Effective Date: [INSERT DATE]
Idioma / Language: Este documento está disponible en español. This document is available in Spanish. → POLÍTICA DE PRIVACIDAD — español
Cunaguaro S.A.S. ("Cunaguaro," "we," "us," or "our") operates the Punch desktop application, its companion mobile application, the backend API services, and any related websites (collectively, the "Services"). This Privacy Policy describes how we collect, use, share, and protect your personal information when you use our Services.
By using the Services, you agree to the practices described in this Policy. If you do not agree, please do not use the Services.
This Policy applies to all Services provided by Cunaguaro S.A.S., a company incorporated under the laws of the Oriental Republic of Uruguay. The Services are available in the Supported Regions listed at [INSERT WEBSITE URL]/about, subject to change as we expand to additional countries and servers. This Policy is governed by Uruguayan data protection law (Ley N° 18.331), as well as applicable international regulations including the GDPR where relevant.
Uruguay has been granted an adequacy decision by the European Commission, meaning Uruguayan data protection standards are recognized as equivalent to those of the European Union.
Punch reads match data from the Riot Live Client API (127.0.0.1:2999) running on your local machine. This includes:
Critically, this gameplay data is processed locally on your device and is not transmitted to or stored on our servers. The AI coaching engine (Layer 0) runs directly on your machine. Only minimal, derived signals (not full raw match data) are sent to our backend when a cloud AI query is necessary.
When you use the Services, we automatically collect:
We use the collected information for the following purposes:
| Purpose | Data Used | Legal Basis |
| Provide and maintain the Services (coaching, voice delivery, account linking) | Riot ID, gameplay signals | Performance of a contract (Terms of Service) |
| Process subscriptions and payments | Email, payment metadata (via processor) | Performance of a contract |
| Deliver and measure advertising ("Farm-to-Play") | Advertising ID, device data, ad interactions | Consent (for personalized ads); Legitimate interest (for ad performance measurement and frequency capping) |
| Improve, personalize, and develop the Services | Usage data, error logs, coaching queries | Legitimate interest |
| Send service notifications, updates, and marketing communications | Consent (opt-in required for marketing) | |
| Comply with legal obligations and enforce our Terms | All categories as needed | Legal obligation; legitimate interest |
| Ensure security, prevent fraud, and detect abuse | IP, device data, usage patterns | Legitimate interest; legal obligation |
Where we rely on legitimate interest as a legal basis, you have the right to object to such processing. Where we rely on consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Punch offers a free tier funded by advertising. Free users view advertisements within the desktop application during lobby or idle phases. Each ad view earns "Coaching Minutes," which are consumed during active matches. Users may purchase a Premium subscription to remove ads and gain unlimited coaching.
We may partner with third-party advertising networks and ad-serving companies to display advertisements in the Services. These partners may use cookies, device identifiers, and similar tracking technologies to:
As of the effective date, the ad provider(s) we work with include: [INSERT AD PROVIDER(S)]. This list may be updated from time to time. You may opt out of interest-based advertising through the privacy preferences section of the application.
You can control whether your data is used for personalized advertising, as these features become available, by:
We use cookies and similar technologies (e.g., local storage, session identifiers) for the following purposes:
When you first launch the application, you will be presented with a cookie consent interface where you can accept or decline each category of non-essential cookies. You can change your preferences at any time through the application's privacy settings. Disabling essential cookies may impair the functionality of the Services.
We do not sell your personal information. We share information only in the following circumstances:
We engage third-party vendors to perform functions on our behalf, including:
These providers are contractually bound to process data solely per our instructions and in compliance with this Policy.
We may disclose information when required by law, court order, or governmental regulation, or when we believe in good faith that disclosure is necessary to:
In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information becomes subject to a different privacy policy.
We may share aggregated or de-identified information that cannot reasonably identify you for research, marketing, analytics, or other purposes.
Cunaguaro S.A.S. is based in Uruguay. Some of our service providers may process data in other countries (e.g., United States via Google Cloud). When we transfer personal data internationally, we implement appropriate safeguards in accordance with applicable law, including:
We retain personal information only for as long as necessary to fulfill the purposes described in this Policy:
| Data Category | Retention Period |
| Account data (Riot ID, email, subscription status) | Duration of account + 1 year after deletion |
| Match gameplay data | Not stored on our servers (processed locally only) |
| Coaching logs (derived signals sent to AI) | 90 days |
| Usage analytics and error logs | 2 years |
| Payment records | As required by applicable tax and accounting laws |
| Ad impressions and interactions | 2 years |
We may retain information for longer periods where required by law, to resolve disputes, or to enforce our Terms of Service.
Under Uruguayan law (Ley N° 18.331) and, where applicable, the GDPR, you have the following rights regarding your personal data:
To exercise any of these rights, contact us at legal@punchai.gg. We will respond within the timeframes required by applicable law (30 days under Ley 18.331; 30 days extendable to 60 under GDPR). We may ask for proof of identity before processing your request.
If you believe our processing violates data protection law, you have the right to lodge a complaint with the Unidad Reguladora y de Control de Datos Personales (URCDP) in Uruguay or the supervisory authority in your country of residence.
The Services are not directed at children under the age of 14 (the age of consent for data processing under Uruguayan law). We do not knowingly collect personal information from children. If we become aware that a child under the applicable minimum age has provided us with personal information, we will delete it promptly. Parents or guardians who believe their child has provided us with personal information should contact us at legal@punchai.gg.
We implement appropriate technical and organizational measures to protect your personal information, including:
However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.
Data Breach Notification: In the event of a personal data breach, we will notify the Unidad Reguladora y de Control de Datos Personales (URCDP) within 72 hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with Ley N° 18.331 and applicable regulations.
The Services may contain links to third-party websites or services (e.g., Riot Games, payment processors). This Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you interact with.
The Services also interact with the Riot Games ecosystem. League of Legends and all related marks are the property of Riot Games, Inc. Punch is not endorsed by or affiliated with Riot Games.
We do not currently respond to "Do Not Track" (DNT) signals sent by browsers or desktop environments, as there is no consistent industry standard for DNT.
We may update this Privacy Policy from time to time. Material changes will be communicated through:
The updated Policy will be effective 30 days after such notice, unless a different effective date is stated. Continued use of the Services after that date constitutes acceptance of the updated Policy.
Cunaguaro S.A.S. plans to introduce an optional behavioral analytics engine ("Player Profile") as a Premium-tier feature after the beta phase. If enabled explicitly by the user, this feature will:
Status during beta: This feature is NOT active. No match history or behavioral profiling data is stored on our servers during the beta period. Gameplay data continues to be processed exclusively on your local device, as described in Section 2.2.
Cunaguaro S.A.S.
Uruguay, Oriental Republic of Uruguay
For questions, concerns, or to exercise your data protection rights:
*Last updated: [INSERT DATE]*