LEGAL

Privacy Policy

Effective date: 25 July 2026 · Applies to football-english.pages.dev and the "Gaffer PRO" Android app (TWA)

📋 Plain-language summary (not a substitute for the full text below)

1. Who is responsible for your data (Data Controller)

Álvaro Gómez Gómez, an individual based in Casarabonela (Málaga), Spain, is the data controller (responsable del tratamiento) for the personal data processed through this website and application, operated as a personal, small-scale project (not a registered company).

Contact for any privacy matter: alvaroggcasarabonela@gmail.com

Given the limited scale and nature of the processing carried out, the appointment of a Data Protection Officer (DPO) is not mandatory under Article 37 of Regulation (EU) 2016/679 (GDPR).

2. What personal data we collect

2.1 If you create an account with email and password

2.2 If you sign in with Google

2.3 Gameplay and progress data

2.4 Session and security data

2.5 "The Gaffer" AI chat

If you use the AI tutor chat feature (PRO), the text of your message is sent to our backend and forwarded, in real time, to DeepSeek (a third-party AI provider) purely to generate a reply. We do not store the content of your chat messages on our own servers. DeepSeek's own retention practices apply to the message once it reaches their systems — see Section 4 below regarding this international transfer.

AI transparency notice (EU AI Act, Art. 50): The Gaffer is an artificial intelligence system, not a human coach. This is stated directly in the chat window header ("The Gaffer (AI Tutor)") and in its own opening message, and it is instructed to confirm this plainly if you ask it directly.

2.6 Payment data

PRO access is purchased through a Stripe Payment Link. Card numbers, billing details and payment credentials are entered directly on Stripe's own secure page and are never received, seen, or stored by us. We only receive a payment confirmation and a one-time session identifier, used exclusively to generate your PRO access code.

3. Purposes and legal basis for processing

PurposeLegal basis (Art. 6 GDPR)
Creating and managing your account, keeping you logged in, syncing your progressPerformance of a contract (Art. 6.1.b) — necessary to provide the service you requested
Google Sign-In authenticationPerformance of a contract (Art. 6.1.b), initiated by your own action
Providing the AI tutor chat to PRO usersPerformance of a contract (Art. 6.1.b) — a feature you actively choose to use
Processing PRO payments (via Stripe)Performance of a contract (Art. 6.1.b)
Sending password-reset emails (via Resend)Performance of a contract (Art. 6.1.b) — a feature you actively trigger to regain access to your own account
Rate-limiting by IP/device, brute-force login protection, fraud prevention on PRO codes, session securityLegitimate interest (Art. 6.1.f) — keeping the service available and free from abuse

4. Who we share data with — international transfers

Some lessons' code supports embedding a YouTube video instead of a direct video file, though no lesson currently published uses this. If this is enabled in the future, YouTube (operated by Google LLC) would set its own cookies directly in your browser under its own policies, independently of this site, and we will update this policy before turning it on.

We do not sell your data, and we do not use advertising or analytics networks of any kind.

5. How long we keep your data

6. Cookies

This site uses only strictly necessary / technical cookies, exempt from prior consent under Article 22.2 of the Spanish LSSI-CE (E-Commerce Act) and Recital 66 of Directive 2002/58/EC (ePrivacy):

CookiePurposeDuration
sessionKeeps you signed in (HttpOnly, Secure)30 days
oauth_statePrevents forgery during Google Sign-In (HttpOnly, Secure)10 minutes

We do not use advertising, analytics, or third-party tracking cookies, so no cookie-consent banner is required. Your device identifier and offline progress are stored in localStorage, not in cookies, and never leave your browser unless you create an account.

7. Children's privacy

Under Article 7 of Spanish Organic Law 3/2018 (LOPDGDD), a minor may only consent to data processing from the age of 14 onward; below that age, parental or guardian consent is required. This service is not knowingly directed at, or intended for, children under 14, and we do not knowingly collect personal data from them without such consent. If you believe a child under 14 has created an account or provided us data without appropriate consent, please contact us using the details in Section 1 or the form in Section 8, and we will delete it.

8. Your rights, and how to exercise them ("protest" / objection channel)

Under Articles 15 to 22 of the GDPR and the LOPDGDD, you have the right to:

This service does not carry out automated decision-making or profiling producing legal or similarly significant effects on you (Art. 22 GDPR) — your XP/rank is simple, non-automated gamification with no consequences outside the app.

Delete your account right now

If you're currently signed in on this device, you can permanently delete your account and all associated data (progress, completed lessons, sessions) immediately, with no need to wait for a manual request.

Submit a request or objection

Fill in the form below to exercise any of the above rights, or to raise an objection or complaint directly with us. It will open your email client with a pre-filled message addressed to us — review it and hit send. We will respond within one month (extendable by two further months for complex requests, as permitted by Art. 12.3 GDPR), free of charge for the first request in any given period.

This form does not send data anywhere by itself — it only prepares an email in your own mail app. If you prefer, you can also write directly to alvaroggcasarabonela@gmail.com, or lodge a complaint with the AEPD at any time.

9. Security measures

10. Changes to this policy

We may update this policy as the app evolves. The "Effective date" at the top will reflect the date of the latest revision. If changes are significant, we will make reasonable efforts to highlight them on the site.

11. Contact

For any question about this policy or your data: alvaroggcasarabonela@gmail.com