F Freebo

Privacy Policy

Last updated: December 17, 2025

1. Introduction

This Privacy Policy explains how Freebo (“the Bot”, “we”, “our”) processes personal data when you interact with the Bot on Discord. We aim to be transparent and comply with the EU General Data Protection Regulation (“GDPR”) and applicable Finnish data protection law.

2. Data Controller and Contact

Controller: Mika Raitanen

Email: [email protected]

3. Personal Data We Collect

The Bot may process the following data, only to the extent necessary to provide its features:

  • Discord User IDs
  • Discord Server (Guild) IDs
  • Channel IDs
  • Message content only when explicitly required (For moderation, giveaways, ticket system)
  • Bot usage and event metadata (e.g., timestamps of actions, feature usage) to operate and troubleshoot the service

The Bot does not intentionally collect:

  • Email addresses
  • IP addresses (unless automatically logged by our hosting provider; see Section 7)
  • Passwords
  • Special categories of data (sensitive data) unless you explicitly provide them in messages

4. Purposes and Legal Bases

We process personal data for the purposes below, based on the following GDPR legal bases:

Provide core bot functionality

Legal basis: Legitimate interests (GDPR Art. 6(1)(f)) — operating and maintaining the Bot as requested by server administrators and users.

Server-specific settings and moderation features

Legal basis: Legitimate interests (GDPR Art. 6(1)(f)) and/or performance of a contract-like service request (GDPR Art. 6(1)(b)) depending on the feature.

Security, abuse prevention, troubleshooting, and improving stability

Legal basis: Legitimate interests (GDPR Art. 6(1)(f)).

Legal compliance requests (if any)

Legal basis: Legal obligation (GDPR Art. 6(1)(c)) where applicable.

5. Data Sharing and Recipients

We do not sell personal data. We may share data only with:

  • Discord, as the platform provider (data is exchanged via Discord APIs as part of providing the service)
  • Our infrastructure providers (hosting, databases, monitoring) acting as processors: gamehoster.fi
  • Authorities where required by applicable law

6. International Transfers

We aim to host and process data within the EU/EEA. If any data is transferred outside the EU/EEA (for example, due to third-party infrastructure), we will rely on applicable transfer mechanisms such as adequacy decisions or Standard Contractual Clauses, and we will update this policy accordingly.

7. Data Storage, Security, and Retention

We use reasonable technical and organizational measures to protect data (e.g., access controls, secrets management, and least-privilege practices).

Retention: We retain personal data only as long as necessary for the purposes described above. Typical retention periods:

  • Configuration data (server settings): until removed by server admins or until the Bot is removed from the server
  • Operational logs (for security/troubleshooting): up to 3 years
  • Stored command/message content (if any feature stores it): only as needed for that feature, or until deletion is requested

8. Your Rights (GDPR)

Subject to applicable law, you have the right to request access, rectification, erasure, restriction, objection, and (where applicable) data portability. You can also withdraw consent where processing is based on consent.

To exercise your rights, contact us at [email protected]. We may need to verify your identity (e.g., by asking you to contact us from the same Discord account).

9. Complaints (Finland)

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Finnish supervisory authority, the Office of the Data Protection Ombudsman.

More information: tietosuoja.fi

10. Children’s Privacy

The Bot is not directed to children under 13. Use of Discord and the Bot must comply with Discord’s age requirements and Terms.

11. Third-Party Services

The Bot operates on Discord. Discord’s own processing of personal data is described in Discord’s Privacy Policy: discord.com/privacy

12. application's scope / automated decisions

The Bot does not use automated decision-making with legal or similarly significant effects (GDPR Art. 22). If features change in the future (e.g., profiling), we will update this policy.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top indicates when it was last revised.