This Privacy Policy explains how Innovative SEO LTD (“we”, “us”, “our”) processes personal data in connection with our website and related services.

We process personal data in accordance with:

• EU General Data Protection Regulation (EU) 2016/679 (“GDPR”)

• German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG)

• German Telecommunications-Telemedia Data Protection Act (TTDSG)

• Applicable EU and German data protection legislation

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.

1. Data Controller

The controller responsible for processing personal data is:

Innovative SEO LTD
FLT 5, BLK A, The Podium
Triq Montanaro Gauci
STJ 1291, St Julians
Malta

Email: privacy@innovativeseo.se

2. Categories of Personal Data

We may process the following categories of personal data.

2.1 Data You Provide Voluntarily

• Email address (e.g. newsletter subscription or contact form)

• Messages and inquiries

• Consent preferences

• Communication settings

2.2 Automatically Collected Data

When you access our website, certain technical data may be collected automatically:

• IP address

• Device type and operating system

• Browser type and version

• Referring URLs

• Pages visited

• Interaction events (e.g. navigation patterns and clicks)

This data may be collected through cookies and similar technologies as described in our Cookie Policy.

2.3 Gameplay and Platform Data

When you use the social gaming platform, we may process additional platform-related data, including:

• Account identifiers

• Gameplay activity and session data

• Virtual currency balances

• In-game interactions and progression

• Technical device data used for fraud prevention and abuse detection

This processing is necessary to operate the platform and provide core functionality.

Legal basis:

• Contractual necessity (Art. 6(1)(b) GDPR)

• Legitimate interest in ensuring system integrity and preventing misuse (Art. 6(1)(f) GDPR)

Virtual currency used within the platform has no monetary value and cannot be redeemed for money or prizes.

3. Purposes of Processing

We process personal data for clearly defined purposes, including:

• Operating and maintaining the website and platform

• Ensuring system security and fraud prevention

• Responding to user inquiries

• Improving website functionality and usability

• Measuring aggregated website performance and analytics (only with consent)

• Measuring advertising effectiveness and campaign performance for the free-to-play platform (only with consent)

• Complying with legal obligations

We do not sell personal data.

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

Personal data is not processed for the purpose of facilitating monetary wagering, gambling transactions, or financial betting activities.

4. Legal Bases for Processing (Article 6 GDPR)

We process personal data only where a lawful basis applies:

• Consent (Art. 6(1)(a) GDPR) – analytics cookies, marketing cookies, newsletters and advertising measurement

• Legitimate interest (Art. 6(1)(f) GDPR) – website operation, system security and fraud prevention

• Legal obligation (Art. 6(1)(c) GDPR) – compliance with applicable laws

• Contractual necessity (Art. 6(1)(b) GDPR) – providing platform functionality and user account services

Where processing is based on legitimate interest, we ensure our interests do not override your fundamental rights and freedoms.

You may withdraw consent at any time.

Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

5. Cookies and Device Storage (Germany)

We use cookies and similar technologies in accordance with GDPR and the German Telecommunications-Telemedia Data Protection Act (TTDSG).

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

• where strictly necessary for website functionality, or

• where the user has provided prior consent.

Accordingly:

• Strictly necessary cookies are used to ensure website functionality and security.

• Analytics cookies are activated only after explicit user consent.

• Marketing and advertising cookies are activated only after explicit user consent.

Non-essential cookies are not set, stored, or accessed before consent is obtained.

Further details are available in our Cookie Policy.

6. Advertising and Conversion Tracking

Where marketing cookies are enabled based on user consent, we may use advertising and conversion tracking technologies to:

• Measure whether advertising campaigns resulted in website actions (e.g. form submissions)

• Improve campaign performance

• Prevent fraud

• Support remarketing where applicable

Data processed may include:

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

• 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 controllers or processors depending on 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.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy.

Typical retention periods include:

• Contact inquiries: up to 24 months

• Email subscriptions: until withdrawal of consent or up to 24 months after last interaction

• Server logs (including IP addresses): typically 30–90 days

• Analytics data (with consent): up to 14 months

• Advertising and conversion tracking data: up to 13 months

• Consent records: up to 3 years

• Gameplay data: retained while the account remains active and deleted after account closure unless legal obligations require otherwise

Users may request account deletion at any time by contacting:

privacy@innovativeseo.se

8. Consent Records and Accountability

When you provide or withdraw consent through our consent management system, we store records including:

• Consent status

• Categories accepted or rejected

• Date and time of consent

• Consent identifier

These records are maintained to demonstrate compliance with GDPR accountability requirements (Art. 5(2)).

9. Third-Party Service Providers

We may share limited personal data with trusted service providers such as:

• Hosting providers

• Analytics providers

• Advertising measurement providers

• Security and infrastructure providers

• Email service providers

Where required, Data Processing Agreements (DPAs) are in place.

Certain providers (such as Google or Meta) may process personal data as independent controllers.

10. International Data Transfers

Some service providers may process personal data outside the EU/EEA.

Where such transfers occur, we ensure appropriate safeguards are implemented, including:

• EU Standard Contractual Clauses (SCCs)

• Additional technical and organisational safeguards

Further details can be provided upon request.

11. Records of Processing Activities

We maintain records of processing activities in accordance with Article 30 GDPR, including:

• Categories of personal data processed

• Purposes of processing

• Retention periods

• Categories of recipients

• Security measures

12. Automated Decision-Making

We do not use automated decision-making or profiling producing legal or similarly significant effects within the meaning of Article 22 GDPR.

13. Data Security

We implement appropriate technical and organisational measures to protect personal data against:

• Unauthorized access

• Accidental loss or destruction

• Misuse or alteration

Security measures are reviewed regularly.

14. Your Rights Under GDPR

If you are located in Germany or another EU/EEA country, you have the right to:

• Access your personal data

• Rectify inaccurate data

• Request erasure

• Restrict processing

• Data portability

• Object to processing

• Withdraw consent at any time

To exercise your rights, contact:

privacy@innovativeseo.se

We respond within one month unless an extension is permitted under applicable law.

15. Right to Lodge a Complaint (Germany)

If you believe your data protection rights have been violated, you may lodge a complaint with a German data protection supervisory authority (Datenschutzaufsichtsbehörde).

A list of German supervisory authorities is available here:

https://www.datenschutzkonferenz-online.de/datenschutzaufsichtsbehoerden.html

16. Children’s Data

The social gaming platform is intended exclusively for individuals 18 years of age or older.

We do not knowingly collect personal data from minors.

If such data is identified, it will be deleted without undue delay.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or operational changes.

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