Privacy policy

This page explains what the Forepitch website («we») stores about its readers and account holders, why, for how long and what you can do about it. We collect as little as the site needs to work, we do not sell data, show no ads and use no third-party trackers or analytics services.

Who is responsible for the data

The controller of personal data is the owner of the Forepitch website. For any question about your data, including requests from the EU, the UK, Brazil and elsewhere, write to privacy@forepitch.com; this address is also the contact of the person responsible for data protection (the encarregado in Brazil).

You can read the site without telling us anything. An account needs only an e-mail address: without it you cannot sign in or recover access; a nickname and everything else are optional.

What we store

If you only read the site

• Visit statistics. For every page view: the page address, the site you came from (only its domain, e.g. google.com) and the country, determined from your IP address. To count unique visitors we keep a hash of the IP address and browser mixed with a random salt of the day; the salt is deleted the next day, after which the hash cannot be linked to anyone. The IP address itself is not stored, no cookies are used for this, bots are not counted.
• Visit memory, without an identifier. To see how long the site is read and whether readers come back, your browser keeps in its storage (fp_v) only dates and counts: the day of your first and last visit, how many days you visited, when the current visit was last active and how many pages and seconds it has. With a page view it sends conclusions from them — «first view of the day», «the previous visit was 3 days ago», «first came on 12.09» — plus how many seconds the page was on screen and in use and the device type (phone, tablet, computer); the browser and system are taken from the User-Agent header. On the server all of this is only added to counters per day: no identifier is sent or stored, so nobody can be followed from visit to visit. The memory starts again 13 months after the first visit. You can switch it off below; it is also off when the browser sends «Global Privacy Control» or «Do Not Track».
• Technical server logs (address, time, requested page) may be kept briefly by the server for its operation and protection against attacks.
• Translation error reports (if you send one from a page in English, Portuguese or Spanish): the text with the error, your suggestion, a comment, the page address and the time — without your account or IP address.

If you create an account

• Account: e-mail; the password only as a scrypt hash (we never see or store the password itself); the nickname, if you set one; the dates of registration and last sign-in; whether the e-mail is confirmed; the Premium end date and whether the trial was used; the country of registration and of the last sign-in (determined from the IP address); which version of this policy you accepted and when.
• Active days: the dates on which you used the site while signed in (only the dates, without pages) — to count how many players come back. Kept for 400 days and deleted together with the account.
• Sessions: while you are signed in, a random token in a cookie identifies the session. We store only its hash, the start and last visit time, the IP address and browser name of the session — to protect the account (for example, to see a sign-in from an unknown place). An account can be signed in on at most three devices at once; the list of devices and signing out of them are in the profile.
• «Beat the model»: your picks for the round’s matches (the outcome and, if you give one, the exact score) and their time, the league you play in (and a change you asked for) and your division in every season. Your nickname, points, rank, badges and division are public on the leaderboard (the rank is computed from your answers, the badges you earned are kept); the nicknames of the seasons’ prize winners and of the rounds’ best players are shown on the game page. If you create or join a league with friends, we keep its name, game league, invite link, creator and members with the date they joined; only its members see its table. The player of the month’s nickname is shown on the game page.
• Invites: the code of your invite link (made when you open the profile) and, if you registered with a friend’s link, who invited you — that is how the “Brought a friend” badge is counted (how many friends came, only you see). The link between the two accounts is deleted as soon as either is deleted; invites earn no Premium, and friends’ e-mails are never shown.
• Fair play: so that prizes go to people, not scripts, the server checks finished mini-game series (the timing and spread of the shots) and marks suspicious ones — such a record waits for an admin’s decision. To spot second accounts, the admin sees whether prize winners’ active sessions share an IP address; we collect no new data for this. If a friends’ league owner removes you, we keep that mark so the old link doesn’t let you back in — until the owner lifts it or the league is deleted.
• Favourites: the teams and competitions you marked (a free account keeps up to three of each), and with Premium matches too.
• The «Penalties» mini-game: your series — where you aimed, when you let go and what came of it — and your best result for the table of records; they are deleted with the account. Series played without an account are kept for a day. Where players shoot is counted only anonymously — how many shots went to each zone of the goal, with no link to an account.
• Notifications (if you turned them on): the subscription address your browser’s push service gave, its encryption keys, the device’s language and time zone (so that nothing comes at night), which notifications you want (about your favourite teams’ matches; in “Beat the model” — your round’s and season’s results, a new rank and a reminder before a round) and which were already sent — by match or round and kind — and the highest rank we have told you about. The subscription is deleted when you turn notifications off, when the browser drops it, and with the account.
• The Premium trial: so that it cannot be taken again and again, we keep a hash of the mailbox that used it (not the address itself; Gmail dots and «+tags» count as one mailbox). This hash stays after the account is deleted. Disposable e-mail addresses cannot register.
• Mail links (password reset, e-mail confirmation): single-use; only their hash is stored.
• Sign-in attempts: to stop password guessing, failed attempts (address and e-mail) are counted in the server’s memory for up to an hour and are not written to disk.
• Protecting Premium data: so that it is not downloaded by scripts or passed on, we remember which matches an account opened during the last 24 hours (the records are deleted after two days); signs of automated requests — for example, a request not from a browser or not from the match’s page — and very frequent sign-ins are recorded in the administrator log with the browser name. The Premium numbers of every account carry an invisible mark that tells which account they were copied from (see the terms of use); the mark is computed from the account number and stores nothing.
• Administrator log: changes an administrator makes to an account (Premium, nickname, blocking) are recorded with the account’s e-mail; the same log keeps Premium limit hits and signs of automated requests.

