on10.ai

Privacy Policy

Effective date: October 2, 2026

This Privacy Policy explains how Pendulibrium D.O.O. (“Pendulibrium”, “we”, “us”) collects, uses and protects personal data when you use the ON10 website at on10.ai (the “Website”) and the ON10 mobile app (the “App”). Together we call them the “Services”. We wrote it to be short and clear. If anything is unclear, write to us at contact@pendulibrium.com.

1. Who we are

The data controller is Pendulibrium D.O.O., Ss. Cyril and Methodius 40-1, 1000 Skopje, North Macedonia. Contact: contact@pendulibrium.com.

We are based in North Macedonia and offer the Services worldwide. We follow the North Macedonian Law on Personal Data Protection and, where they apply to you, the EU and UK General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the CPRA (CCPA), other US state privacy laws, and similar laws in other countries.

2. The short version

  • Your videos stay on your phone. ON10 processes video on your device. We do not upload, store or see your videos.
  • Registering is optional. You can join the waitlist with only your email.
  • We collect only what we need: your email, and if you create a profile, your name, city, ZIP code, sport and profile picture.
  • We send marketing emails only if you opt in. Every email has an unsubscribe link.
  • We do not sell your personal data and we do not share it for targeted advertising.
  • Payments happen in the Apple App Store or Google Play. We never see your card details.

3. Data we collect

3.1 Data you give us

  • Waitlist and email signup (Website): your email address. If you came through a friend’s invite link, the invite code.
  • Account (App, optional): email address, first name, last name, city, ZIP code, the sport you play and a profile picture.
  • Social sign-in: if you sign in with Apple, Google or another provider, we receive the basic details that provider shares with your permission, usually your name, email address, profile picture and an account ID. We never receive your password. With Sign in with Apple you can choose to hide your email.
  • Messages to us: what you write when you contact us, and your contact details.

3.2 Data collected automatically

  • Website usage: pages you visit, the site that sent you (for example a search engine or social network), campaign tags in links (such as utm_source), browser and device type, and approximate location derived from your IP address. We use Google Analytics for this.
  • Visit and signup source: our Website keeps a random visitor ID and the source of your first visit in your browser (cookie and local storage, up to 30 days) so we can tell which links bring signups. This ID does not identify you by name.
  • Referral program: when you open a friend’s invite link we record the visit, which store button you tap, and a click ID. To connect an invite to an app install on iPhone, we may briefly compare the IP address of the link visit and the first app launch within a 72-hour window. We use this only to credit the person who invited you.
  • App usage: basic technical and usage data such as app version, device type, crash reports and which features are used, to keep the App working and improve it.

3.3 Data we do not collect

  • Your videos and clips. They are processed on your device and stay there unless you choose to export or share them yourself.
  • Payment card or bank details. Apple and Google handle all payments.
  • Precise GPS location.
  • Sensitive data such as health, biometric identification, religion or political views. ON10’s AI follows the player you tap within your own video on your device. It does not identify who a person is and does not create facial recognition profiles.

4. How we use your data and our legal bases

For people in the EU, UK and similar regions, here is why we use each kind of data and the legal basis we rely on:

  • Run the waitlist and tell you when ON10 launches: your consent, given when you sign up.
  • Send news, tips and offers by email: your consent. You can withdraw it anytime with the unsubscribe link or by writing to us.
  • Create and run your account, sign-in and profile: performance of our contract with you (our Terms of Service).
  • Provide subscriptions and Pro features bought in the App: performance of our contract with you.
  • Run the referral program and credit rewards: performance of the referral terms you join, and our legitimate interest in preventing abuse.
  • Measure the Website and App and improve them: your consent where the law requires it (for analytics cookies), otherwise our legitimate interest in understanding and improving our Services.
  • Keep the Services secure and prevent fraud and spam: our legitimate interests.
  • Answer your questions and requests: our legitimate interest in helping you, or our contract with you.
  • Comply with the law, tax and accounting rules, and respond to lawful requests: legal obligation.

We do not use your data for automated decisions that have legal or similarly significant effects on you.

5. Cookies and similar technologies

The Website uses a small number of cookies and browser storage:

  • Necessary: to run the site and remember an invite code you arrived with (cookie on10_ref, up to 30 days).
  • Analytics: Google Analytics cookies (such as _ga) and our own first-visit and visitor ID storage (on10_touch, on10_vid), used to count visits and signups by source.

