Privacy Policy

Effective date: August 6, 2026

1. Who is responsible for your information

Imbanerd Interactive Ltd, Level 2, 47 Triq id-Dejqa, Valletta VLT 1234, Malta, is the controller responsible for the personal information collected through imbanerd.com and the imbanerd game. Our data protection contact is Elena Marek, reachable at privacy@imbanerd.com, and is accountable for our compliance with this policy.

Because we are established in the European Union, our processing is subject to the EU General Data Protection Regulation (GDPR) and Maltese data protection law. Because we offer the Game to users in Canada, we also apply the Personal Information Protection and Electronic Documents Act (PIPEDA) to information about our Canadian users. Where the two regimes differ, we apply the standard more protective of you.

2. Scope

This policy explains what personal information we collect, why we collect it, what our legal basis is, who we share it with, how long we keep it, and the choices and rights you have. It applies to the website, the game, and our advertising.

3. What we collect

The Game has no accounts, so we collect far less than a typical site.

Age confirmation: a cookie recording that you confirmed you are 19 or older. It stores the fact of the confirmation, not a date of birth.
Gameplay information stored on your device: your virtual coin balance and in-game settings, held in your browser's local storage and not transmitted to us.
Technical information: IP address, approximate location derived from it (country and region, not precise location), browser and device type, operating system, language, and referring page, recorded in our server logs.
Support correspondence: messages you send us by email and our replies, including the address you write from.

We do not collect names, usernames, passwords, or dates of birth. We do not collect payment card details, because the Game is free and we do not process payments. We do not collect special categories of data, and we do not knowingly collect information from anyone under 19.

4. Why we collect it, and our legal basis

To run the Game and remember your progress on your device — necessary for the performance of our agreement with you (GDPR Art. 6(1)(b)).
To confirm that users meet the minimum age requirement — our legitimate interest in operating an adults-only service and compliance with advertising rules (Art. 6(1)(f) and (c)).
To keep the Service secure, prevent automated play and abuse, and investigate breaches of our Terms — our legitimate interest in the security of the Service (Art. 6(1)(f)).
To provide support — performance of our agreement and our legitimate interest in answering you (Art. 6(1)(b) and (f)).
To understand how the Game is used and improve it — your consent for any analytics cookies, and otherwise our legitimate interest in aggregated statistics (Art. 6(1)(a) and (f)).
To measure and optimise our advertising, including ads served through Google Ads — your consent (Art. 6(1)(a)).
To comply with legal obligations and respond to lawful requests — compliance with a legal obligation (Art. 6(1)(c)).

For our Canadian users, the same purposes are supported by your consent under PIPEDA, which may be express or implied depending on the purpose and the sensitivity of the information.

5. Withdrawing consent

Where we rely on consent, you may withdraw it at any time: through the cookie settings offered on the site for any analytics and advertising cookies, or by writing to privacy@imbanerd.com. Withdrawal does not affect processing carried out before it. The age confirmation cookie is strictly necessary — without it the Game cannot be shown to you at all.

6. Who we share it with

We do not sell your personal information. We share it only with processors acting on our behalf, under contract and only for the purposes described above:

hosting and infrastructure providers;
analytics providers, to measure use of the Game;
advertising platforms, including Google, to measure and optimise our campaigns;
email providers, for support correspondence;
professional advisers, and law enforcement or regulators where required by law.

7. International transfers

We are based in Malta and store information within the European Economic Area where possible. Some of our providers process information in third countries, including the United States. For such transfers we rely on an adequacy decision where one applies, or otherwise on the European Commission's Standard Contractual Clauses together with additional technical safeguards. Information about users in Canada is therefore processed outside Canada, and while it is in another country it may be accessible to the courts, law enforcement, and national security authorities of that country under its laws. You can ask us at privacy@imbanerd.com for details of the safeguards in place and where your information is held.

8. Cookies and local storage

We use strictly necessary storage to remember your age confirmation and to keep your coin balance on your device; the Service does not work without it, and it is set without consent as the law permits. Analytics and advertising cookies are optional and are set only after you allow them through a cookie banner; where we are not running them, none are set at all. You can change or withdraw your choice at any time, and you can block or delete cookies and site data in your browser — doing so resets your coin balance.

9. How long we keep it

The age confirmation cookie expires after 30 days. Coin balances and settings stay in your browser until you clear its storage, and are never held by us. Support correspondence is kept for 24 months. Server and technical logs are kept for 12 months, except where we must keep specific records longer to comply with a legal obligation or to establish, exercise, or defend a legal claim.

10. How we protect it, and breach notification

We use encryption in transit, access controls limiting staff access to what their role requires, and monitoring for unauthorised access. No system is completely secure. If a personal data breach occurs, we will notify the Information and Data Protection Commissioner in Malta within 72 hours where the breach is likely to result in a risk to your rights, and we will notify affected users directly where the risk is high. For our Canadian users we will also report to the Office of the Privacy Commissioner of Canada where the breach creates a real risk of significant harm.

11. Your rights

You may ask us to:

confirm whether we hold personal information about you and give you access to it;
correct information that is inaccurate or incomplete;
delete the information associated with you;
restrict our processing, or object to processing based on our legitimate interests;
provide your information in a structured, commonly used, machine-readable format, or transmit it to another controller;
withdraw your consent where we rely on it.

Write to privacy@imbanerd.com. We will respond within one month, and within 30 days for requests from Canadian users, and we do not charge a fee for a routine request. Because we hold no account records, we may need details such as the approximate dates and IP address of your visits to locate anything about you. We do not make decisions about you based solely on automated processing that would produce legal effects or similarly significant effects for you.

12. Complaints

If you are not satisfied with our response, you may complain to the Information and Data Protection Commissioner in Malta at idpc.org.mt. If you are in Canada, you may instead complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca, or to the privacy regulator of your province where one exists.

13. Children

The Service is for adults aged 19 and over. We do not knowingly collect information from anyone below that age. If you believe a minor has been using the Service, contact privacy@imbanerd.com and we will delete any information we hold.

14. Changes to this policy

We may update this policy. The current version is always available at imbanerd.com/privacy with its effective date. Where a change is material we will announce it on the site before it takes effect.

15. Contact

Elena Marek, Imbanerd Interactive Ltd, Level 2, 47 Triq id-Dejqa, Valletta VLT 1234, Malta · privacy@imbanerd.com