Privacy Notice

1. Controller

Prio1 Oy, Business ID 2211129-7, Kytäjärvenkaari 20, 05720 Hyvinkää, Finland. Privacy requests: [email protected]. Telephone: +358 400 400 510.

This notice covers players, people who interact with shared Lines, people contacting us, and sponsor contact persons.

2. Data, purposes and legal bases

We receive information from you, your use of the service, Prio1 Login, our payment provider and other users who message, invite or report you. The bases below refer to GDPR Article 6: contract (1)(b), consent (1)(a), legal obligation (1)(c) and legitimate interests (1)(f).

Data: Sign-in email or identity reference, account links and sign-in times — Purpose and basis: Authenticate you through Prio1 Login and manage your account. Contract. SayNoWay keeps the link information needed for its own account; it does not store a password.

Data: Display name, drawn avatar, date of birth, derived age and adulthood status, chosen country, six profile words, optional city and introduction — Purpose and basis: Provide your player card and apply age limits. Contract. Sign-in details, name, avatar, date of birth, country and profile words are required to play; without them we cannot complete the account.

Data: Optional gender, consent record and gender-based room or matching choices you make — Purpose and basis: Display your chosen gender theme and apply the selected gender-based features. Consent. Where this reveals sexual orientation, explicit consent under Article 9(2)(a) also applies. You can play general modes without supplying gender and withdraw consent in Settings. Withdrawal removes the relevant data, including recovery copies, without removing the rest of your account. It does not affect earlier processing that was lawful.

Data: Room participation, answers, predictions, scores and necessary game state — Purpose and basis: Run the match and its immediate result display. Contract.

Data: Friend requests, friendships, notifications, messages and blocks — Purpose and basis: Provide communication and enforce contact choices. Contract; our legitimate interest in preventing unwanted contact also supports blocks.

Data: A Line you choose to share, its answer and guesses submitted through its link — Purpose and basis: Provide the requested sharing and guessing feature. Contract. This also applies to a link recipient who submits a guess without a player account.

Data: Credit balance, credit transactions, orders, amounts, currency, payment status and references — Purpose and basis: Supply purchases, reconcile payments and refunds, and maintain required financial records. Contract and accounting/tax obligations. Full card numbers and security codes are handled by Stripe, not stored by SayNoWay.

Data: Reports, relevant evidence, decisions and support/privacy correspondence — Purpose and basis: Handle requests, enforce rules, protect users and resolve disputes. Contract for account or purchase support; legal obligation for statutory notices and rights requests; legitimate interests in safety and establishing or defending claims.

Data: IP address, request address, browser information, event times, sign-in/security events and diagnostic error codes — Purpose and basis: Authenticate connections, prevent abuse and diagnose faults. Legitimate interests in security and service reliability.

Data: Campaign delivery/completion events used to make statistical totals — Purpose and basis: Measure delivery of sponsored rounds. Legitimate interest in confirming campaign delivery. Identifiable answers, messages and gender-based preferences are not supplied to sponsors or used to create advertising profiles.

The limited account-recovery copy is kept for our legitimate interest in preventing accidental irreversible loss. Consent-based fields require consent covering that storage and are removed if consent is withdrawn. Recovery data is not used for play or advertising.

3. Who can see or receive data

Tablemates see the information made available during play, including people you do not know at public tables. Your full player card is available to current tablemates during the match and to friends. Your date of birth is not displayed; your age in years is. An answer is revealed to the table through the game's reveal step. If you choose to share a Line, link recipients can see its answer after guessing. Messages are available to their participants, are stored on our server and are not end-to-end encrypted. Relevant content may be reviewed to handle a report or legal obligation.

Prio1 Login and Prio1 Pay are Prio1 Oy services under the same controller. External recipients include Hetzner (EU hosting), Cloudflare (network delivery, security and email routing), providers hosting and delivering our correspondence, and Stripe (payments). Processors act under data-processing agreements. Stripe also acts as an independent controller for its own payment, fraud-prevention and regulatory purposes; see Stripe's privacy notice (https://stripe.com/privacy).

Sponsors receive campaign statistics only where the output does not identify players; small or revealing results are withheld. We disclose necessary information to competent authorities when legally required. We do not sell personal data.

