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Last Updated: December 8, 2024 | Effective Date: December 8, 2024 | Version: 2.1

This Privacy Policy applies to all services provided by SocialFlow Ads and is GDPR-compliant. We are committed to transparency and protecting your rights as a data subject.

1. Data Controller Information

Data Controller: SocialFlow Ads
Registration: Malta Business Registry
Address: Level 3, St. Julian's Business Centre, Elia Zammit Street, St. Julian's STJ 3155, Malta
Email: privacy@socialflowads.com
Data Protection Officer: dpo@socialflowads.com

2. Scope and Applicability

This Privacy Policy applies to:

This policy does NOT cover third-party operators (casinos, sportsbooks) that you visit through our affiliate links. Those sites have their own privacy policies.

3. Information We Collect

3.1 Personal Data You Provide Directly

Data Type Source Purpose Legal Basis
Contact Information Contact forms, email Respond to inquiries Legitimate interest
Email Address Newsletter signup Marketing communications Consent (opt-in)
Feedback & Comments Contact forms Service improvement Legitimate interest

3.2 Automatically Collected Data

Data Category Specific Data Points Collection Method Retention Period
Technical Data IP address, browser type, OS, device type Server logs, analytics 26 months
Usage Data Pages visited, time on site, referral source Google Analytics 26 months
Cookie Data Cookie IDs, preferences, session data First & third-party cookies Varies (see Section 5)
Affiliate Tracking Click IDs, referral paths Affiliate network cookies 30-90 days

3.3 Data We Do NOT Collect

4. Legal Basis for Processing (GDPR Article 6)

We process your personal data based on the following legal grounds:

Consent (Article 6(1)(a))

  • Newsletter subscriptions
  • Marketing cookies
  • Optional analytics

You can withdraw consent at any time.

Legitimate Interest (Article 6(1)(f))

  • Website analytics and optimization
  • Fraud prevention and security
  • Responding to inquiries

Balanced against your rights and freedoms.

Legal Obligation (Article 6(1)(c))

  • Tax records and accounting
  • Regulatory compliance
  • Response to lawful requests

Required by EU or Member State law.

Contract Performance (Article 6(1)(b))

  • Service delivery
  • Technical support
  • Account management (if applicable)

Necessary to fulfill our services.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience and analyze site performance. You can control cookie preferences through our Cookie Consent Manager.

5.1 Cookie Categories

Category Purpose Examples Duration Required?
Strictly Necessary Essential site functions Session management, security Session only ✓ Yes
Performance Site analytics Google Analytics (_ga, _gid) 26 months Optional
Functional Remember preferences Language, cookie consent 12 months Optional
Targeting/Advertising Affiliate tracking Referral tracking cookies 30-90 days Optional

5.2 Third-Party Cookies

Service Provider Purpose Cookies Set Privacy Policy
Google Analytics Website analytics _ga, _gid, _gat Google Privacy
Affiliate Networks Referral tracking Varies by network See individual network policies

5.3 Managing Cookies

You have several options to manage cookies:

6. How We Use Your Information

We process your data for the following purposes:

Website Operations

  • Provide access to our content and services
  • Maintain site security and prevent fraud
  • Ensure technical functionality
  • Monitor and improve performance

Communication

  • Respond to your inquiries
  • Send newsletters (with consent)
  • Provide customer support
  • Notify of policy changes

Analytics & Improvement

  • Analyze user behavior and preferences
  • Improve content relevance
  • A/B testing and optimization
  • Create aggregated statistics

Affiliate Partnerships

  • Track referrals to partner operators
  • Attribute commissions correctly
  • Comply with partner agreements
  • No personal data shared with operators

7. Data Sharing and Disclosure

We do NOT sell your personal data. We may share data with the following categories of recipients:

7.1 Service Providers (Data Processors)

Provider Category Purpose Data Shared Location
Web Hosting Site infrastructure Technical logs, IP addresses EU/EEA
Analytics Providers Site analytics Usage data, anonymized IPs USA (adequacy decision)
Email Services Newsletters, transactional emails Email addresses EU/EEA
Affiliate Networks Referral tracking Anonymous click IDs Varies

All data processors are bound by Data Processing Agreements (DPAs) and comply with GDPR requirements.

