Privacy Policy

1. Introduction & Biomechanical Scope

At BomberManager (operated by BomberManager SRL, a company incorporated under the laws of Italy, with its registered office in Rome), we operate a digital football simulation model that processes spatial coordinates, ball velocity curves, and environmental metrics. This policy governs how we collect, catalog, and secure data from visitors and users, ensuring compliance with global data protection laws, including the European General Data Protection Regulation (GDPR) and the Italian Data Protection Code (Legislative Decree no. 196/2003).

Our data processing activities are structured around the following categories:

Biomechanical Simulation Logging: Mapping player movement curves and vector data.
Environmental Variable Telemetry: Logged parameters including pitch moisture, temperature levels, and wind resistance indices.
User Engagement Tracking: Storing strategic chalkboard presets and tactical preference configurations.
Regulatory Compliance: Adapting all technical processing matrices to match Italian Garante per la protezione dei dati personali standards.

2. Personally Identifiable Information

We collect user-provided details including name, email address, password hashes, and billing credentials when you subscribe to premium tiers. We do not store raw credit card numbers; all monetization transactions are securely processed by third-party payment gateways operating in compliance with PCI-DSS standards.

The categories of personal data collected include:

Identity Information: Legal first name, last name, and chosen profile nickname.
Contact Information: Valid email address for system updates and newsletter delivery.
Authentication Credentials: Secure salted password hashes (raw passwords are never stored).
Transaction Records: Billing country, Italian fiscal codes where applicable, payment methods, transaction timestamps, and invoice records.

3. Striker Telemetry & Coordinates Storage

When using our interactive tactical chalkboard or running wind-tunnel simulation reports, the coordinate parameters (e.g. x-axis and y-axis positions, velocity values, drag coefficients) are logged to map user-designed attacking formations and compile performance tables.

Specifically, our systems capture:

Positional Arrays: Dynamic Cartesian coordinates of tactical nodes on the virtual football pitch.
Kinematic Factors: Simulated ball acceleration rates, friction coefficients of different grass lengths, and air density values.
Scouting Data Exports: User-compiled tables showcasing team formations, passing lanes, and shot success probabilities.
Simulation Preset Configurations: Saved profiles representing specific football manager archetypes (e.g., Guardiola, Klopp, Arteta) and custom stadium sizes.

4. Automated Device Log Collection

Our web servers automatically record technical parameters including your Internet Protocol (IP) address, browser version type, operating system configuration, active viewport ratios, referring URLs, and screen zoom kinematics events to prevent bot abuse and improve site speed.

Our system automatically registers:

Network Telemetry: Anonymized or masked IP addresses, proxy status flags, and ISP identifiers.
Device Metadata: User-agent strings, device brand/model, screen resolution, and rendering engine versions.
Interaction Log Files: Click events, hover durations over tactical hotspots, and zoom coordinates on the 3D stadium mockups.
Temporal Data: Visit timestamps, duration of sessions, and navigation pathways within the tactical portal.

5. Purpose of Data Processing

All processed data is utilized to render customized tactical boards, calculate aerodynamic ball trajectories, manage subscription access, optimize database query delivery, send technical updates, and verify agreement compliance.

We process your data for the following specific purposes:

Operational Execution: Rendering custom 3D stadium physics and tactile pitch graphics dynamically.
Account Administration: Processing payments, activating premium accounts, and sending license renewal notices.
Technical Performance Optimization: Enhancing load speeds, running system debug scripts, and balancing server loads across European data hubs.
Customer Engagement: Providing support desk services, responding to inquiries, and delivering newsletter updates if opted in.

6. Legal Basis for Processing

Under European guidelines, we process personal details based on your explicit consent, for the performance of a subscription contract, to comply with legal responsibilities, and for legitimate interests like network security.

Under European guidelines (specifically Article 6 of the GDPR and related Italian privacy regulations), our legal foundations include:

Consent (Art. 6(1)(a) GDPR): Your voluntary consent given during cookie configuration, registration, or newsletter sign-up.
Contract Performance (Art. 6(1)(b) GDPR): Facilitating access to tactical dashboards and premium scouting tiers.
Legal Obligation (Art. 6(1)(c) GDPR): Fulfilling tax requirements under Italian fiscal law, including billing compliance and accounting records.
Legitimate Interests (Art. 6(1)(f) GDPR): Securing our infrastructure against digital fraud, preventing bot scripts, and improving overall website response times.

