Legal
Privacy policy
Last updated
Draft template. This page has not been reviewed yet and is not legal advice. Check every section, fill in the bracketed parts, then setneedsReview: false in content/legal/privacy.md.
This policy explains what personal data we collect through our websites, fifthelementstudio.com and shattereddivide.fifthelementstudio.com, why we collect it, and what rights you have. We have tried to keep it short and in plain English.
Who we are
These websites are run by Keegan Mccormack trading as Fifth Element Studio, a sole trader based in the United Kingdom. We are the "controller" of your personal data under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
You can contact us about anything in this policy at info@fifthelementstudio.com.
[ICO registration number: add yours here if you are registered, or remove this line.]
What we collect and why
If you join the mailing list
- What: your email address, the date and time you signed up and confirmed, and whether you opened or clicked our emails.
- Why: to send you news about SHATTERED DIVIDE, including launch announcements.
- Lawful basis: your consent. You confirm it twice: by ticking the box, and by clicking the link in the confirmation email.
- How long: until you unsubscribe. Every email has an unsubscribe link, and you can also email us.
If you use the contact form or request a creator key
- What: your name, email address and message. For creator key requests, also your platform, channel link and audience size.
- Why: to read and reply to your message, or to decide whether to send you a key.
- Lawful basis: our legitimate interest in answering messages sent to us.
- How long: we keep these emails for up to [24 months] and then delete them, unless we need them for an ongoing conversation.
When you visit the site
- Analytics: we use Umami, which counts visits and a few events (such as clicks on "Wishlist on Steam") without cookies and without building a profile of you. We only see totals, not individuals. Lawful basis: our legitimate interest in understanding how the site is used.
- Spam protection: our forms use Cloudflare Turnstile to check that a real person is sending them. Turnstile looks at signals from your browser and your IP address for this check only. Lawful basis: our legitimate interest in keeping the site secure.
- Server logs and rate limits: our hosting providers process your IP address to deliver pages to you. Our own API does not record IP addresses in its logs. It holds them in memory for up to an hour to stop people sending too many messages.
Who we share it with
We use a small number of trusted services ("processors") to run the site. They only use your data to provide their service to us:
| Service | What it does | Where |
|---|---|---|
| Brevo (Sendinblue SAS) | Mailing list, and delivers contact form messages to our inbox | European Union |
| Cloudflare (Turnstile) | Spam protection on forms | Global |
| Umami | Cookieless visitor statistics | [Check region] |
| Netlify | Hosts the websites | Global, United States |
| Heroku (Salesforce) | Runs the form API | United States |
Where data is transferred outside the UK, we rely on the safeguards UK law allows, such as the UK Extension to the EU-US Data Privacy Framework or the UK International Data Transfer Addendum. [Check each provider's terms and update this paragraph.]
We never sell your data, and we never share it for advertising.
Embedded content
The trailer is hosted on YouTube and the store widget comes from Steam. Neither loads until you click to load it. Once you do, YouTube or Steam may collect data and set cookies under their own privacy policies.
Your rights
You have the right to:
- ask for a copy of the personal data we hold about you
- ask us to correct it
- ask us to delete it
- object to, or ask us to restrict, how we use it
- withdraw your consent at any time (for example, by unsubscribing)
- ask for your data in a portable format
To use any of these rights, email info@fifthelementstudio.com. We will reply within one month.
If you are unhappy with how we have handled your data, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. We would appreciate the chance to put things right first, so please contact us.
Children
The mailing list is for people aged [16] and over.
Changes to this policy
If we change this policy, we will update the date at the top of this page. If the change is significant, we will tell mailing list subscribers.