Privacy Policy

Effective Date: February 19th 2025

Last Updated: March 10th, 2025

Welcome to Under the Stairs Limited website, a game development studio based in Croatia. We are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, and protect your personal information when you visit our website, play our games, or interact with our services. By using our services, you agree to the terms outlined in this policy.

This policy complies with the General Data Protection Regulation (GDPR) (EU 2016/679) and applicable Croatian data protection laws.

1. Who We Are

• Company Name: Under the Stairs Limited
• Registered Address: 5 Brayford Square, London, UK
• Email: contact@underthestairs.studio

If you have any questions about this Privacy Policy or how we handle your data, please contact us using the details above.

2. What Personal Data We Collect

We collect minimal data to improve our website and provide services. The only information we collect includes:

• Analytics Data: We use Google Analytics to gather anonymized data about website traffic, user behaviour, and interactions. This helps us understand how users engage with our website.
• Cookies: Our website uses cookies to enhance functionality and improve the user experience. These cookies may track anonymized usage data, such as pages visited, and time spent on the site.
• Newsletter Subscription: If you subscribe to our newsletter, we collect your email address to send you updates. This is managed through Mailchimp, which has its own privacy policies that you can read here.

3. How We Use Your Data

We process your data for the following purposes:

• To analyse website traffic and improve user experience (Google Analytics).
• To manage and send newsletters to subscribers (Mailchimp).
• To maintain the security and functionality of our website.

Legal Bases for Processing:

The General Data Protection Regulation (GDPR) require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

4. How Long We Keep Your Data

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy. Retention periods include:

• Contact Form Data: Up to 1 year after your last communication with us.
• Analytics Data: 14 months (Google Analytics default retention period).

You can request data deletion at any time (see Section 6).

5. Who We Share Your Data With

We never sell or trade your personal data. However, we may share data with:

• Mailchimp: Handles newsletter subscriptions and email communications. For more details, refer to Mailchimp’s Privacy Policy.
• Legal Authorities: If required by law or to protect our rights and safety.
• Google Analytics: Tracks anonymized user data. You can opt out via Google’s opt-out tools.

6. Your Rights Under GDPR

As an EU resident, you have the following rights:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Correct inaccurate or incomplete data.
• Right to Erasure (Right to be Forgotten): Request deletion of your data.
• Right to Restrict Processing: Limit how we use your data.
• Right to Object: Object to data processing for marketing or legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time (if processing is based on consent).

You can:

• Cookie Management: Disable cookies through your browser settings.
• Analytics Opt-Out: Use Google’s opt-out tools if you prefer not to be tracked.
• Unsubscribe from Newsletter: Each email we send includes an unsubscribe link.

To exercise your other rights, contact us at  contact@underthestairs.studio. We will respond within 30 days as required by GDPR.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences.
• Analyze website traffic and improve performance.
• Deliver personalized advertising (with your consent).

You can manage your cookie preferences via your browser settings.

8. Security Measures

We implement industry-standard security measures to protect your data, but please note that no online transmission or storage system is 100% secure.

9. Changes to This Privacy Policy

We may update this policy occasionally to reflect changes in our practices or legal requirements.  Any changes will be posted on this page with an updated effective date.

Last Updated: 10th March 2025

10. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

• Email: contact@underthestairs.studio