Privacy Policy

Effective date: May 14, 2025

1. Who is responsible for your information

Sense of Freedom co. Ltd, a company registered in England and Wales, registered office 28 Chesterton Rd, Cambridge CB4 3AZ, United Kingdom, is the controller responsible for the personal information collected through hgs-services.com and the Secret Fortune Island game. The person accountable for our compliance with this policy is Neal Parsons, Chief Executive Officer, reachable at neal6parsons@gmail.com.

Because we are established in the United Kingdom, our processing is subject to the UK General Data Protection Regulation and the Data Protection Act 2018. Because we offer the Game to users in Canada, we also apply the Personal Information Protection and Electronic Documents Act (PIPEDA), and, for users in Quebec, the Act respecting the protection of personal information in the private sector. Where these 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 marketing.

3. What we collect

Account information: email address, username, password (stored only as a cryptographic hash), age confirmation, and the date your account was created.
Gameplay information: virtual coin balance, spins, session times, bonuses granted, and your in-game settings.
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.
Cookies and similar technologies: identifiers used to keep you signed in, to remember your age confirmation, and to measure traffic and advertising performance. See section 8.
Support correspondence: messages you send us and our replies.

We do not collect payment card details, because the Game is free and we do not process payments. We do not collect special category data, and we do not knowingly collect information from anyone under 19, or under 18 in Quebec.

4. Why we collect it, and our legal basis

To create and operate your account and save your progress — necessary for the performance of our contract with you (UK GDPR Art. 6(1)(b)).
To grant the 2,000-coin welcome bonus and other bonuses, and to detect duplicate accounts and bonus abuse — performance of our contract and our legitimate interest in preventing abuse (Art. 6(1)(b) and (f)).
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 fraud and automated play, and investigate breaches of our Terms — our legitimate interest in the security of the Service (Art. 6(1)(f)).
To provide customer support — performance of our contract (Art. 6(1)(b)).
To understand how the Game is used and improve it — your consent for 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, 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 on the site for analytics and advertising cookies, through Settings for marketing messages, or by writing to neal6parsons@gmail.com. Withdrawal does not affect processing carried out before it. Where we need certain information to provide the Service at all, withdrawing consent may mean we can no longer keep your account open.

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 delivery providers, for account and service messages;
professional advisers, and law enforcement or regulators where required by law.

Our commercial partners referred to in the Affiliate Disclosure do not receive your personal information from us.

7. International transfers

We are based in the United Kingdom. Some of our providers process information in other countries, including the United States and countries in the European Economic Area. For transfers out of the United Kingdom we rely on UK adequacy regulations where they apply, or otherwise on the International Data Transfer Agreement or the UK Addendum to 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 neal6parsons@gmail.com for details of the safeguards in place and where your information is held.

8. Cookies

We use strictly necessary cookies to keep you signed in and to remember your age confirmation; the Service does not work without them, and they are set without consent as the law permits. Analytics and advertising cookies are optional and are set only after you allow them through our cookie banner. You can change or withdraw your choice at any time through the cookie settings on the site, and you can block or delete cookies in your browser.

9. How long we keep it

We keep account and gameplay information for as long as your account is open. After you close your account, or after 36 months of inactivity, we delete or anonymise it, except where we must keep specific records longer to comply with a legal obligation or to establish, exercise, or defend a legal claim. Support correspondence is kept for 24 months. Technical logs are kept for 12 months.

10. How we protect it, and breach notification

We use encryption in transit, hashed passwords, 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 Commissioner’s Office within 72 hours where the breach is likely to result in a risk to your rights, and we will notify you 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, and to the Commission d’accès à l’information du Québec where users in Quebec are affected.

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 your account and the information associated with it;
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;
stop the dissemination of your information or de-index a link giving access to it, where the law provides that right;
withdraw your consent where we rely on it.

Write to neal6parsons@gmail.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. We may ask you to verify your identity first. 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 Commissioner’s Office in the United Kingdom at ico.org.uk. If you are in Canada, you may instead complain to the Office of the Privacy Commissioner of Canada at priv.gc.ca, or, if you are in Quebec, to the Commission d’accès à l’information du Québec at cai.gouv.qc.ca.

13. Children

The Service is for adults aged 19 and over, or 18 and over in Quebec. We do not knowingly collect information from anyone below that age. If you believe a minor has created an account, contact neal6parsons@gmail.com and we will close the account and delete the information.

14. Changes to this policy

We may update this policy. The current version is always available at hgs-services.com/privacy with its effective date. Where a change is material we will notify registered users before it takes effect.

15. Contact

Neal Parsons, Chief Executive Officer, Sense of Freedom co. Ltd, 28 Chesterton Rd, Cambridge CB4 3AZ, United Kingdom · neal6parsons@gmail.com