Privacy policy

Who is the controller

Ivory Games LLC, 30 N Gould St, STE R, Sheridan, WY 82801, United States, is the data controller for this website. For any question about your data, or to exercise any of the rights below, write to show email address.

What we collect

• What you enter in a form: your name, email address, and — only if you choose to give it — a phone number.
• The optional answers you give on the second step of a form, such as your timeline, nationality, budget or the area you are looking in.
• Anything you write to us by email.
• A record of each page view: the path of the page, the domain that referred you, the country and region you are connecting from, the family of browser and operating system, a rough width band for your screen and whether you are on a phone, tablet or computer. The country is worked out from your IP address and the address is then discarded; to count unique visitors, only a one-way daily fingerprint is kept, made with an ingredient that is thrown away every 24 hours, so nothing stored can be tied back to you. No cookie or identifier is placed on your device, and nothing is collected at all if your browser sends a Do Not Track or Global Privacy Control signal.
• When you send a form, create a retirement plan or ask to list your business: the IP address you connected from, your browser’s identification string (the “user agent”) and the approximate location — country, region, city — that a geolocation service derives from that address. They are kept with your request, and deleted with it, so that we can tell a genuine enquiry from an automated one, investigate abuse, and know roughly where and in which time zone to reach you.
• Four events about how our forms are used — a form was seen, opened, completed, or its optional second step answered — with the page, the language and which form. These tell us where people give up on a form; they contain nothing you typed.
• If you create a retirement plan: the answers you choose to give it (who is moving, which country you are moving from, roughly when, where in Spain, and the optional questions inside the plan), which steps you have marked done, skipped or not applicable, and any private note you write on a step. Every one of those answers is optional and can be skipped.
• A handful of events about your own plan — a plan was created, a question answered or skipped, a step changed status, an email was sent — so we can see which parts of the plan people find useful. They record which question, never what you answered.
• If you invite a partner to your plan, their first name and email address. We use them to send that one invitation and to know who else can open the plan, and for nothing else. Anyone invited can write to us and we will remove their address.

What we do not collect

We do not use advertising cookies, analytics cookies, social plugins, session replay or fingerprinting, and nothing about you is stored on your device by our measurement. The only cookies this site sets are the two that keep you signed in to your own retirement plan, described below; they are strictly necessary for a service you asked for, which is why you are not being asked to accept anything.

The form events described above are processed by our own measurement platform, operated by us on servers in the European Union — no third-party analytics vendor receives them. It works without cookies or local storage, without session recording, without automatic capture of clicks and keystrokes, and with IP addresses discarded rather than stored — it receives only the named events we chose to send. It is switched off entirely if your browser sends a Do Not Track or Global Privacy Control signal.

To stop automated abuse of our forms we also hold a one-way hash of the connecting IP address in the server’s memory for one hour, used only to rate-limit. That hash is never stored on disk or shared; it is separate from the copy of the address kept with a request you actually sent, described above.

Storage on your own device

If you complete a form, your browser keeps your name, email and phone number locally so you do not have to type them again elsewhere on the site. This stays on your device, is never read by anyone else, and clearing your browser data removes it. You can also click “Not you?” on any form to clear it.

Your retirement plan

A retirement plan has no password. Instead, two cookies are set when you create one and cleared when you sign out. The first identifies your plan, is signed so it cannot be edited, cannot be read by any script on the page, and lasts a year — that is what stops us asking you to sign in on every visit. The second holds only your first name and how far along your plan is, so the top of the page can greet you without slowing the site down for everybody else.

If you open your plan on another device we email you a link that signs you in. That link works once and expires after 30 minutes. We store no password, so there is none to lose.

Everything in your plan is yours to change. Any answer can be given, changed or skipped at any time, and any step can be marked as not applying to you. Ask us and we will delete the whole plan.

If you asked us to email you your plan and next steps, we write when your plan has something to tell you: a step whose usual time has come round, a quarter of the way through, or a month gone by with work already due. Never more than one email a fortnight, and never a newsletter.

Every one of those emails carries a link that stops them, and most email programmes also show their own unsubscribe button beside our name. Stopping them never affects the sign-in link — being unsubscribed must not lock you out of your own plan. There is no tracking pixel in anything we send: we do not know whether you opened it, and we have chosen not to find out.

Why we are allowed to hold it

• Your consent, and the steps you asked us to take before entering a contract, for anything you submit through a form (Article 6(1)(a) and (b) GDPR).
• Performance of the service you asked for, for the plan itself and the sign-in cookie that keeps it open (Article 6(1)(b) GDPR).
• Your consent, for the plan emails — which is why the box is there to untick, and why one click in any of them stops them (Article 6(1)(a) GDPR).
• Our legitimate interest in keeping the site working and free of automated abuse, for the pageview record and the temporary anti-spam hash (Article 6(1)(f) GDPR).

Who we share it with

When you ask to be matched with a lawyer, insurance broker, tax adviser or housing specialist, we pass your enquiry to a professional who can answer it, and only for that enquiry. If you have not asked for an introduction, nothing is passed to anyone.

Three suppliers process data on our behalf and on our instructions only: an email provider, to send and receive mail; a network provider (Cloudflare), which carries traffic between your browser, this website and our platform; and the analytics processor described above. We do not sell, rent or trade your details, and we do not add you to any marketing list you did not ask for.

Where your data is

Everything you send us through a form, and the record we keep of our contact with you, is stored on servers located in Spain, inside the European Union. Since 2026-08-24, enquiries and our record of contact with you are managed on our own operations platform, which runs on a separate server, also in Spain. Your email address is stored encrypted on that platform. Traffic between this website and that platform travels over the network of Cloudflare, Inc., a US company certified under the EU–US Data Privacy Framework.

Ivory Games LLC is registered in the United States, so the people operating the site may access this data from outside the European Economic Area. Where that happens it is on the basis of your consent and because it is necessary to answer the request you made (Article 49(1)(a) and (b) GDPR).

How long we keep it

Enquiries are kept for up to 24 months after our last contact with you, and then deleted. Pageview records are kept for up to 12 months. A retirement plan is kept while you are using it: after 24 months with no sign of you it is archived and your details are erased from it — your name, your email address, your phone number, your partner’s name and address, and any private note you wrote on a step. What is left is the shape of the plan with nobody attached to it. If you ask us to delete anything sooner, we do.

Your rights

You can ask us for a copy of your data, to correct it, to delete it, to restrict or object to how we use it, to receive it in a portable form, and to withdraw your consent at any time. Write to show email address and we will answer within 30 days. There is no charge.

If you are not satisfied with our answer, you can complain to the data protection authority where you live — in Spain the AEPD, in Germany your Landesdatenschutzbehörde, in France the CNIL, in the United Kingdom the ICO.

Changes

If this policy changes, the date at the top of the page changes with it. We will not start using data we already hold for a new purpose without asking you first.