Seya LLC — Privacy Policy

Effective Date: April 14, 2026

1. Controller Information

Seya LLC ("Seya", "we", "us", "our")

Address: Wyoming, United States

Email: legal@seya.llc

2. Scope Of This Policy

This Privacy Policy explains how we collect, use, disclose, store, and protect personal data when you use our websites, applications, APIs, dashboards, monetization products, and related services (collectively, the "Services").

This Policy applies to users, visitors, applicants, publishers, customers, partners, and support contacts.

By using the Services, you acknowledge this Policy.

3. Categories Of Personal Data We Process

A) Account and identity data

Email address and account identifiers

Username, profile settings, and login metadata

Verification-related data you provide

B) Application and operational profile data

Publisher application details and review outcomes

Configuration settings, traffic source declarations, and compliance flags

Account status history and internal risk notes

C) Financial and payout data

Payout method details and payment recipient data

Payout requests, transaction references, reversal events, and ledger records

Tax or compliance information required for lawful payment operations

D) Device, network, and technical data

IP address and derived location indicators

Browser, operating system, language, and device metadata

Session identifiers, rate-limit identifiers, and anti-abuse signals

E) Usage and analytics data

Event logs, timestamps, page/service interactions, and feature usage

Referral/source data and performance metrics

Aggregated or pseudonymized analytics measurements

F) Communications and support data

Messages sent to support or legal channels

Attachments, dispute records, and compliance correspondence

G) Cookies and similar technologies

Essential session/authentication cookies

Preference cookies

Security and anti-fraud cookies

Analytics or measurement technologies where enabled

4. Data Sources

We collect data:

Directly from you through forms, account actions, integrations, and communications.

Automatically from your device, browser, and interactions with the Services.

From service providers supporting hosting, authentication, payment, analytics, and security.

From partners or public/compliance sources when needed for fraud prevention, sanctions screening, or legal obligations.

5. Why We Process Personal Data

We process personal data to:

Provide, maintain, and improve the Services.

Authenticate users and secure accounts and systems.

Review eligibility and operate publisher or monetization programs.

Detect, prevent, and investigate fraud, abuse, and security incidents.

Process payments, payouts, accounting, and reconciliation.

Send operational, legal, and support communications.

Enforce our terms, protect rights, and comply with legal obligations.

Perform analytics, reliability monitoring, and product optimization.

6. Legal Bases (Where Applicable)

Where GDPR, UK GDPR, or similar laws apply, we rely on one or more lawful bases:

Contract necessity to provide requested Services.

Legitimate interests, including security, abuse prevention, service administration, and business continuity.

Legal obligations, including tax, accounting, sanctions, and lawful request compliance.

Consent where required, such as certain optional cookies or marketing activities.

7. Automated Decision-Making And Profiling

We use automated systems and risk rules to detect suspicious activity, enforce abuse controls, and protect platform integrity.

These controls may temporarily restrict sessions, transactions, or account actions.

Where required by law, users may request human review for significant decisions.

8. Cookies And Tracking Technologies

We use cookies and similar tools for:

Account login and session continuity.

Security controls and abuse prevention.

Service preferences and usability.

Performance and analytics.

You can adjust browser settings to block cookies, but some features may not function correctly.

Where required by law, non-essential tracking is subject to consent.

9. Data Sharing And Disclosure

We may share personal data with:

Hosting, infrastructure, security, and analytics vendors.

Identity/authentication, communications, and customer support providers.

Payment processors, banking, payout, and financial service providers.

Professional advisors (legal, compliance, accounting, auditors) under confidentiality protections.

Authorities, courts, regulators, and law enforcement where required or legally justified.

Corporate counterparties in mergers, acquisitions, financing, restructuring, or asset transfers, subject to applicable protections.

We do not sell personal data for monetary payment.

Where applicable law defines certain disclosures as "sale" or "sharing," we provide legally required opt-out mechanisms.

10. International Transfers

Your data may be processed in jurisdictions outside your own.

Where required, we implement appropriate safeguards, such as contractual clauses or equivalent lawful transfer mechanisms.

11. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, including:

Active account management and service delivery.

Fraud detection, security investigations, and platform integrity.

Financial reconciliation, tax, accounting, and audit obligations.

Legal defense, dispute handling, and regulatory compliance.

When retention is no longer necessary, we delete, anonymize, or securely isolate data according to applicable law.

12. Security Measures

We use technical and organizational safeguards proportionate to risk, including:

Access controls and role-based permissions.

Logging, monitoring, and abuse detection controls.

Encryption in transit and protective storage practices where appropriate.

Vendor due diligence and contractual security requirements.

No transmission or storage system is completely secure, and absolute security cannot be guaranteed.

13. Your Privacy Rights

Depending on your jurisdiction, you may have rights to:

Access personal data and receive a copy.

Correct inaccurate data.

Delete personal data, subject to legal exceptions.

Restrict or object to certain processing.

Data portability.

Withdraw consent where processing relies on consent.

Appeal denial of rights requests where required by law.

Lodge a complaint with a competent authority.

To exercise rights, contact legal@seya.llc.

We may request verification information before completing your request.

14. US State Privacy Disclosures

If you are in a US state with an applicable privacy law, you may have rights to know, access, correct, delete, and opt out of certain uses of personal data.

You may also have rights related to targeted advertising, profiling, or sensitive data processing, depending on local law.

We do not discriminate against users for exercising privacy rights.

Global Privacy Control (GPC) and Do Not Track:

Where legally required, we treat recognized browser-based privacy signals, including GPC, as valid opt-out requests for relevant processing.

Our systems may not respond to all legacy "Do Not Track" signals in jurisdictions where such handling is not legally mandated.

15. Children's Data

The Services are not intended for children under 18.

We do not knowingly collect personal data from children.

If you believe a child provided data, contact legal@seya.llc so we can investigate and take appropriate action.

16. Third-Party Services And Links

The Services may contain links to or integrations with third-party websites or products.

Those third parties operate under their own terms and privacy policies, and we are not responsible for their practices.

17. Data Incident Handling

We maintain internal procedures to identify, contain, assess, and respond to security incidents.

Where required by law, we provide notice to affected individuals, regulators, or counterparties.

18. Changes To This Policy

We may update this Privacy Policy to reflect legal, technical, operational, or business changes.

The revised version is effective when posted with an updated date unless stated otherwise.

19. Contact

Privacy and legal requests:

Seya LLC

Wyoming, United States

legal@seya.llc