Privacy Policy
1. Who We Are & Data Controller Identity
Games4ALiving ("we", "us", or "our") is the data controller responsible for processing your personal data in connection with the services available at games4aliving.com (the "Service").
Registered address:
Carrer Roc Boronat 122, 08018 Barcelona, Catalonia, Spain
For general privacy inquiries:
Email: [email protected]
Postal: Privacy Team, Games4ALiving, Carrer Roc Boronat 122, 08018 Barcelona, Spain
1.1 Data Protection Contact
As a small independent studio, we handle data protection matters directly. For any questions relating to personal data processing and your data subject rights, please contact:
- Name: Manel Sort
- Email: [email protected]
- Address: Carrer Roc Boronat 122, 08018 Barcelona, Spain
2. Scope of This Policy
This Privacy Policy applies to all personal data collected through:
- Our website at games4aliving.com and any subdomains;
- Our games and related downloadable content;
- Communications between you and us (email, contact forms);
- Newsletter and blog subscription activities.
It does not apply to third-party websites linked from our Service (including itch.io, our game distribution platform). We encourage you to review those parties' privacy policies.
3. Personal Data We Collect
3.1 Data You Provide Directly
| Category | Examples | When Collected |
|---|---|---|
| Identity data | First name, last name | Contact forms, newsletter sign-up |
| Contact data | Email address | Contact forms, newsletter sign-up |
| Communications data | Support emails, contact messages | Contact form submissions, direct email |
| Marketing preferences | Newsletter opt-in/opt-out status | Newsletter sign-up, unsubscribe actions |
3.2 Data Collected Automatically
| Category | Examples | Source |
|---|---|---|
| Technical data | IP address, browser type, OS, device type | Server logs |
| Usage data | Pages visited, session duration, referral source | Analytics cookies (consent-gated) |
| Cookie & consent data | Cookie consent record, preferences | Cookie consent system |
3.3 Special Category Data
We do not intentionally collect or process special categories of personal data (Article 9 GDPR). Please do not submit such data through our Service.
4. Legal Bases & Purposes for Processing
Under Article 6 GDPR, we rely on the following legal bases:
| Purpose | Legal Basis (Art. 6 GDPR) | Data Categories Used |
|---|---|---|
| Respond to contact form messages | Legitimate interests (6(1)(f)) | Identity, contact, communications |
| Send newsletter and studio updates | Consent (6(1)(a)) | Identity, contact, marketing preferences |
| Improve our website via analytics | Consent (6(1)(a)) | Technical, usage |
| Comply with legal obligations | Legal obligation (6(1)(c)) | As required |
5. Data Sharing & Third-Party Processors
We do not sell your personal data. We share data only as described below, under appropriate contractual safeguards (Data Processing Agreements per Article 28 GDPR).
- Hosting provider: Our website hosting infrastructure — service delivery and data storage, protected by standard contractual clauses;
- Email service provider: Newsletter delivery — DPA in place;
- Analytics provider: Website analytics (consent-gated) — pseudonymised data, SCCs;
- itch.io: Game distribution platform — governed by itch.io's own privacy policy;
- Professional advisors: Legal, accounting — bound by confidentiality obligations;
- Law enforcement / regulators: Only when required by legal obligation or court order.
6. International Data Transfers
We are established in Spain (EU). Some of our service providers may process data outside the EEA. Wherever personal data is transferred outside the EEA, we ensure adequate protection using Standard Contractual Clauses (SCCs) per Article 46(2)(c) GDPR or adequacy decisions issued by the European Commission.
7. Data Retention
| Data Category | Retention Period | Basis |
|---|---|---|
| Contact form messages | 3 years from last interaction | Legitimate interests |
| Newsletter subscribers | Until consent withdrawn, plus 1 year | Consent + legal proof |
| Analytics data | 26 months (or as configured) | Legitimate interests |
| Server logs | 12 months | Legitimate interests (security) |
8. Your Data Subject Rights
Under the GDPR (Articles 15–21), you have the following rights regarding your personal data:
Right of Access (Art. 15)
Request a copy of all personal data we hold about you, along with information about how it is processed.
Right to Rectification (Art. 16)
Request correction of inaccurate or incomplete personal data we hold about you.
Right to Erasure (Art. 17)
Request deletion of your personal data where there is no compelling reason for continued processing.
Right to Restriction (Art. 18)
Request that we restrict processing of your data in certain circumstances.
Right to Data Portability (Art. 20)
Receive your personal data in a machine-readable format where processing is based on consent or contract.
Right to Object (Art. 21)
Object to processing based on legitimate interests and to direct marketing at any time.
Right to Withdraw Consent
Withdraw any consent you have given at any time, without affecting the lawfulness of prior processing.
8.1 How to Exercise Your Rights
Submit a request by:
- Email: [email protected] with subject line "Data Subject Request";
- Post: Games4ALiving, Attn: Privacy Team, Carrer Roc Boronat 122, 08018 Barcelona, Spain.
We will respond within 30 days. We may need to verify your identity before processing your request.
8.2 Right to Lodge a Complaint
If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the data protection supervisory authority. In Spain, the lead supervisory authority is:
- Agencia Española de Protección de Datos (AEPD) — www.aepd.es
We ask that you contact us first so we can try to resolve any concern directly.
9. Data Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, or alteration, including:
- Encryption of data in transit (TLS);
- Access controls and principle of least privilege;
- Regular software updates and security monitoring;
- Incident response procedures.
10. Cookies & Tracking Technologies
We use cookies and similar tracking technologies on our website. For detailed information, please see our Cookie Policy. You can manage your cookie preferences at any time via the cookie banner at the bottom of any page.
11. Children's Privacy
Our website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data without parental consent, please contact us at [email protected] and we will promptly delete it.
12. Third-Party Links
Our Service contains links to third-party websites including itch.io. We are not responsible for their privacy practices. We encourage you to review their privacy policies when you leave our Service.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post a notice on our website and update the "Last updated" date at the top of this page.
14. Contact Us
For any questions relating to this Privacy Policy or the processing of your personal data, please contact:
- Data Controller: Games4ALiving
- Email: [email protected]
- Postal Address: Carrer Roc Boronat 122, 08018 Barcelona, Spain
- Website: games4aliving.com