7. Third-Party Sharing Rules

We do not sell personal details. We share metadata with trusted service providers (web hosting, database engines, email senders) under strict non-disclosure contracts, and with scouting agencies only when users choose to export public player telemetry sheets.

Our sharing partners include:

Cloud Infrastructure Providers: Web hosting servers and relational database clusters physically located within the EU.
Payment Processing Gateways: Secure systems that handle premium subscription billing transactions.
Email Delivery Networks: Platforms utilized to transmit system notifications, password recovery codes, and strategic digests.
Authorized Sports Scouts: Strategic partners, but only if you explicitly choose to make your custom player telemetry boards public.

8. Advanced Cryptographic Security

We deploy Transport Layer Security (TLS) encryption, secure password hashing algorithms, and isolated firewalls to protect database clusters. While we apply standard security measures, no digital transmission can be guaranteed completely secure.

Our defense-in-depth security protocol includes:

Encryption in Transit: TLS 1.3 encryption protocols protecting all forms and data entries.
Data Minimization: Removing unnecessary identifiers and archiving legacy simulation coordinate sheets.
Network Segmentation: Restricting database access to authorized maintenance scripts and internal application interfaces.
Access Control Matrices: Applying strict read/write permission protocols to ensure that staff can only access data required for debugging.

9. International Data Transfer Boundaries

Your data may be processed on servers located outside your home region. We enforce EU Standard Contractual Clauses (SCCs) to ensure that cross-border transfers maintain equivalent privacy standards.

To guarantee compliance, we ensure that:

EU-Centric Hosting: Our primary database and core tactical simulation engines are hosted within the EU.
Standard Contractual Clauses: Contracts with international partners include standard clauses approved by the European Commission.
Supplementary Safeguards: Implementing end-to-end encryption for any data synchronized across external backup repositories.
Regulatory Audits: Reviewing data pipelines annually to comply with Italian and EU cross-border communication laws.

10. Data Retention Policy

User account details are retained as long as your profile remains active. Unsubscribed accounts and inactive telemetry reports are archived after 24 months, with personal identifiers stripped for statistical analysis.

Our retention guidelines are structured as follows:

Active User Account Data: Retained for the duration of the active subscription or profile lifespan.
Telemetry and Tactical Chalkboards: Kept for 24 months of consecutive inactivity before automatic archival.
Financial and Transaction Records: Retained for up to 10 years to comply with Italian tax and accounting legislation.
Anonymized Simulation Models: Kept indefinitely as aggregate mathematical metadata to train simulator physics.

11. User Data Portability Rights

You hold the right to access, edit, or delete your personal details. You can request a machine-readable JSON export of your saved tactical coordinates by contacting our support desk.

Your rights as a data subject under GDPR Chapter III include:

Right of Access (Art. 15 GDPR): Requesting a copy of all personal details and tactical telemetry files stored under your profile.
Right to Rectification (Art. 16 GDPR): Updating inaccurate coordinator values, nicknames, or contact emails.
Right to Erasure (Art. 17 GDPR): Requesting permanent deletion of your account and saved tactical boards.
Right to Portability (Art. 20 GDPR): Exporting your data in a structured, machine-readable JSON format.
Right to Object (Art. 21 GDPR): Objecting to processing based on legitimate interests or direct communications.

12. Children's Privacy Shield

Our simulation portal is designed for users aged 16 and older. We do not intentionally process details from minors. If we discover a child under 16 has registered, the profile is permanently deleted immediately.

Our protective measures include:

Age Attestation: Requiring birth-year declarations or confirmation statements during the registration sequence.
Parental Inquiries: Enabling parents to contact our support desk to verify and request deletion of minor profiles.
Design Constraints: Creating tactical board content intended solely for mature strategy analysis, avoiding child-targeted designs.
Automatic Filtering: Blocking chat or coordinate sharing for profiles identified as failing age criteria.

13. Policy Amendments & Contact Details

We reserve the right to amend this agreement to reflect updates in physical modeling algorithms or legal regulations. If you have questions regarding this 13-point privacy policy, contact us at compliance@bombermanager.com or write to our Italian headquarters.

Our physical and digital contact parameters:

Data Protection Officer: BomberManager Compliance Committee (dpo@bombermanager.com)
Registered Physical Address: BomberManager SRL, Via dei Fori Imperiali, 24, 00186 Roma (RM), Italy
National Regulatory Authority: Garante per la protezione dei dati personali, Piazza Venezia n. 11, 00187 Roma (IT)
Response Turnaround: In compliance with European standards, we respond to data subject inquiries within 30 calendar days.

Biometric Data & Telemetry Privacy Agreement