{
 "schema_name": "page",
 "schema_version": "2.0",
 "page_type": "privacy",
 "url": "/privacy/",
 "canonical": "/privacy/",
 "language": "en",
 "hreflang": [],
 "translations": [],
 "heading": "Privacy notice",
 "description": "What personal data Forecast Record processes about the people whose public forecasts it measures and about visitors, why and on what legal basis.",
 "first_paragraph": {
  "body": "Forecast Record is the controller of the personal data on this site; it publishes under this name from Estonia. This notice says what we process about the people whose public forecasts we measure and about visitors, why, for how long, and how to object, ask for erasure or complain (version 0.9, 7 November 2026).",
  "key_number": "0.9",
  "data": "2026-11-07",
  "source_info": "this notice",
  "brand": "Forecast Record"
 },
 "indexable": true,
 "noindex_reason": null,
 "indexing_threshold": {
  "settled_count": 0,
  "date_count": 0,
  "required_settled": 0,
  "required_dates": 0
 },
 "data_date": "2026-11-07T19:52:23.438Z",
 "built_at": "2026-11-07T19:52:23.438Z",
 "lastmod": "2026-11-07T07:23:48.684Z",
 "content_hash": null,
 "meaning_hash": "453f78f5e6130ca27103df3814ad4123e4ed51d746bf2443498c078fb4504f6b",
 "dependency_group": "static",
 "release_id": "20261107-195223",
 "markup": [
  {
   "type_code": "WebPage",
   "allowed": true,
   "cause": null
  },
  {
   "type_code": "Organization",
   "allowed": true,
   "cause": null
  }
 ],
 "exports": [
  {
   "type_code": "json",
   "url": "/privacy/index.json",
   "bytes": null
  }
 ],
 "modules": {
  "affiliate": false,
  "api": true,
  "compare_yourself": false
 },
 "affiliate_block": null,
 "restrictions": {
  "name_withdrawn": false,
  "tracker_number": null,
  "withdrawn_quotes": [],
  "removed_at": null,
  "cause": null,
  "suspended_records": [],
  "withdrawal_log_number": 0
 },
 "page_links": {
  "methodology": "/methodology/",
  "right_of_reply": "/right-of-reply/",
  "source_coverage": "/coverage/",
  "corrections_log": "/corrections/",
  "api": "/api/",
  "claim": "/claim/"
 },
 "text_blocks": [
  {
   "heading": "About this notice",
   "anchor_id": "about",
   "revision": "0.9",
   "valid_from": "2026-10-09",
   "valid_until": null,
   "body": "This notice explains what personal data Forecast Record processes, why, on what legal basis, for how long and what you can do about it. It covers two groups of people: those whose public football forecasts we record and measure, and visitors who read this site or write to us."
  },
  {
   "heading": "If we measure your forecasts: what we hold",
   "anchor_id": "what",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "What we hold about a person whose forecasts we record:\n\n- the name or handle under which you publish, and the public channels where you publish (a website, an X account, a YouTube channel, a podcast feed);\n- the forecasts you published: the text, or a short excerpt of a transcript, that contains them, with the address and the time of publication;\n- when we first recorded each forecast, and whether it was recorded before kick-off, restored from a pre-match archive or found after the match;\n- the results and numbers we compute from your forecasts, and how they changed over time;\n- your responses, corrections and requests, if you send any.\n\nWhat we do not collect: private messages, anything behind a login or a paywall, contact details found on the pages we read (they are removed before anything is published), and anything about your private life.\n\nPodcast episodes are transcribed to find the forecasts in them, and the transcription separates speakers within an episode. In a test in September 2026 we created voice templates for 11 podcast participants to recognise them across episodes. Recognition across episodes is switched off; the templates from that test are stored encrypted and are not used for new records."
  },
  {
   "heading": "Where the data comes from",
   "anchor_id": "sources",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "Only from publicly accessible sources: the pages, feeds, videos and podcast episodes that you or your publisher made public, and earlier copies of those pages kept by public web archives such as the Internet Archive. Market prices and official match results come from sports data providers and contain no personal data about you."
  },
  {
   "heading": "Why we process it, and on what legal basis",
   "anchor_id": "basis",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "Purpose. To publish an independent, checkable record of public football forecasts — what was said before a match against what happened — so that readers can judge the tipsters and sources who publish to them.\n\nLegitimate interests (Article 6(1)(f) GDPR). The public interest in being able to check forecasts that are published to the public, often next to links to betting operators, and our interest in publishing that record. We weighed it against your interests and limited what we do accordingly:\n\n- we use only what you published to the public, under the name and in the role in which you published it;\n- we measure published forecasts; we do not describe or judge the person;\n- every number links to its evidence and to the rules it was computed by;\n- a profile stays out of search engines until enough of its record can be checked;\n- a forecast whose author is uncertain is kept out of personal totals until the attribution is checked;\n- you can respond, correct, object and ask for erasure, and each request is decided by a person.\n\nJournalistic purposes. Our editorial work — checking who made a forecast, separating what was recorded before kick-off from what was found later, publishing corrections and responses — is also processing for journalistic purposes under § 4 of the Estonian Personal Data Protection Act (Isikuandmete kaitse seadus). It allows such processing without consent where there is a public interest, it is in line with the principles of journalistic ethics and it does not excessively harm the rights of the person concerned. We rely on it only as far as our pages actually meet those conditions; where they do not, the legitimate-interest basis and all the rights below apply in full.\n\nVisitors and people who write to us. Legitimate interests — to deliver the site securely, and to answer requests and keep a record of how we handled them — and our legal obligation to answer data protection requests (Article 6(1)(c) GDPR)."
