PRIVACY POLICY
Last updated: March 2026
1. Introduction
Welcome to Panenka Football Manager ("Panenka", "we", "us", or "our"). Panenka Football Manager is a free-to-play, browser-based multiplayer football manager game available at www.panenkafm.com. We are committed to protecting your personal data and your right to privacy.
This Privacy Policy explains what information we collect when you use our website and game, why we collect it, how we use it, and your rights regarding that information. It applies to all users of www.panenkafm.com and any related services we provide.
By creating an account or using Panenka Football Manager, you acknowledge that you have read and understood this Privacy Policy.
2. Who We Are (Data Controller)
Panenka Football Manager is operated within the European Union. For the purposes of the General Data Protection Regulation (GDPR) and applicable data protection law, the operator of Panenka Football Manager is the data controller responsible for your personal data.
If you have any questions about this policy or our data practices, you can contact us at:
• Website: www.panenkafm.com
• Email: info@panenkafm.com
3. What Personal Data We Collect
3.1 Account Registration Data
When you create an account, we collect:
• Username (display name)
• Email address
• Password (stored in hashed/encrypted form - we never store plain-text passwords)
• Date of account creation
3.2 Gameplay & Activity Data
As you play Panenka Football Manager, we collect data related to your in-game activity, including:
• Team name, formation choices, and tactical decisions
• Match results, league standings, and division history
• In-game currency balances and transactions
• Player cards collected, packs opened, and squad management actions
• Login timestamps and session duration
3.3 Technical & Device Data
We automatically collect certain technical data when you access our platform:
• IP address
• Browser type and version
• Operating system
• Device type (desktop, mobile, tablet)
• Pages visited and interactions within the game interface
• Referring URL
3.4 Communications Data
If you contact us directly (e.g., for support, via email, or through in-game feedback forms),
we collect:
• Your name and email address
• The content of your message
• Any attachments or screenshots you provide
3.5 Data We Do NOT Collect
We do not collect or process:
• Payment or financial information (Panenka Football Manager is free to play with no
paid transactions at this time)
• Government-issued ID or sensitive personal data
• Precise geolocation data
4. Legal Basis for Processing (GDPR)
We process your personal data on the following legal grounds under the GDPR:
Performance of a contract: To create and manage your account, and to provide the game service you have signed up for.
Legitimate interests: To improve our game, detect fraud, ensure security, and analyse how users interact with our platform - provided these interests are not overridden by your rights.
Consent: Where we send marketing communications or use non-essential cookies, we rely on your explicit consent, which you can withdraw at any time.
Legal obligation: Where we are required to retain or process data to comply with applicable EU law.
5. How We Use Your Data
We use the data we collect for the following purposes:
• To create and maintain your Panenka Football Manager account
• To provide the game service, including matchdays, league progression, and pack rewards
• To personalise your experience and remember your preferences
• To send transactional emails (e.g., account verification, password reset)
• To send game-related updates and news (with your consent)
• To analyse gameplay patterns and improve game balance, features, and
performance
• To detect, investigate, and prevent cheating, fraud, or abuse
• To respond to support requests and user feedbackTo comply with legal obligations
6. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to operate and improve our service. Cookies are small text files stored on your device
6.1 Types of Cookies We Use
Essential cookies: Required for the game to function (e.g., session authentication, login state). These cannot be disabled.
Analytics cookies: Help us understand how users navigate and use the game (e.g., via Google Analytics or a self-hosted analytics solution). Used with your consent.
Preference cookies: Remember your in-game settings and UI preferences.
6.2 Managing Cookies
You can control and manage cookies through your browser settings. Note that disabling essential cookies may prevent you from logging in or using the game. For analytics and non-essential cookies, you can withdraw your
consent at any time through our cookie settings.
7. Data Sharing and Third Parties
We do not sell your personal data to any third party. We may share data only in the following limited circumstances:
Service providers: Trusted third-party providers who assist in operating our platform (e.g., hosting providers, email delivery services, analytics tools). These providers are contractually bound to process data only on our instructions and in compliance with GDPR.
Legal requirements: We may disclose data if required by law, court order, or to protect the rights, property, or safety of Panenka Football Manager, its users, or others.
Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction. We will notify you in advance.
Any third-party processors we use are located within the European Economic Area (EEA) or, where they are outside the EEA, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses).
8. Data Retention
We retain your personal data only as long as necessary for the purposes described in this policy:
Active account data is retained for as long as your account exists.
If you request account deletion, we will delete your personal data within 30 days, except where we are required to retain it for legal or compliance reasons.
Anonymised, aggregated gameplay statistics may be retained indefinitely for game development and balancing purposes.
Server and access logs are typically retained for 90 days.
9. Your Rights Under GDPR
As a resident of the EU/EEA, you have the following rights regarding your personal data:
Right of access: Request a copy of the personal data we hold about you.
Right to rectification: Request that we correct inaccurate or incomplete data.
Right to erasure: Request deletion of your data ('right to be forgotten'), subject to legal obligations.
Right to restriction: Ask us to limit how we process your data in certain circumstances.
Right to data portability: Receive your data in a structured, machine-readable format.
Right to object: Object to processing based on legitimate interests or for direct marketing purposes.
Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at info@panenkafm.com. We will respond within 30 days. If you are unsatisfied with our response, you have the right to lodge a complaint with your national Data Protection Authority.
10. Children's Privacy
Panenka Football Manager is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, please contact us immediately at info@panenkafm.com and we will take steps to delete such information.
Users aged 13 to 15 should have the consent of a parent or legal guardian before registering.
11. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction. These include:
Encrypted password storage (hashed with a secure algorithm)
HTTPS/TLS encryption for all data in transit
Access controls limiting who within our team can access personal data
Regular security reviews and monitoring
While we take data security seriously, no online service can guarantee absolute security. In the unlikely event of a data breach that poses a risk to your rights, we will notify you and the relevant authorities as required by law within 72 hours.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you via email or a prominent notice on the game interface.
The date at the top of this policy indicates when it was last revised. We encourage you to review this policy periodically.
13. Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us:
Panenka Football Manager
• Website: www.panenkafm.com
• Email: info@panenkafm.com
You also have the right to contact your national Data Protection Authority within the EU/EEA.
© 2026 Panenka Football Manager | www.panenkafm.com
