Privacy Policy

This Privacy Policy explains how Aceberry Labs ("Aceberry", "we", "us" or "our") handles personal information when you visit our website, contact us, book a call, or otherwise interact with us in connection with our B2B services.

1. Who We Are

Aceberry Labs is an independent digital studio and business brand providing design, development, marketing, strategy and related B2B services, including services for gaming, iGaming, sports technology and other digital products.

Aceberry Labs is currently operated as an independent business brand rather than through a separate incorporated legal entity. The individual operating Aceberry Labs determines the purposes and means of the personal data processing described in this Policy and is the data controller for the purposes of applicable data protection law.

Privacy contact: helloaceberry@gmail.com

2. Scope of This Policy

This Policy applies to personal information processed through the Aceberry Labs website and in connection with enquiries, discovery calls, proposals and prospective or existing business relationships.

Aceberry Labs is a service provider to businesses. We do not operate an online casino or sportsbook through this website, accept bets, hold player funds, or provide gambling services directly to consumers.

3. Personal Information We Collect

Information you provide to us

If you email us, contact us through Telegram, book a call or otherwise communicate with us, we may receive information you choose to provide, including:

• your name and contact details;
• company name, role or professional information;
• project requirements, budget, timeline and business needs;
• messages, files or other content you send us;
• booking and scheduling details.

The website currently does not contain a direct contact form, so information is not submitted through a website form.

Website and technical information

When you load the website, our hosting and infrastructure providers may process technical information necessary to deliver and secure the site, such as your IP address, browser type, device information, request time and technical logs.

Analytics information

If you consent to analytics technologies, we may use Google Analytics 4, loaded through Google Tag Manager, to understand how visitors use the website. Depending on configuration, this may include pages and sections viewed, interactions with website elements, referral source, device and browser information, approximate location and pseudonymous identifiers.

Advertising and marketing information

If you consent to marketing technologies, we may use Meta Pixel or similar tools, which may also be loaded through Google Tag Manager, to measure advertising performance and, where enabled, support remarketing. These tools may receive information such as page visits, button interactions, browser identifiers, IP address, user agent and campaign identifiers.

Local storage

We use browser local storage to remember your cookie preferences and website theme choice. More information is provided in ourCookie Policy.

4. How and Why We Use Personal Information

Responding to enquiries and preparing proposals. We use information you provide to understand your request, communicate with you, assess project fit and prepare a proposal or take other steps you request before entering into a contract. Legal basis: steps taken at your request before entering into a contract and/or our legitimate interests in operating our business.

Managing business relationships. If we work together, we may process personal information necessary to provide services, manage the relationship, keep business records and communicate about the work. Legal basis: performance of a contract, legitimate interests and compliance with legal obligations.

Operating and securing the website. We process technical information to deliver the website, prevent abuse, troubleshoot issues and maintain security. Legal basis: our legitimate interests in operating a secure and reliable website.

Analytics. We use analytics to understand website performance and visitor behaviour. Legal basis: consent where required by applicable law.

Advertising and remarketing. We use marketing technologies to measure campaigns and, where enabled, reach relevant audiences. Legal basis: consent where required by applicable law.

Legal and compliance purposes. We may process information where necessary to comply with applicable law, respond to lawful requests, protect our rights, prevent fraud or establish, exercise or defend legal claims. Legal basis: legal obligation and/or legitimate interests.

5. Cookies and Similar Technologies

We use cookies, local storage, pixels and similar technologies. Strictly necessary technologies may operate without consent where permitted by law. Analytics and marketing technologies remain disabled until you consent where prior consent is required.

You can manage or withdraw your choices at any time through the Cookie settings link on the website. Withdrawing consent does not affect processing that occurred before withdrawal.

6. Service Providers and Other Recipients

We may share or make personal information available to service providers and other recipients where reasonably necessary for the purposes described above. These currently include:

• Google: Google Tag Manager, Google Analytics 4, email, calendar and related business services;
• Meta Platforms: Meta Pixel and advertising measurement;
• Cloudflare: website hosting, content delivery, security and access control;
• Telegram: when you choose to communicate with us through Telegram;
• professional advisers or contractors where reasonably necessary for our business;
• government, regulatory or law-enforcement authorities where disclosure is required by law.

We do not sell personal information for monetary payment.

7. International Data Transfers

Some service providers may process personal information outside the country where you are located, including in the United States. Where the GDPR, UK GDPR or another law requires safeguards for international transfers, we rely on an applicable legal transfer mechanism, such as an adequacy decision, the EU-U.S. Data Privacy Framework where applicable, Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another legally permitted mechanism.

8. Data Retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including legal, accounting and dispute-resolution needs. As a general rule:

• enquiries and ordinary business correspondence may be retained for up to 24 months after the last meaningful interaction;
• client, contractual, invoice and project records may be retained for longer where necessary for legal, tax, accounting or contractual purposes;
• Google Analytics event data is generally configured with a retention period of up to 14 months;
• cookie consent preferences are generally retained for approximately 12 months before we ask again;
• security and technical logs are retained for periods reasonably necessary for security and operational purposes.

We may retain information for longer where required by law or reasonably necessary to establish, exercise or defend legal claims.

9. Your Privacy Rights

Depending on your location and applicable law, you may have rights to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your information;
• request restriction of certain processing;
• object to certain processing based on legitimate interests;
• receive certain information in a portable format;
• withdraw consent at any time;
• object to or opt out of certain direct marketing or targeted advertising;
• lodge a complaint with the competent data protection authority.

To exercise a privacy right, email helloaceberry@gmail.com. We may need to verify your identity before completing certain requests. Where GDPR or UK GDPR applies, we normally respond within one month, subject to legally permitted extensions.

10. United States Privacy Rights

Residents of certain U.S. states may have additional privacy rights where the relevant state privacy law applies to Aceberry Labs. Depending on the law, those rights may include access, correction, deletion, portability and the ability to opt out of certain targeted advertising, sale or sharing of personal information.

We do not sell personal information for monetary payment. Where applicable law treats disclosure of online identifiers to advertising platforms as "sharing", "sale" or "targeted advertising", you may use Cookie settings to opt out. Where legally required, we will also honour qualifying browser-based opt-out preference signals, such as Global Privacy Control.

11. Automated Decision-Making

We do not use personal information collected through this website to make solely automated decisions that produce legal or similarly significant effects concerning you.

12. Children

This website is intended for business users and is not directed to children. We do not knowingly collect personal information from anyone under the age of 18 through this website. If you believe a child has provided personal information to us, please contact us so we can take appropriate steps.

13. Security

We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. The website is delivered using encrypted HTTPS connections. No method of transmission or storage can guarantee absolute security, so please avoid sending sensitive information that is not necessary for your enquiry.

14. Third-Party Websites and Services

Our website may contain links to third-party websites or services. Their processing of personal information is governed by their own privacy notices and practices. Aceberry Labs is not responsible for the privacy practices of third parties.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the website, technologies, business operations or legal requirements. When we make changes, we will update the "Last updated" date. Where legally required, we may provide additional notice or request renewed consent.

16. Contact

For questions, requests or complaints relating to this Privacy Policy or your personal information, contact:

Aceberry Labs, helloaceberry@gmail.com