Privacy Policy
Last updated: August 10, 2026. Privacy contact: [email protected] · Support: [email protected].
This Policy explains how Refoot processes personal data on its website, game and Android app, in compliance with the Brazilian General Data Protection Law — LGPD (Law No. 13,709/2018) and other applicable rules.
1. Controller and data protection officer
The data controller is Moisés Silvano, the developer responsible for Refoot (refoot.io). The controller also acts as the data protection officer (DPO) under Article 41 of the LGPD and can be reached through the dedicated channel [email protected].
2. Data we process
- Account and identity: account identifier, email and basic data made available by Google or Discord when you choose one of these sign-in methods. With email and password sign-in, authentication is managed by Supabase; Refoot never receives your password in readable form.
- Date of birth: collected once to confirm the minimum age (14+ rating). Never shown to other players.
- Profile and game: display and club names, squad, progress, virtual currency and items, rewards, stats, matches, ranking, events, achievements, friends, invites and content you save in the game.
- Consent records: we keep the date, origin and document version whenever you accept the Terms or make a cookie choice — the proof required by the LGPD.
- Technical and security data: IP address, session identifiers, browser, operating system and device type, plus access, error, disconnection, reconnection and network quality logs and actions needed to prevent fraud, abuse and cheating.
- Approximate country: the game may infer a starting nation from the language and time zone supplied by the device. We do not access GPS for this purpose.
- Usage and Analytics: if you accept optional cookies, Google Analytics receives information about pages, screens, menus and interactions, together with technical data generated by the service.
- Purchases: for web checkout we receive the transaction identifier and status, product, amount and payer email. We do not receive the full card number or banking credentials.
3. Purposes and legal bases
We use the data for the purposes below, each supported by an LGPD legal basis (Article 7). We do not sell personal data.
| Purpose | Legal basis |
|---|---|
| Creating and authenticating the account, saving and syncing progress, operating matches, ranking, events, rewards, friends, store and support | Performance of a contract (Art. 7, V) |
| Processing and proving purchases; keeping transaction records | Performance of a contract and compliance with legal/tax obligations (Art. 7, II and V) |
| Preventing fraud, cheating and abuse; protecting accounts and servers; technical and security logs | Legitimate interest (Art. 7, IX) and, for payments, fraud prevention |
| Confirming the minimum age (date of birth) | Legal obligation and protection of teenagers (Arts. 7, II, and 14) |
| Usage metrics (Google Analytics) | Consent (Art. 7, I) — revocable at any time in Settings |
| Push notifications | Consent — you enable and disable whenever you want |
4. Cookies, local storage and Analytics
Essential cookies and local storage keep your session, language, preferences, local progress, app cache and update controls. Google Analytics is optional and analytics storage remains denied until you choose “Accept all.” You may choose “Essential only” and continue using the game, or change your choice in Settings. In the installed app, Google Analytics is not loaded. We do not use this data for behavioral advertising.
5. Processors and sharing
We share only the data needed with service providers (processors) that make the service possible:
- Supabase: authentication, database and progress storage;
- Google and Discord: sign-in, when chosen by the user;
- Google Analytics: usage metrics, only after consent and only on the website;
- Google (Firebase Cloud Messaging, Play Billing and Play Games): app notifications, Google Play digital purchases and achievements when you use the Android app;
- Cloudflare: site delivery, network protection and abuse prevention;
- hCaptcha (Intuition Machines) or Cloudflare Turnstile: anti-bot verification at sign-in and sign-up;
- Mercado Pago: processing of website purchases (receives the payer email and transaction identifier);
- Fly.io: hosting of the game servers and APIs (technical logs);
- AI providers (DeepSeek and PIAPI): used only in internal administration and content-creation tools. We do not send player data to these providers as part of how the game works.
We may also disclose data when legally required or needed to protect users, Refoot or third parties.
6. Android app, purchases and ads
Website purchases are processed by Mercado Pago. Digital goods in the Android version distributed through Google Play follow the applicable Google Play rules and billing system. The version covered by this Policy does not display ads or behavioral advertising. If ads are added in the future, this Policy and the Data safety declaration will be updated before that version is released.
7. International transfers and security
Some processors process or store data outside Brazil (for example Supabase, Google, Cloudflare, hCaptcha and Fly.io, with infrastructure in the United States and other countries). These transfers rely on the safeguards of Article 33 of the LGPD — in particular contractual clauses ensuring an equivalent level of protection, such as the standard clauses adopted by those providers. We use encrypted transmission, restricted access controls and abuse-prevention measures. No system, however, is completely immune from incidents; in the event of a relevant security incident we will notify data subjects and the ANPD as required by Article 48.
8. Retention and deletion
Account and game data are kept while the account exists. Specific periods:
- access (presence) logs: up to 60 days;
- technical match telemetry: up to 30 days;
- feedback and reports: up to 12 months;
- transaction records: kept, anonymized after account deletion, for the period required by legal and tax obligations (generally 5 years);
- inactive anonymous accounts: deleted after 6 months without use;
- proof of consent: while the account exists.
When you delete your account we remove the identity and associated cloud data — including notification subscriptions, linked telemetry and submitted feedback — except for the anonymized records above. Residual backup copies may remain until secure backup rotation.
Delete your account in-game at Settings → Manage account → Danger zone → Delete account (double confirmation). Outside the app, request deletion at [email protected] using the address linked to your account, or see the step-by-step guide at refoot.io/delete-account. Deletion is permanent and is not merely account deactivation.
9. Your rights
Under Article 18 of the LGPD, you may request confirmation and access, correction, portability, information about sharing, anonymization, blocking or deletion of unnecessary data, withdrawal of consent and review of automated decisions. In-game, Settings → Manage account → Download my data generates a file with your account data (portability). For other requests, write to [email protected]. We may verify your identity first and will respond within the timeframes of the LGPD. You may also lodge a complaint with the Brazilian data protection authority (ANPD).
10. Children and teenagers
Refoot is rated 14+ and is not directed to children under that age. We confirm the minimum age through the date of birth at first access. Processing of teenagers' data follows the best-interest standard of Article 14 of the LGPD and the Brazilian Child and Adolescent Statute; teenagers should make purchases with guardian involvement where required by applicable law. If you believe a child improperly provided personal data, contact [email protected] so we can remove it.
11. Changes and contact
We may update this Policy as the game and its providers evolve. The effective version date appears at the top; material changes require a new in-game acceptance. Privacy questions or requests: [email protected].