Our service is hosted in Germany. International service providers may process relevant data outside the EEA, including in the United States. Transfers use applicable adequacy decisions, including the EU–US Data Privacy Framework for transfers covered by a recipient's participation, or EU Standard Contractual Clauses and necessary additional safeguards where adequacy does not apply. Request details or a copy of the applicable safeguards at [email protected].

4. Retention and account deletion

Category: Account and profile — Retention rule: During the account relationship. Deleting the account disables it and hides the profile immediately. Only the profile, credit balance and minimum sign-in link needed for automatic recovery remain recoverable for 30 days, then are erased unless you restore the account. Consent-based fields also remain subject to withdrawal of consent.

Category: Friends, requests, blocks, notifications and messages — Retention rule: During the account relationship or until the relevant relationship/request is removed. On account deletion, social relationships and messages are removed, including messages from both participants' inboxes. They are not included in account recovery.

Category: Match data — Retention rule: Until the active match, its result display and necessary outstanding game commands have ended. It is then erased; it is not retained as a player-history archive. Records needed for an identified safety matter, pending social request or financial obligation follow the separate applicable rule, not indefinite whole-match retention.

Category: Shared Lines and guesses — Retention rule: Until the share is deleted, its link expires or the relevant account is deleted. A visitor's guess remains with that share unless erased earlier under an applicable request.

Category: Routine technical and sign-in logs — Retention rule: Up to 14 days. A relevant extract may be isolated for a specific active security matter and follows the case-retention rule below.

Category: Reports and correspondence — Retention rule: Until the request, investigation and any associated review are concluded. After that, only records required for an identified legal obligation or a specific, documented legal claim are retained, until the applicable obligation or limitation period ends. An unresolved status alone does not justify indefinite storage.

Category: Financial records — Retention rule: Records needed for the usable balance and pending transactions remain for those purposes. Accounting vouchers and transaction correspondence are retained for six years from the end of the calendar year in which the financial year ended; statutory accounting books and financial statements for ten years from the financial year end. Longer retention applies only where another applicable accounting or tax rule requires it. These periods do not apply indiscriminately to every game event.

Category: Disaster-recovery copies, where used — Retention rule: Rolling retention of no more than 30 days. They are restricted to recovery, and erasures are reapplied before restored data returns to normal use.

After deletion, necessary financial, safety and legal records may still identify you; their use is limited to those purposes. The 30-day recovery period is not an automatic delay for a valid statutory erasure request. A shared Prio1 Login identity may continue for other Prio1 services; a SayNoWay-only recovery link is removed when recovery ends unless a separate lawful purpose requires it.

Statistics may remain without a time limit only when they are genuinely anonymous.

5. Cookies and browser storage

We use browser storage for sign-in, sign-in security, connection recovery and settings you request. The sign-in cookie `snw_sid` lasts for the browser session, or up to 365 days if you choose to stay signed in. A sign-in security cookie, when needed, lasts up to 10 minutes. Current-room recovery data lasts for the browser tab. Sound and music settings you choose remain until changed or cleared; temporary navigation and tutorial state lasts for the session. You can remove stored settings in your browser; blocking necessary storage can prevent sign-in or play.

SayNoWay does not use advertising or third-party analytics tracking. Stripe's separate payment interface provides information about its own device storage and processing.

6. Your rights

Subject to the applicable conditions, you can request access and a copy, correction, erasure, restriction and portability of your personal data. Consent can be withdrawn at any time.

You can object, on grounds relating to your situation, to processing based on our legitimate interests.

Use Settings for the available controls or contact [email protected]. We respond without undue delay, normally within one month; if the law permits an extension, we explain it within that month. Requests do not require an active game account. You can complain to the Finnish Data Protection Ombudsman (https://tietosuoja.fi/en/home) or another competent supervisory authority.

7. Sponsor contacts

For business contacts we process names, work contact details, sign-in records, correspondence and campaign/order information received from the contact or their employer. Our legitimate interests are managing the business relationship and securing access; contract applies where the individual is the contracting party, and legal obligations apply to financial records. Operational contact data lasts for the business relationship and completion of outstanding matters. The financial, case, log, recipient, transfer and rights rules above also apply.