address and password. Passwords are stored hashed, never in plain text. Authentication runs on our own auth service using JSON Web Tokens (JWT); we do not use third-party sign-in providers.
• Profile data — your display name and, if you upload one, your avatar image.
• Gameplay data — the communities you belong to, your squad, lineups, bids, budget and points.
• Technical data — server logs as described above. If you report a problem, the details you send us by email.

Your display name, avatar and gameplay activity are visible to the other members of your community — that is the point of the game. They are not public outside it.

04 Purpose and Legal Basis

Account, profile and gameplay data are processed to provide the game you signed up for. Legal basis: Art. 6(1)(b) GDPR (performance of a contract).

Server log data is processed to operate and secure the service. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a functioning, secure service).

If you email us at [email protected], we process your message solely to answer it, on the basis of Art. 6(1)(b) and (f) GDPR.

05 Hosting and Processors

This website and the Entrenaro backend are hosted on Railway (Railway Corp., 548 Market St, San Francisco, CA 94104, USA) under a data processing agreement, with EU Standard Contractual Clauses covering the transfer of data to the United States.

Our domain is registered with Cloudflare (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA), which also provides our DNS and acts as a proxy in front of the site. Because every request passes through Cloudflare's network, it processes connection data — your IP address, the page requested and technical details of your browser — in order to route the request and protect the service against attacks. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure, available service). A data processing agreement with EU Standard Contractual Clauses is in place. See cloudflare.com/privacypolicy.

Match and player data shown in the app is licensed from a sports data provider. That data concerns professional footballers, not you — no personal data of yours is sent to the provider.

We do not use an analytics or crash-reporting service. Problems reach us by email only.

06 App Stores

The app is distributed through the Apple App Store and Google Play. When you download or update it, the respective store operator processes data under its own privacy policy — we have no access to it and receive no personal data from those visits.

07 Data Retention

Server log data is deleted or anonymised after 30 days.

Account, profile and gameplay data are kept for as long as your account exists. You can delete your account in the app at any time; the data is then removed within 30 days, except where we are required to keep records by law.

Email correspondence is kept as long as needed to handle your enquiry and to meet statutory retention obligations.

08 Data Sharing

We do not sell your data and we do not use it for advertising. Beyond the processors named above, acting solely on our instructions, your data is not passed to third parties.

09 Your Rights (GDPR)

You have the right to:

• Access your data (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction of processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)

You can delete your account yourself in the app. To exercise any of the other rights, contact us at [email protected].

10 Children

Entrenaro is not directed at children under 16. If you are under 16, you need the consent of a parent or guardian to use the app.

11 Supervisory Authority

You have the right to lodge a complaint with the competent supervisory authority:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit
Postfach 3163, 65021 Wiesbaden
datenschutz.hessen.de

12 Changes

This policy may be updated from time to time. The current version is always available at this URL.