  },
  {
   "heading": "Why we do not write to you individually",
   "anchor_id": "notification",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "When personal data is not obtained from the person concerned, Article 14 GDPR normally requires the controller to tell them. We do not contact the people we measure individually, and we rely on the exception in Article 14(5)(b) GDPR: we record forecasts from more than a hundred public sources as they appear, many people are known to us only by a handle, and contacting each of them would take a disproportionate effort and would mean collecting contact details we do not otherwise hold. For our editorial work we also rely, as far as it applies, on § 4 of the Estonian Personal Data Protection Act.\n\nInstead, Article 14(5)(b) asks us to make the information public and protect your interests in other ways, and this is how we do it:\n\n- this notice is linked from the foot of every page;\n- every profile has an \"Is this your profile?\" link to the form;\n- a profile stays out of search engines until its record reaches the published threshold;\n- every major change to a record is announced in the public corrections log."
  },
  {
   "heading": "Who receives the data",
   "anchor_id": "recipients",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "Readers: published profiles, pages and downloads are public.\n\nService providers who process data for us:\n\n- Cloudflare — hosting, delivery, the request form and its message store, and storage of evidence copies (United States; EU-U.S. Data Privacy Framework);\n- Google — the Gemini language model, which reads public texts to find forecasts (United States; EU-U.S. Data Privacy Framework);\n- Alibaba Cloud — language and speech models that read public texts and transcribe public podcast audio (Singapore, which has no EU adequacy decision; the transfer is covered by the EU standard contractual clauses in Alibaba Cloud's data processing terms);\n- Apify — collection of public posts and video information from X and YouTube (Czech Republic).\n\nThese providers receive the public material we read, not the messages you send us; those stay with Cloudflare and with us. We do not sell personal data, and nothing about you is passed to betting operators."
  },
  {
   "heading": "How long we keep it",
   "anchor_id": "retention",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "- Profiles, forecasts and the evidence behind them: for as long as the profile is published. The saved copy of each publication is the evidence for the numbers built on it, so it is kept for as long as those numbers are published.\n- If a profile is removed after a decision on a request, its pages, downloads and cards are removed at once; the evidence and the decision are kept only as long as needed to answer legal claims about what we published.\n- Messages sent through the form: two years after the request is closed, then deleted. The public request log contains no personal data.\n- Affiliate link clicks: only the country, the region and the type of page are recorded, not who clicked.\n- Technical logs: Cloudflare keeps them under its own terms; we do not keep IP addresses."
  },
  {
   "heading": "If you visit this site",
   "anchor_id": "visitors",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "We do not set cookies, and we use no analytics scripts and no advertising trackers. Cloudflare, which delivers the site, processes IP addresses and request data to deliver pages and protect the site against abuse, and may set a strictly necessary security cookie. When you follow an affiliate link we record the country, the region and the type of page, not who you are. When you use the form we receive your email address, the page you name, your message and the country your message came from."
  },
  {
   "heading": "Your rights",
   "anchor_id": "rights",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "You can ask us:\n\n- for a copy of the data we hold about you (Article 15 GDPR);\n- to correct inaccurate data (Article 16);\n- to erase data about you (Article 17);\n- to restrict processing while a dispute is decided (Article 18);\n- to stop processing data about you, on grounds relating to your situation (Article 21).\n\nData portability (Article 20) applies only to data processed on the basis of consent or a contract, which we do not use; every profile already has its data as JSON and CSV downloads, and we send you your copy in the same form. Every number here comes from published rules, the same for every tipster and source. These numbers describe a public record of predictions and carry no legal or similarly significant effect on anyone (Article 22).\n\nRequests are free. We answer within one month of receipt; for a complex request we may extend this once, by up to two months, and tell you why within the first month. We act on a request once we know it comes from the person concerned: a post or a message from a channel already listed in the profile, or an email from an address published there — we do not ask for documents. How we decide an objection or an erasure request is explained on the right of reply page."
  },
  {
   "heading": "How to object or ask for erasure",
   "anchor_id": "object",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "Use the form on the right of reply page and choose \"I object to the processing of data about me\" or \"Erase data about me\". Give the address of the profile or page, say briefly why — for an objection, what in your situation makes the processing unfair to you — and give an email address for our reply. You get a reference number on screen at once. Once we have confirmed it is you, the profile is kept out of search engines until we decide, and you receive a reasoned decision within one month."
  },
  {
   "heading": "Complaints",
   "anchor_id": "complaints",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "If you think we handle your data unlawfully, you can complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, Estonia, +372 627 4135, www.aki.ee — or to the supervisory authority of the country where you live or work (Article 77 GDPR). We would rather hear from you first, through the form, but you do not have to."
  },
  {
   "heading": "Changes to this notice",
   "anchor_id": "changes",
   "revision": null,
   "valid_from": null,
   "valid_until": null,
   "body": "This is version 0.9 of the notice, dated 9 October 2026. Any change will be listed here with its date.\n\n14 October 2026: Cloudflare also stores copies of the evidence; added to “Who receives the data”.\n\n18 October 2026: the safeguard for transfers to Alibaba Cloud (Singapore) named in “Who receives the data”."
  }
 ],
 "operator": {
  "brand": "Forecast Record",
  "legal_entity": "Nordhandel OÜ",
  "registration_number": "12402241",
  "address": "Masti tn 17, 11911 Tallinn, Estonia",
  "email": "privacy@forecastrecord.com",
  "country_name": "Estonia",
  "supervisor": "Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate), Tatari 39, 10134 Tallinn, Estonia, +372 627 4135",
  "supervisor_url": "https://www.aki.ee/en",
  "draft": false,
  "missing_items": []
 },
 "entity_id": "privacy:/privacy/",
 "source_revision": 34
}