3. Privacy Policy

Effective Date: May 15, 2026 Last Updated: May 15, 2026 

3.1 Introduction

TOMODEV ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share information when you use AI Football Predictions (the "App"). By using the App, you agree to the collection and use of information as described in this Privacy Policy.

This Privacy Policy is designed to comply with:

• Google Play Developer Program Policies

• Apple App Store Review Guidelines

• General Data Protection Regulation (GDPR)

• California Consumer Privacy Act (CCPA)

• Vietnam's Law on Cybersecurity and Personal Data Protection

3.2 Information We Collect

We may collect the following categories of information:

a) Information You Provide Directly

• Account registration details such as name and email address (if account features are available).

• User preferences, selected teams, leagues, and favorite match settings.

• Feedback or messages submitted to our support team.

b) Information Collected Automatically

• Device information: Device model, operating system version, unique device identifiers (e.g., Android ID), and mobile network information.

• Usage data: App features accessed, match predictions viewed, session duration, tap interactions, and in-app navigation patterns.

• Performance data: Crash reports, error logs, and app load times.

• Log data: IP address, access timestamps, and general location (country/region level).

c) Information from Third-Party Services

• Google Firebase: Used for backend infrastructure, real-time database, user authentication, and crash diagnostics via Firebase Crashlytics.

• Firebase Analytics / Google Analytics: Collects anonymized, aggregated usage data to help us understand how users engage with AI Football Predictions and to improve features and performance.

• Google AdMob: Collects device and usage information, including advertising identifiers, to deliver relevant advertisements within the App.

3.3 How We Use Your Information

We use the information we collect to:

1. Provide and operate the core features of AI Football Predictions, including AI-generated match predictions and football analytics.

2. Personalize your in-app experience (e.g., favorite teams, leagues, and prediction preferences).

3. Display advertisements via Google AdMob.

4. Monitor and improve App performance, fix technical issues, and prevent fraud or abuse.

5. Conduct anonymized analytics to understand usage trends and improve the App.

6. Respond to user support inquiries.

7. Comply with applicable legal obligations and enforce our Terms of Service.

8. Send important App-related notifications (e.g., policy updates, new features) where applicable.

3.4 AI Features & Data Processing

AI Football Predictions uses AI models to analyze football data and generate predictions and insights. When you use these features:

• Your in-app inputs (e.g., selected matches, preferred leagues) are processed to generate relevant AI predictions.

• We do not use your personal data to train AI models without your explicit consent.

• AI processing may be performed locally on your device or via secure, encrypted cloud-based services, depending on the feature.

• AI-generated predictions are based on historical match data, team statistics, and algorithmic analysis — they are not guaranteed outcomes.

• We take reasonable technical measures to ensure data transmitted for AI processing is handled securely.

3.5 Permissions We Request

AI Football Predictions may request the following device permissions to deliver core functionality:

Internet Access: Required for AI prediction features, live data updates, ads, and cloud services

Notifications: To send match alerts, prediction updates, and relevant in-app notifications

Advertising ID: Used by Google AdMob for ad personalization (can be opted out)

We request only the permissions strictly necessary for the App's functionality. You may manage or revoke permissions at any time through your device settings.

3.6 Data Sharing & Disclosure

We do not sell your personal data to third parties. We may share your information only in the following limited circumstances:

• Service Providers: With trusted third-party partners (e.g., Firebase, Google AdMob) who assist us in operating the App. These parties are contractually obligated to protect your data and may not use it for their own purposes beyond what is necessary to provide their services.

• Legal Compliance: If required by law, court order, or a governmental authority.

• Business Transfers: In the event of a merger, acquisition, or sale of TOMODEV's assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.

• Safety: To protect the rights, safety, or property of TOMODEV, our users, or the public.

3.7 Advertising & Google AdMob

We use Google AdMob to display advertisements within AI Football Predictions. AdMob may collect and use your device's advertising ID and other technical signals to serve personalized or non-personalized ads.

• Opt out of personalized ads on Android: Settings → Google → Ads → Opt out of Ads Personalization.

• Opt out of personalized ads on iOS: Settings → Privacy & Security → Tracking → disable tracking for AI Football Predictions.

• For more information on how Google uses data for advertising, visit Google's Privacy & Terms.

3.8 Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law:

• Analytics and usage data are retained for up to 24 months.

• Support communications are retained for up to 12 months after resolution.

• Account data is retained until account deletion is requested.

• You may request deletion of your data at any time by contacting us (see Section 3.10).

3.9 Data Security

We implement industry-standard technical and organizational measures to safeguard your information, including:

• Encryption of data in transit using TLS/SSL protocols.

• Secure cloud infrastructure powered by Google Firebase.

• Strict internal access controls limiting who can access user data.

• Regular security reviews and monitoring.

However, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security, and you use the App at your own risk.

3.10 Your Rights & Choices

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.

• Correction: Request correction of inaccurate or incomplete information.

• Deletion: Request that we delete your personal data ("Right to be Forgotten").

• Portability: Request a copy of your data in a portable, machine-readable format.

• Objection: Object to certain types of data processing.

• Withdraw Consent: Withdraw consent at any time where processing is based on your consent.

To exercise any of these rights, please contact us at support@tomodev.vn. We will respond within 10 business days.

3.11 Children's Privacy

AI Football Predictions is not directed at children under the age of 13 (or the applicable minimum age in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal information without appropriate parental consent, we will delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately at support@tomodev.vn.

3.12 Third-Party Links & Services

The App may reference or link to third-party websites, sports data providers, or external resources. TOMODEV is not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party services you access.

3.13 International Data Transfers

Your information may be processed or stored on servers located outside of your home country, including in the United States (via Google Firebase and AdMob infrastructure). By using AI Football Predictions, you consent to the transfer of your information to countries that may have different data protection laws than your jurisdiction. We take reasonable steps to ensure your data is protected in accordance with this Privacy Policy.

3.14 Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or service updates. When we make changes, we will:

• Update the "Last Updated" date at the top of this page.

• Notify users through an in-app notice or other appropriate communication where required by law.

Continued use of AI Football Predictions after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

3.15 AI and Automated Processing

Certain App features use automated systems and AI-based processing to generate football predictions, confidence scores, trend analysis, and statistical visualizations.

These systems process football-related datasets, usage signals, and interaction data to improve prediction quality and user experience.

3.16 Data Safety & Consistency

We strive to ensure consistency between this Privacy Policy, our Google Play Data Safety disclosures, and the actual behavior of the App.

Data collection and processing practices may vary depending on device type, enabled permissions, subscription features, country, and third-party service integrations.

3.17 Contact Us

If you have any questions, concerns, or data-related requests regarding this Privacy Policy, please contact us:

• Email: support@tomodev.vn

• Website: tomodev.vn

• Company: TOMODEV

• Response Time: We aim to respond to all privacy inquiries within 10 business days.