Privacy Policy

Last updated: 3 September 2026

1. Data controller

The controller of the personal data collected through SMana.it is CHE IDEA di Fabio Cocco, Via Cav. Nicola Berardi, 8, 70018 Rutigliano (BA), Italy — VAT No. 07418380726 — Tax Code CCCFBA75R11A662W. Contacts: info@smana.it — certified email (PEC) fabiococco@pec.it.

2. Data processed

SMana may process data provided during registration and use of the service, including first name, last name, email address, telephone number, age, country, protected credentials, server and club data, the first and last name chosen for the virtual coach, game data and statistics, service messages, internal messages and conversations between coaches, reports, preferences and technical logs.

When Plus is purchased, SMana also processes the billing data required for the transaction, such as first name, last name, tax code where required, address, postal code, city, province, country and billing email, as well as order data, amount, duration, transaction identifiers and payment/refund status.

3. Payment data

Payments are handled through PayPal. SMana does not need to store full card details or the user's PayPal credentials. Only the identifiers and technical outcomes required to verify, reconcile, activate and refund the order are processed.

4. Purposes

Data are processed to create and manage the account; verify the email address; provide access to the game; manage clubs, Worlds, progress and messages; provide support; prevent abuse and fraud; ensure security and stability; manage Plus, orders, payments, refunds and withdrawal; issue tax documents; and comply with administrative, accounting, tax and legal obligations.

5. Legal bases

Depending on the circumstances, processing is carried out for the performance of the contract or measures requested by the user, compliance with legal obligations, the controller's legitimate interest in the security and proper management of the service and, where required, on the basis of consent.

6. Providers and recipients

SMana may use technical providers that are necessary for the operation of the service. In particular:

• Brevo, for sending and technically managing transactional and service emails;
• PayPal, for managing payments and refunds;
• Aruba PEC / Aruba Electronic Invoicing, for preparing, transmitting and storing/managing tax documents according to the service used;
• the Italyn Exchange System (Sistema di Interscambio) and competent public authorities, where tax data must be communicated by law;
• hosting and technical infrastructure providers strictly necessary to provide the service.

Personal data are not sold to third parties.

7. Electronic invoicing

Billing data may be included in tax documents and transmitted to the parties involved in electronic invoicing and tax compliance. Data associated with an order are retained so that the historical correspondence with the issued document is preserved even if the user subsequently changes their billing information.

8. Internal messaging and moderation

SMana provides an internal messaging system between coaches. The content of conversations, related metadata (sender, recipient, date and time, club/World) and any reports are stored on the service systems to enable delivery, replies, security, abuse prevention and moderation.

Deleting a conversation from a user's area removes it only from that user's view and does not technically erase the history. The other participant may continue to view it, and the administration may retain the history for moderation, security, user protection and dispute management purposes. Only the administration may close a thread to prevent new messages or permanently delete it from the service's operational systems.

If a message is reported, the administration may review the reported message and the entire conversation needed to understand its context. Internal messaging is not an end-to-end encrypted communication system and must not be used to transmit passwords, financial data or other highly confidential information.

9. Reports concerning names, trademarks and content

When a person uses the public form to report a name, trademark, image or other content, SMana processes the data supplied in the form, including first name, last name, any company or organisation, telephone number, email address, the reporting person's capacity, the reason and description of the report, as well as references to the match report and the names displayed at the time of submission. These data are used solely to receive, verify, document and manage the report, contact the reporting person when necessary, prevent abuse and protect the rights of SMana, users and third parties.

Reports may be retained for the time necessary to handle them and subsequently for a period proportionate to documentation requirements, protection of rights and management of possible disputes. The data are not used for promotional purposes.

10. Email communications

Communications required for registration, email verification, security, password recovery, game management, purchases, Plus, invoices and withdrawal are sent because they are necessary to the relationship with the user. Any future promotional communications will be managed separately and, where required, subject to consent.

11. Retention

Account and game data are retained for as long as necessary to provide the service and subsequently according to criteria proportionate to security purposes, protection of rights and management of possible disputes.

Data and documents relating to contractual relationships, payments and invoicing are retained for the period required by applicable civil, accounting and tax obligations, normally up to 10 years, unless different or longer periods are required by law or necessary in the event of litigation.

12. Minors

Independent registration with SMana is permitted only to users who declare that they are at least 14 years old. Younger users may not register independently.

13. User rights

Where applicable, users may exercise their rights of access, rectification, erasure, restriction, objection and portability by writing to info@smana.it or by certified email (PEC) to fabiococco@pec.it. Users may also lodge a complaint with the Italyn Data Protection Authority.

14. Security

SMana adopts reasonable technical and organisational measures, including HTTPS, hashed password storage, session management, backups, access controls and limitation of administrative privileges.

15. Updates

This notice may be updated when new features, categories of data, payment methods, tax services or providers are introduced. The current version is the one published on this page.