Privacy Policy

Last Updated: November 26, 2025

Data Controller: Cross Solutions LLC

1. Introduction

Welcome to Proply ("we," "our," or "us"). We are committed to protecting your privacy and ensuring transparency about how we collect, use, and protect your information. This Privacy Policy explains our practices regarding data collection and use when you use the Proply mobile application (the "App").

By using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Information Collected Automatically

When you use the App, we automatically collect certain information, including:

Device Information:

• Device type (iPhone, iPad, Android device)
• Operating system version (iOS, Android)
• Device identifiers (such as device ID)
• App version and build number
• Language and region settings

Usage Information:

• Features and screens you access within the App
• Time spent in the App
• Subscription status and purchase history
• App performance and crash reports (if applicable)

Network Information:

• IP address (may be collected by our service providers)
• Network connection type

2.2 Subscription and Payment Information

When you subscribe to Pro Membership, the following information is collected:

By Apple (App Store):

• Apple ID
• Payment method information
• Purchase history
• Subscription status

By RevenueCat:

• Subscription status and entitlements
• Purchase transactions
• Subscription renewal dates
• Device identifiers linked to your subscription

Note: We do not directly collect or store your payment information. All payment processing is handled by Apple through the App Store, and subscription management is handled by RevenueCat. We only receive information about your subscription status to provide you with access to premium features. We do not collect email addresses or require user accounts - the App is device-based only.

2.3 Information We Do NOT Collect

We do not collect:

• Email addresses (unless you contact us directly)
• Names or personal identification information
• Location data (GPS coordinates)
• Contacts or address book information
• Photos or media files
• Biometric data

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision

• To provide and maintain the App and its features
• To manage your Pro Membership subscription
• To deliver sports data, predictions, and analytics
• To authenticate your subscription status and grant access to premium features

3.2 App Improvement

• To understand how users interact with the App
• To identify and fix bugs or technical issues
• To improve App performance and user experience
• To develop new features and functionality

3.3 Communication

• To send you important updates about the App (if applicable)
• To respond to your support requests or inquiries
• To notify you about changes to our Terms of Use or Privacy Policy

3.4 Legal Compliance

• To comply with applicable laws and regulations
• To respond to legal requests or court orders
• To protect our rights and prevent fraud or abuse

4. Third-Party Services and Data Sharing

We share information with the following third-party service providers:

4.1 RevenueCat

Purpose: Subscription management and payment processing

Data Shared:

• Device identifiers
• Subscription status
• Purchase transactions
• App identifiers

Privacy Policy: https://www.revenuecat.com/privacy

RevenueCat helps us manage your Pro Membership subscription and verify your access to premium features. They do not have access to your payment information, which is handled exclusively by Apple.

4.2 Apple (App Store)

Purpose: Payment processing and subscription management

Data Shared:

• Subscription purchase requests
• App usage data (for App Store analytics)

Privacy Policy: https://www.apple.com/privacy/

All payments are processed through Apple's secure payment system. We do not have access to your payment method details or full Apple ID information.

4.3 Sports Data Providers

Purpose: Providing game information, statistics, and player data

Data Shared:

• API requests for sports data (may include device identifiers)
• Sport preferences and search queries

We work with third-party sports data providers to deliver game information, player statistics, and other sports-related content. These providers may collect technical information such as IP addresses and device identifiers.

4.4 Analytics Services

We do not currently use third-party analytics services. If we add analytics services in the future, we will update this Privacy Policy to reflect those changes.

4.5 Legal Requirements

We may disclose your information if required by law or in response to:

• Court orders or legal processes
• Government requests
• Law enforcement investigations
• Protection of our rights or the rights of others

4.6 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change in ownership.

5. Data Storage and Security

5.1 Data Storage

• Local Storage: Some data (such as cached sports data and preferences) is stored locally on your device
• Third-Party Storage: Subscription and usage data is stored by RevenueCat and Apple on their secure servers
• Our Servers: We do not store user data on our own servers. All subscription and user data is managed by RevenueCat and Apple.

5.2 Data Retention

• Subscription Data: Retained by RevenueCat and Apple for as long as your subscription is active and for a reasonable period thereafter for business and legal purposes
• Usage Data: Retained for analytics and improvement purposes, typically for up to 12 months
• Cached Data: Stored locally on your device and can be cleared by uninstalling the App

5.3 Security Measures

We implement appropriate technical and organizational measures to protect your information, including:

• Secure data transmission (HTTPS)
• Limited access to personal information
• Regular security assessments
• Compliance with industry security standards

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Your Rights and Choices

6.1 Access and Correction

You have the right to:

• Request access to the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your information (subject to legal and contractual obligations)

To exercise these rights, please contact us at getproply@gmail.com.

6.2 Subscription Management

You can manage your subscription at any time through:

• iOS: Settings > [Your Name] > Subscriptions > Proply
• Android: Google Play Store > Subscriptions

Canceling your subscription will stop future charges but will not automatically delete your data.

6.3 Data Deletion

To request deletion of your data:

1. Cancel your subscription (if applicable)
2. Uninstall the App from your device
3. Contact us at getproply@gmail.com to request deletion of any data stored on our servers

Note: Some information may be retained for legal or business purposes, such as:

• Transaction records (required for accounting)
• Information required to comply with legal obligations
• Anonymized usage data for analytics

6.4 Opt-Out Options

• Push Notifications: You can disable push notifications in your device settings (if applicable)
• Subscription: You can cancel your subscription at any time through your device's subscription settings

7. Children's Privacy

Proply is not intended for users under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country.

By using the App, you consent to the transfer of your information to:

• United States: Where our service providers (RevenueCat, Apple) are located
• Other jurisdictions: Where our sports data providers operate

We take appropriate measures to ensure your information receives adequate protection in accordance with this Privacy Policy.

9. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You can request information about the categories and specific pieces of personal information we collect
• Right to Delete: You can request deletion of your personal information
• Right to Opt-Out: You can opt-out of the sale of personal information (we do not sell personal information)
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights

To exercise these rights, please contact us at getproply@gmail.com.

10. European Privacy Rights (GDPR)

While Proply is primarily designed for users in the United States, if you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

• Right of Access: You can request a copy of your personal data
• Right to Rectification: You can request correction of inaccurate data
• Right to Erasure: You can request deletion of your data ("right to be forgotten")
• Right to Restrict Processing: You can request limitation of data processing
• Right to Data Portability: You can request your data in a portable format
• Right to Object: You can object to certain types of data processing

To exercise these rights, please contact us at getproply@gmail.com.

Legal Basis for Processing: We process your data based on:

• Contractual necessity: To provide the App and subscription services
• Legitimate interests: To improve the App and prevent fraud
• Legal obligations: To comply with applicable laws

11. Cookies and Tracking Technologies

The App does not use cookies. Our website (getproply.com) does not currently use cookies or tracking technologies, and we do not collect data through our website. If this changes in the future, we will update this Privacy Policy accordingly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Updating the "Last Updated" date at the top of this Privacy Policy
• Posting a notice in the App (if significant changes occur)

Your continued use of the App after such changes constitutes your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: getproply@gmail.com

Website: https://getproply.com