Privacy policy

Who is the controller

The data controller is Avendavi AB, a company registered in Sweden. You can reach our privacy contact at privacy@proprinse.com. A registered postal address and company number will be listed here in the reviewed version of this policy.

What data we collect

We process the following categories of personal data.

• Account data: your email address, optional display name, and login timestamps. We use email magic links, so we do not store passwords.
• Marketing capture: an email address and consent record when you opt in to a newsletter, deal alert, or to unlock the game.
• Attribution data: clicks on outbound firm links, an anonymous device identifier stored in a signed cookie, a hashed IP address, a hashed user agent, and the referring page. This lets us match a later purchase to your cashback or to a creator.
• Transaction data: conversions reported by a firm or network, commission amounts, cashback and creator earnings, and payout records. For payouts we use Stripe, including identity verification (KYC) handled by Stripe.
• Game and engagement data: guesses, streaks, leaderboard position, and raffle entries.

We do not intentionally collect special categories of data, and the service is not directed at children under 18.

Why we process it and the legal basis

• To provide your account and the service you request: performance of a contract (Article 6(1)(b)).
• To run attribution, cashback, and creator earnings: our legitimate interest in operating the affiliate model and paying you correctly (Article 6(1)(f)), and performance of a contract where a payout is due.
• To send newsletters and deal alerts: your consent (Article 6(1)(a)), which you can withdraw at any time.
• To prevent fraud and self dealing, secure the site, and keep records: our legitimate interest and our legal obligations (Article 6(1)(c) and 6(1)(f)).

Cookies and similar technologies

We use a small number of cookies, including a session cookie for login and a signed anonymous identifier for attribution. Optional analytics are privacy friendly and configured without cross site tracking. See our cookie policy for the full list.

Sharing and processors

We share data only as needed to run the service. This includes our hosting provider, our email delivery provider for magic links and opted in messages, our payments provider Stripe for payouts and KYC, and proprietary trading firms or their affiliate networks for the limited purpose of matching a referral to a purchase. Each acts as a processor or independent controller under a suitable agreement. We do not sell personal data.

International transfers

Where a provider processes data outside the European Economic Area, we rely on an adequacy decision or on Standard Contractual Clauses with appropriate safeguards. Details of each transfer will be listed in the reviewed version of this policy.

How long we keep data

We keep account data while your account is active and for a reasonable period afterwards. We keep transaction, commission, and payout records for as long as required by accounting and tax law in Sweden. Marketing data is kept until you withdraw consent or unsubscribe. Hashed attribution identifiers are retained only as long as needed to attribute conversions and resolve disputes.

Your rights

Under the GDPR you have the right to access your data, to rectify it, to erase it, to restrict or object to processing, to data portability, and to withdraw consent at any time without affecting prior processing. To exercise any of these, email privacy@proprinse.com. You also have the right to lodge a complaint with your local supervisory authority. In Sweden this is the Swedish Authority for Privacy Protection (IMY).

Changes

We may update this policy as the service evolves. Material changes will be highlighted on the site. This draft will be replaced once it has been reviewed.