Where the law requires it, we ask for your consent before setting analytics cookies, and you can change your choice at any time. You can also block or delete cookies in your browser settings, and opt out of Google Analytics with Google’s browser add-on. We do not use advertising cookies.

6. Who we share data with

We share personal data only with service providers that help us run the Services, under contracts that require them to protect it and use it only on our instructions:

  • Hosting: our web hosting provider, which stores the Website and its database.
  • Google: Google Analytics for usage measurement, and Google Firebase for app sign-in and account data.
  • Sign-in providers: Apple, Google and any other social sign-in you choose to use.
  • App stores: Apple and Google process subscriptions and payments as independent controllers under their own privacy policies.
  • Email delivery: the service we use to send waitlist and marketing emails.

We may also disclose data if the law requires it, to protect our rights, users or the public, or as part of a merger, acquisition or sale of assets, in which case this policy will continue to protect your data.

We do not sell personal data. We do not share personal data for cross-context behavioral advertising.

7. International transfers

We are located in North Macedonia and some of our providers are located in the European Union, the United States and other countries. When we transfer personal data from the EU, UK or other regions with transfer rules, we rely on adequacy decisions or on safeguards such as the European Commission’s Standard Contractual Clauses.

8. How long we keep data

  • Waitlist email: until you unsubscribe or ask us to delete it, or until we stop the waitlist.
  • Account data: while your account is active. When you delete your account we delete or anonymize your data within 30 days, except where the law requires us to keep it longer.
  • Analytics data: up to 26 months.
  • Referral and visit records: up to 24 months, or longer only while needed to settle a reward.
  • Messages to us: up to 24 months after the conversation ends.

9. Your rights

Depending on where you live, you have some or all of these rights:

  • Access the personal data we hold about you and get a copy.
  • Correct inaccurate or incomplete data.
  • Delete your data.
  • Restrict or object to certain uses, including use based on our legitimate interests.
  • Data portability: receive your data in a common machine-readable format.
  • Withdraw consent at any time, without affecting earlier use.
  • Opt out of marketing emails at any time.
  • Complain to a data protection authority. In North Macedonia this is the Personal Data Protection Agency. In the EU or UK you can contact the authority where you live or work.

To use your rights, write to contact@pendulibrium.com. You can also delete your account directly in the App. We answer within one month, or 45 days where US state law applies, and we may ask for information to confirm your identity. We will not charge you or treat you differently for using your rights.

10. Additional information for US residents

This section applies to residents of California and other US states with privacy laws (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon and others).

  • Categories we collect: identifiers (name, email, account ID, IP address), customer records (city, ZIP code, profile picture), internet and app activity, and approximate location from IP. Sources, purposes and recipients are described in sections 3, 4 and 6.
  • Sensitive personal information: we do not collect it for the purpose of inferring characteristics about you.
  • Sale and sharing: we do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the past 12 months. We honor Global Privacy Control signals as an opt-out request.
  • Your rights: to know, access, correct and delete your data, to opt out of sale, sharing and targeted advertising, and to not be discriminated against for using these rights. You may use an authorized agent. If we deny a request, you can appeal by replying to our answer.

11. Children and young athletes

ON10 is made for players of all ages, and many are under 18. Accounts for children must be created and managed by a parent or legal guardian:

  • Children under 13 (or under the age of digital consent in their country, which is up to 16 in the EU) may only use an account created by a parent or guardian, who gives consent on their behalf.
  • We do not knowingly collect personal data from a child without that consent. If we learn we did, we delete it.
  • Parents can review, change or delete their child’s data and withdraw consent at any time by writing to us.

If you believe a child has given us personal data without a parent’s consent, contact us at contact@pendulibrium.com.

12. Security

We use appropriate technical and organizational measures to protect personal data, including encrypted connections (HTTPS), access controls and providers with strong security practices. No system is completely secure. If a data breach affects you, we will notify you and the authorities as the law requires.

13. Links and third-party services

The Services may link to or work with third-party services such as the App Store, Google Play and social networks. Their privacy policies apply when you use them.

14. Changes to this policy

We may update this policy. We will post the new version here with a new effective date, and if the changes are significant we will tell you by email or in the App.

15. Contact

Pendulibrium D.O.O.
Ss. Cyril and Methodius 40-1, 1000 Skopje, North Macedonia
Email: contact@pendulibrium.com