7.2 Affiliate Partners & Operators

⚠️ Important Disclosure

When you click an affiliate link to a casino or sportsbook:

7.3 Legal Disclosures

We may disclose your information if required to:

8. International Data Transfers

Our primary data processing occurs within the EU/EEA. When we transfer data outside the EEA, we ensure adequate protection through:

You have the right to request information about the safeguards we use for international transfers.

9. Your Rights Under GDPR

As a data subject in the EU/EEA, you have the following rights:

🔍 Right to Access (Article 15)

Request a copy of your personal data we hold. We will provide this within 30 days, free of charge.

✏️ Right to Rectification (Article 16)

Correct inaccurate or incomplete personal data.

🗑️ Right to Erasure (Article 17)

Request deletion of your data ("right to be forgotten") when no longer necessary or consent withdrawn.

⏸️ Right to Restriction (Article 18)

Limit how we process your data in certain circumstances.

📦 Right to Data Portability (Article 20)

Receive your data in a structured, machine-readable format.

🚫 Right to Object (Article 21)

Object to processing based on legitimate interests or for direct marketing.

🤖 Automated Decision-Making (Article 22)

Not subject to solely automated decisions with legal effects. (We do not use such processing.)

❌ Right to Withdraw Consent

Withdraw consent at any time where processing is based on consent.

9.1 How to Exercise Your Rights

To exercise any of your rights:

9.2 Right to Lodge a Complaint

If you believe we have not handled your data properly, you have the right to lodge a complaint with a supervisory authority:

10. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy:

Data Type Retention Period Reason
Contact Form Data 2 years after last contact Service delivery, legal claims
Newsletter Emails Until unsubscribe + 30 days Marketing purposes
Analytics Data 26 months Google Analytics default, trend analysis
Server Logs 90 days Security, troubleshooting
Affiliate Tracking 30-90 days Attribution period per partner agreements
Legal/Financial Records 7 years Tax compliance, legal obligations

After retention periods expire, data is securely deleted or anonymized beyond recovery.

11. Data Security Measures

We implement appropriate technical and organizational measures to protect your data:

🔒 Technical Measures

  • SSL/TLS encryption (HTTPS)
  • Secure hosting infrastructure
  • Regular security updates
  • Firewall protection
  • Access controls and authentication
  • Regular backups

📋 Organizational Measures

  • Data minimization principle
  • Staff training on data protection
  • Confidentiality agreements
  • Access limited to authorized personnel
  • Data breach response procedures
  • Regular security audits

⚠️ Security Disclaimer

While we implement industry-standard security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but continuously work to protect your data.

12. Children's Privacy

Age Restriction: Our website is intended for adults (18+ or legal gambling age in your jurisdiction). We do not knowingly collect data from minors.

If we become aware that we have inadvertently collected personal data from a minor, we will:

If you believe we have collected data from a minor, contact us immediately at: privacy@socialflowads.com

13. Automated Decision-Making and Profiling

We do NOT engage in:

Our analytics are used solely for aggregate insights and do not result in automated decisions about individual users.

14. Changes to This Privacy Policy

We may update this policy periodically to reflect:

Notification: Material changes will be communicated via:

We encourage you to review this policy periodically for any changes.

15. Contact Information

Data Protection Contacts

General Privacy Inquiries

Email: privacy@socialflowads.com
Response Time: 2-3 business days
For: General questions, data requests

Data Protection Officer

Email: dpo@socialflowads.com
Response Time: 1-2 business days (GDPR requests)
For: GDPR rights, complaints, concerns

Postal Address:
SocialFlow Ads - Privacy Department
Level 3, St. Julian's Business Centre
Elia Zammit Street
St. Julian's STJ 3155
Malta

16. Additional Resources

For more information about data protection:

Questions or Concerns?

We're committed to transparency and protecting your privacy.

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