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”)

• Finnish Data Protection Act (Tietosuojalaki 1050/2018)

• Applicable EU and Finnish privacy 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 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 via 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 the following additional data:

• 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:

• Operating and maintaining the website

• 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 social gaming 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) – for analytics cookies, marketing cookies, advertising measurement, and newsletters

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

• Legal obligation (Art. 6(1)(c) GDPR) – where required under applicable law

• Contractual necessity (Art. 6(1)(b) GDPR) – where processing is necessary to operate user accounts and provide platform functionality

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 Tracking Technologies

We use cookies and similar technologies in accordance with GDPR and Finnish electronic communications legislation.

• 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 for these purposes 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 data controllers or as processors depending on the configuration of the service.

Marketing technologies are activated only after explicit user consent.

Advertising technologies are used solely to promote the free-to-play social gaming platform.
They are not used to promote real-money gambling services, betting platforms, or monetary wagering.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this policy and in accordance with applicable law.

Typical retention periods:

• Contact inquiries: up to 24 months after resolution

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

• Server logs (including IP addresses): typically 30–90 days, unless required longer for security investigations

• Analytics data (with consent): up to 14 months, after which data is deleted or anonymized where possible

• Advertising and conversion tracking data (with consent): up to 13 months

• Consent records: up to 3 years after withdrawal or last recorded interaction to demonstrate GDPR compliance

• Gameplay data and virtual currency balances: retained for the duration of the user account and deleted upon account closure unless legal obligations require otherwise.

Where legal obligations require longer retention, data may be stored accordingly.

Users may request account deletion at any time by contacting privacy@innovativeseo.se

8. Consent Records and Accountability

When you provide or withdraw consent via our consent management platform, we store a record of:

• Consent status

• Categories accepted or rejected

• Date and time (timestamp)

• Consent identifier

These records are maintained to demonstrate compliance with GDPR (Article 5(2)) and are retained according to the retention periods described above.

Consent records are used solely for compliance and accountability purposes.

You may modify or withdraw your consent at any time.

9. Third-Party Service Providers

We may share limited personal data with trusted service providers, including:

• Hosting providers

• Analytics providers

• Advertising measurement providers

• Security and infrastructure providers

• Email service providers (if applicable)

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

Certain providers (e.g., Google or Meta) may process personal data as independent controllers for their own purposes.

10. International Data Transfers

Some service providers may process personal data outside the European Union or European Economic Area.

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

• EU Standard Contractual Clauses (SCCs)

• Additional technical and organizational measures

You may request further information regarding these safeguards.

11. Records of Processing Activities

We maintain internal 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 that produces legal or similarly significant effects within the meaning of Article 22 GDPR.

13. Data Security

We implement appropriate technical and organizational 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 Finland or the EU/EEA, you have the right to:

• Access your personal data

• Rectify inaccurate or incomplete data

• Request erasure (“right to be forgotten”)

• 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 extended as permitted by law.

15. Right to Lodge a Complaint (Finland)

If you believe your data protection rights have been violated, you may lodge a complaint with:

Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto)
Website: https://tietosuoja.fi
Phone: +358 29 566 6700

16. Children’s Data

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

We do not knowingly collect personal data from minors.
If we become aware that such data has been collected, it will be deleted without undue delay.

17. Changes to This Privacy Policy

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

The latest version will always be available on our website.