Why

• to provide the account: sign-in, profile, Premium, favourites, notifications and the game;
• to protect accounts and the site: against password guessing, abuse and attacks;
• to send letters you asked for or that concern the security of your account (password reset, e-mail confirmation) — we send no newsletters;
• to understand in aggregate which pages are read, from which countries, how long people stay and whether they come back, to improve the site — including fixing the translation errors you report.

Legal bases

• The account, Premium, favourites, the game and e-mails about the account — performance of our contract with you (the terms of use): the service cannot work without these data. In Russia, Belarus, Kazakhstan, Uzbekistan and other countries whose law requires consent, also your consent to processing, given with a separate checkbox at registration (its text).
• Protecting accounts and the site (sessions, sign-in attempts, the administrator’s log, protection of Premium data) — our legitimate interest in a secure service and performance of the contract.
• Anonymous visit statistics — our legitimate interest in understanding how the site is read; the visit memory in the browser in the EU, the UK and Switzerland — your consent (see «Cookies»).
• Push notifications — your consent: you switch them on yourself and can switch them off at any time.
• What we keep after an account is deleted (the hash of the mailbox that used the trial, the anonymised log) — our legitimate interest in preventing abuse.

We do not take decisions with legal effects about you by automated means alone: signs of automated requests are only logged, and decisions about accounts are taken by the administrator. There is no profiling for advertising.

Cookies and browser storage

We use cookies only for signing in; there are no advertising or third-party cookies and no outside analytics services. For our own visit statistics the browser storage keeps dates without an identifier (fp_v, see above). Fonts and scripts are loaded from our own server.

In the EU and the European Economic Area, the UK and Switzerland (we tell by the browser’s time zone) the visit memory is switched on only with your consent — the «Allow» button in the cookie bar or the switch below; until then only page views are counted. The sign-in cookies and the storage for the theme and settings are needed for the site to work and do not require consent.

Switch the visit memory off

Switched off, the browser forgets the memory and the visits are counted only as page views (see «Visit statistics»).

Where the data are stored

The data are stored on the server that runs the site (HOSTKEY B.V., NL) and in its backups. E-mails are delivered by Resend (USA; sent from the EU, Ireland). Push notifications go through the browser makers’ services, which may be outside your country, including in the USA; they receive only the encrypted notification. When data leave the EU, the UK or Switzerland, the transfer relies on adequacy decisions or the standard contractual clauses of these services.

Who else gets the data

• Mail service. When we send you a letter, your e-mail and the letter’s text are passed to the mail delivery service (Brevo, Sendinblue SAS, France) only for delivering it.
• Hosting. The data is stored on the server that runs the site.
• Browser push services. Notifications are delivered by the service of your browser’s maker (Google for Chrome and Android, Mozilla for Firefox, Apple for Safari, Microsoft for Edge): it receives the encrypted notification, the time it was sent and the subscription address, and cannot read the text.
• The country is determined on our own server from the free DB-IP database (db-ip.com, CC BY 4.0); IP addresses are not sent anywhere.
• Otherwise we pass data to no one, except when required by law.

