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Privacy Policy

Version 2026-07-02-draft · Effective date: pending

DRAFT — pending legal review. This policy is a working draft and has not yet been reviewed by counsel.

1. Who we are

Holy Pools ("we", "us"), operated by [COMPANY LEGAL NAME], [COMPANY ADDRESS], is the data controller for the sports prediction game at www.holypools.com. Contact: theholypools@gmail.com.

2. What we collect

We do not collect payment card details (deposits are not currently available) and we do not run advertising trackers. Local storage in your browser is used only to keep your session and your in-progress picks.

3. What we use it for

4. Who processes it

We use a small set of processors, each receiving only what their function needs:

We do not sell your data, and we do not share it with advertisers. Sports fixtures and results come from third-party data providers, but no personal data of yours is sent to them.

5. Retention

Account and gameplay data are kept while your account exists. The balance ledger and settlement records are retained after account closure for as long as required for audit and legal purposes. Technical logs rotate on short cycles set by our hosting providers. Error reports expire automatically on our error-tracking plan's retention window (90 days).

6. Your rights

Depending on your jurisdiction, you may have the right to access, correct, export, or delete your personal data, and to object to or restrict certain processing. Until self-service tools ship, contact theholypools@gmail.com and we will action requests within 30 days. Account deletion removes your personal identifiers; anonymized settlement records may be retained as described in Retention.

7. Security

Data is encrypted in transit (TLS) and at rest by our providers. Database access is protected by row-level security; wallet mutations require locks and leave an audit trail. No system is perfectly secure — if we learn of a breach affecting your data we will notify you as required by law.

8. Children

Holy Pools is for adults 18+. We do not knowingly collect data from anyone under 18; if we learn we have, we will delete the account.

9. Changes and contact

We may update this policy; material changes will be announced in the app. Questions or requests: theholypools@gmail.com.