This Cookie Policy explains how Innovative SEO LTD (“we”, “us”, “our”) uses cookies and similar technologies on our website.

This policy applies to users located in Germany and other EU/EEA countries and should be read together with our Privacy Policy.

This website operates a free-to-play social gaming platform.
No real-money gambling is offered, no deposits are accepted, and no prizes or items of monetary value can be won.

Virtual currency used within the platform has no real-world value and cannot be redeemed.

Cookies are used solely to operate, secure, and improve the entertainment-only social gaming experience.

For transparency and regulatory clarity:

This website does not operate gambling services, does not process financial transactions, and does not accept deposits or payments.

We use cookies in accordance with:

• EU General Data Protection Regulation (GDPR)

• German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG)

• German Telecommunications-Telemedia Data Protection Act (TTDSG)

• Applicable EU and German data protection legislation

1. What Are Cookies?

Cookies are small text files stored on your device when you visit a website.

They are used to:

• Enable technical functionality

• Ensure website security

• Improve usability

• Measure aggregated website performance (where consent has been given)

• Measure advertising effectiveness (where consent has been given)

Cookies may be:

Session cookies
Deleted when you close your browser.

Persistent cookies
Stored for a defined period.

First-party cookies
Set by our website.

Third-party cookies
Set by external service providers.

Some cookies may process personal data such as IP addresses, device identifiers, or online identifiers.

2. Legal Basis for Cookie Use (Germany)

Under §25 TTDSG, storing or accessing information on a user’s device is permitted only when:

• it is strictly necessary for providing a service explicitly requested by the user, or

• the user has provided prior consent.

Accordingly:

• Strictly necessary cookies are used without consent under §25(2) TTDSG and Art. 6(1)(f) GDPR (legitimate interest).

• Analytics and marketing cookies are used only after explicit consent under §25(1) TTDSG and Art. 6(1)(a) GDPR.

Non-essential cookies are not set, stored, or accessed before you provide explicit consent via our consent management platform.

You may withdraw or modify your consent at any time.

Withdrawal does not affect processing carried out before withdrawal.

These technologies are used solely to operate and improve the free-to-play social gaming platform and do not involve monetary wagering, deposits, or real-money gambling activity.

3. Categories of Cookies We Use

A. Strictly Necessary Cookies (Required)

These cookies are essential for the operation and security of the website.

They may be used for:

• Session management

• Security and fraud prevention

• Load balancing

• Storing cookie preferences

• Age verification status (where applicable)

• Maintaining active gameplay sessions

• Maintaining virtual currency balances

Legal basis:
§25(2) TTDSG and Art. 6(1)(f) GDPR (legitimate interest)

Retention:
Session-based or typically 30–90 days, unless longer retention is technically required for account functionality or fraud prevention.

These cookies do not require consent.

B. Analytics Cookies (Statistics – Optional)

Analytics cookies help us understand how users interact with the website in order to improve functionality and performance.

Analytics data is used only to improve the social gaming platform and user experience.

It is not used to facilitate gambling, betting, or monetary wagering.

Analytics cookies may collect:

• Page views

• Navigation patterns

• Device and browser information

• Interaction events

• Aggregated usage statistics

Analytics data is used solely for statistical and performance analysis and is not used for advertising, profiling, or behavioural targeting unless marketing consent is provided.

Legal basis:
Consent (Art. 6(1)(a) GDPR)

Activation:
Only after explicit user consent.

Retention:
Up to 14 months, after which data is deleted or anonymized where possible.

Where technically possible, IP addresses are shortened or anonymized before further processing.

If you consent to analytics but not marketing, marketing cookies will not be activated.

C. Marketing Cookies (Advertising & Conversion Tracking – Optional)

Marketing cookies are used only after explicit user consent.

They are used to:

• Measure advertising effectiveness

• Track conversions (e.g. whether an advertisement led to a website action)

• Improve campaign performance

• Prevent fraud

Marketing cookies may process:

• Event data (page visits, form confirmations, button clicks)

• Device and browser information

• Cookie identifiers

• Approximate geographic information derived from IP address

Typical providers may include:

• Microsoft Advertising (UET tag)

• Google Ads conversion tracking

• Meta Pixel

These providers may act as independent data controllers or processors, depending on the service configuration.

Advertising technologies are used solely to promote the free-to-play social gaming platform and are not used to promote real-money gambling services.

Retention:
Up to 13 months.

4. Example Cookies

Actual cookies used may vary depending on system configuration.

5. Other Tracking Technologies

In addition to cookies, we may use:

Web Beacons (Pixels)

Used for aggregated measurement of campaign performance where consent has been provided.

Local Storage

Used for storing preferences or technical settings.

Local storage is not used for cross-site tracking without consent.

We do not use device fingerprinting for advertising or behavioural profiling.

Platform Functionality and Game Storage

Cookies or local storage may be used to:

• Maintain active gameplay sessions

• Store virtual currency balances

• Save user preferences

• Ensure fair gameplay and prevent abuse

These technologies are necessary for the operation of the social gaming platform and are not used for real-money transactions.

6. Third-Party Providers

Where analytics or marketing cookies are enabled:

• Data may be transmitted to the relevant provider

• Providers may process data according to their own privacy policies

• Data Processing Agreements are implemented where required

We recommend reviewing the privacy policies of:

• Google

• Microsoft

• Meta

7. International Data Transfers

Some third-party providers may process data outside the EU/EEA.

Where personal data is transferred internationally, we ensure appropriate safeguards, including:

• EU Standard Contractual Clauses (SCCs)

• Additional technical and organisational safeguards

Further information may be requested by contacting us.

8. Consent Records and Accountability

To demonstrate compliance with GDPR and TTDSG, we maintain records of cookie consent including:

• Consent status

• Categories accepted or rejected

• Date and time (timestamp)

• Consent identifier

Consent records are stored securely and retained for up to three (3) years after withdrawal or last recorded interaction.

These records are used solely for compliance and accountability purposes.

9. Managing Your Cookie Preferences

You may:

• Accept all cookies

• Reject non-essential cookies

• Select specific cookie categories

You may modify or withdraw consent at any time using the cookie settings tool.

You may also manage cookies through your browser settings. However, disabling strictly necessary cookies may affect website functionality.

10. Impact of Disabling Cookies

If you disable non-essential cookies:

• Analytics measurement will not occur

• Advertising measurement will not occur

If you disable strictly necessary cookies, certain technical features of the platform may not function correctly.

11. Changes to This Cookie Policy

We may update this Cookie Policy to reflect legal, technical, or operational changes.

The most recent version will always be available on our website.

12. Contact

For questions regarding this Cookie Policy, please contact:

privacy@innovativeseo.se