How long we keep it

• the account, favourites, game picks, divisions, leagues with friends and invites — until you delete the account;
• notification subscriptions — until you turn them off or the browser drops them; records of sent notifications — 14 days;
• the hash of a mailbox that used the trial — also after the account is deleted (otherwise the trial could be taken endlessly);
• sessions — until you sign out or for 60 days after the last visit;
• mail links — until used or expired (1 hour for a password reset, 3 days for confirming the e-mail), then deleted within a week;
• the visit memory in the browser — 13 months from the first visit; the active days of an account and the daily hashes of unique visitors — 400 days;
• which matches an account opened — up to two days; the system entries of the administrator log (limits, signs of automated requests) and translation error reports — 180 days; an administrator’s actions on an account — while the account exists, then without the e-mail and details;
• backup copies of the database — 14 days;
• visit statistics — only in aggregated, depersonalised form (counts per day, page, country, source, device, time and return visits).

Consent to the processing of personal data

By ticking «I consent to the processing of my personal data» at registration you freely and in your own interest give the controller named in «Who is responsible for the data» your consent to process your personal data — your e-mail, nickname, account, session and sign-in details (IP address, browser, country), your actions on the site and in the games, your notification settings — for the purposes listed in «Why». The consent covers collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (disclosure and access) to the e-mail service and the hosting, anonymisation, blocking, erasure and destruction, with or without automation. It is valid until the account is deleted; you can withdraw it by deleting the account in the profile or by writing to privacy@forepitch.com. After that the data are deleted except those listed in «How long we keep it».

Your rights

You can see your data in the profile, download a copy of it there as one file, and delete the account at any time: the account, its favourites, game picks and divisions, memberships of leagues with friends (a league you created passes to the member who joined first), the link to the friend who invited you and to those you invited, notification subscriptions, sessions and visit days are deleted at once; only the trial hash of the mailbox stays, the administrator log keeps that something was done without the e-mail and details, and a won prize place stays without the nickname. Deleting the account also withdraws your consent to processing. For any other request — to correct your data, to object to its processing — write to privacy@forepitch.com; we answer within 10 working days. You may also complain to the data protection authority of your country.

By country

• EU, EEA, UK, Switzerland (GDPR, UK GDPR, the Swiss data protection act): access, rectification, erasure, restriction, portability (the one-file copy in the profile), objection to processing based on legitimate interest, withdrawal of consent at any time without affecting earlier processing, a complaint to your country’s supervisory authority.
• Russia, Belarus, Kazakhstan, Uzbekistan, Ukraine and other CIS countries: information about the processing, updating, blocking or destruction of the data, withdrawal of consent, an appeal to the authorised body (in Russia — Roskomnadzor, in Belarus — the National Personal Data Protection Centre) or to a court.
• Brazil (LGPD): confirmation and access, correction, anonymisation, blocking or deletion, portability, information on whom the data are shared with, withdrawal of consent, a complaint to the ANPD.
• Mexico, Argentina, Colombia, Chile, Peru and other Latin American countries: the rights of access, rectification, cancellation and opposition (ARCO) and a complaint to the national data protection authority.
• Nigeria, South Africa, Kenya, Ghana, Egypt, Morocco, Tanzania and other African countries (NDPA, POPIA, the DPAs and others): access, correction, deletion, objection, portability where the law provides it, and a complaint to the national authority (for example the NDPC, the Information Regulator, the ODPC).

Security

The site works over HTTPS; passwords are stored only as scrypt hashes, session tokens and mail links only as hashes; access to the administration requires a second factor. Pages load scripts only from our own server and cannot be embedded in other sites; the database and its copies are readable by the server only.

If there is a breach

If a breach puts your rights at risk, we will tell the owners of the affected accounts by e-mail without delay and notify the data protection authority within the time the law requires (72 hours in the EU and the UK).

Age

The site is intended for adults (18+) and does not knowingly collect data of minors.

Changes

If this policy changes, the new version with its date appears on this page; about substantial changes we will notify account holders on the site.