Privacy Policy

Effective Date: 19 November 2024
Last Updated: 30 March 2025

PUNT LTD ("Punt", "we", "our", or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and share your personal data when you use the Punt mobile application (the “App”) and related services.

PUNT LTD is the data controller responsible for your personal data.

1. Information We Collect

We collect the following categories of personal data:

1.1 Information You Provide

  • Account Information: name, email address, username, password

  • Profile Information: profile image, bio, or other optional details

  • User Content: takes (predictions), interactions, and other in-app activity

  • Communications: messages sent to support or feedback submissions

1.2 Information Collected Automatically

  • Usage Data: features used, interactions, time spent, app activity

  • Device Information: IP address, device type, operating system, app version

  • Log Data: crash reports, diagnostics, performance data

1.3 Information from Third Parties

  • Analytics Providers: aggregated insights about app usage

  • Advertising Platforms: limited interaction data where applicable

  • Social Platforms: if you interact with Punt content externally

2. Legal Basis for Processing

Under UK GDPR and EU GDPR, we rely on the following legal bases:

  • Contract (Art. 6(1)(b))
    To provide and operate the App

  • Legitimate Interests (Art. 6(1)(f))
    To improve the App, prevent misuse, and understand user behaviour

  • Consent (Art. 6(1)(a))
    For marketing communications and certain tracking technologies

  • Legal Obligation (Art. 6(1)(c))
    To comply with applicable laws

3. How We Use Your Data

We use your personal data to:

  • Provide and operate the App

  • Enable core features (e.g. takes, leaderboards, fan profiles, following)

  • Personalise your experience

  • Analyse usage and improve performance

  • Communicate with you (support, updates)

  • Send marketing communications (where consent is given)

  • Detect and prevent fraud, abuse, or misuse

4. Social Features

Punt includes social features such as:

  • Public profiles

  • Leaderboards

  • Following other users

Information you choose to share (e.g. username, profile, activity) may be visible to other users.

5. Data Sharing

We do not sell your personal data.

We may share your data with:

5.1 Service Providers

Third-party providers that support our operations, including:

  • Cloud hosting

  • Analytics (e.g. Firebase)

  • Customer support tools

These providers process data on our behalf under contractual safeguards.

5.2 Legal and Regulatory Authorities

Where required by law or to protect rights, safety, or security

5.3 Business Transfers

In connection with a merger, acquisition, or sale of assets

We do not allow third parties to use your personal data for their own marketing purposes without your consent.

6. International Data Transfers

Your data may be transferred outside the UK/EEA.

Where this occurs, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs)

  • Transfers to countries with adequacy decisions

7. Data Retention

We retain personal data only for as long as necessary to:

  • Provide the App

  • Comply with legal obligations

  • Resolve disputes

  • Enforce our agreements

You can request deletion of your account at any time.

8. Your Rights

You have the following rights under GDPR:

  • Access your personal data

  • Correct inaccurate data

  • Delete your data

  • Restrict processing

  • Object to processing

  • Data portability

  • Withdraw consent at any time

To exercise your rights, contact: hello@wearepunt.com

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Keep you logged in

  • Understand usage

  • Improve performance

Where required, we request your consent before using non-essential cookies or tracking.

10. Marketing Communications

We will only send marketing communications where you have given consent.

You can opt out at any time by:

  • Clicking “unsubscribe” in emails

  • Adjusting your app settings

11. Children’s Privacy

Punt is not intended for users under 13 years of age (or higher where required by local law).

We do not knowingly collect personal data from children. If we become aware that we have collected such data, we will delete it.

12. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

  • Encryption

  • Access controls

  • Secure infrastructure

However, no system is completely secure.

13. Third-Party Links

The App may contain links to third-party services. We are not responsible for their privacy practices.

14. Changes to This Policy

We may update this Privacy Policy from time to time.

Where changes are significant, we will notify you via:

  • The App

  • Email (where appropriate)

15. Contact

PUNT LTD
Data Protection Contact: hello@wearepunt.com