Privacy Policy

Effective date: 1 January 2026

Aurora Reels OY ("Aurora Reels", "we", "us") is the data controller for personal data processed through the Aurora Reels website (frostreels.com). This Policy explains what data we collect, why we collect it, how long we keep it, and the rights you have under the EU General Data Protection Regulation (GDPR) and the Finnish Data Protection Act (1050/2018).

1. Data we collect

We collect the minimum data required to operate the Service:

• Browser identifiers — user-agent string, viewport, language, and screen dimensions. Used to render the site correctly and to distinguish automated traffic from human visitors.
• Network information — your IP address and coarse geolocation derived from it (country / region only). Used for security, fraud prevention, and to comply with jurisdictional access controls.
• Session cookies and local storage — a small amount of state used to remember your age verification, your virtual coin balance, and your session across page loads. We do not use tracking cookies for third-party advertising.
• Contact form submissions — if you use the contact form, we retain the name, email, and message you provide in order to respond.

2. Legal basis (GDPR Art. 6)

We process browser and network information on the basis of our legitimate interest (Art. 6(1)(f)) in operating and securing the Service. Contact form data is processed on the basis of your consent (Art. 6(1)(a)) and to take steps at your request prior to entering into a service relationship.

3. Third parties

Aurora Reels does not sell personal data. We do not share personal data with third-party advertising networks. Data is disclosed to third parties only in the following limited circumstances:

• to payment processors — only in connection with the alternative free method of entry (AMOE) postal programme, where mail handling and reply postage may be outsourced;
• to infrastructure providers (hosting, DDoS protection) that process data on our behalf under a data processing agreement;
• to competent authorities when required by law.

4. Retention

Access logs, IP data, and browser identifiers are retained for a maximum of twelve (12) months, after which they are aggregated or deleted. Contact form submissions are retained for the duration required to respond and for a maximum of twenty-four (24) months thereafter for quality assurance. Local storage entries (age gate flag, coin balance) live on your device and can be cleared by you at any time through your browser settings.

5. Your rights

Under the GDPR you have the right to:

• request access to personal data we hold about you;
• request rectification of inaccurate data;
• request erasure of your data ("right to be forgotten");
• request portability of data you have provided to us in a structured format;
• object to processing based on our legitimate interests;
• withdraw consent at any time, without affecting the lawfulness of prior processing;
• lodge a complaint with the Finnish Data Protection Ombudsman (tietosuoja.fi).

6. Cookies

Aurora Reels uses only strictly-necessary and functional cookies (age gate, coin balance, session identity). We do not use analytics or advertising cookies. As these cookies are essential to the operation of the site, no consent banner is required under the ePrivacy Directive as implemented in Finland.

7. Security

We apply industry-standard technical and organisational measures to protect personal data, including TLS-encrypted transport, restricted access controls, and periodic security review of our infrastructure. No method of transmission over the internet is completely secure and we cannot guarantee absolute security.

8. Contact for data requests

To exercise any of the above rights, email [email protected] or write to Aurora Reels OY, Bulevardi 12, 00120 Helsinki, Finland. We aim to respond within thirty (30) days of receiving your request.

9. Changes to this policy

We may revise this Policy from time to time. Material changes will be indicated by updating the "Effective date" above and, where appropriate, by a prominent notice on the site.