1. About this policy

This Privacy & Cookie Policy explains how Filip Szafran Software Development, trading as Silent Clock Games ("we", "us" or "our"), processes personal data when you visit https://www.silentclockgames.com/ (the "Website"), contact us by email, or are considered or contacted for professional creator outreach.

The Website is an informational studio website. It does not provide user accounts, a newsletter subscription or an online contact form. Videos displayed on the Website are hosted through Wix rather than embedded from YouTube.

2. Who is responsible for your data?

The data controller is Filip Szafran Software Development, operating under the Silent Clock Games brand, at Jastrzębia 6/8/14, Wrocław, Poland.

You can contact the controller about privacy matters at contact@silentclockgames.com.

3. Personal data we process

3.1 Website delivery, security and technical operation

When you access the Website, Wix and the Website infrastructure may process technical information required to deliver and protect the Website. Depending on the request, this may include your IP address, browser and device information, operating system, referring URL, date and time of access, pages or resources requested, error and security logs, amount of data transferred, internet service provider and an approximate location derived from the IP address.

We process this information to display the Website, maintain its stability, prevent abuse, diagnose faults and protect the Website and its visitors. The legal basis is our legitimate interest in operating a functional and secure website under Article 6(1)(f) GDPR.

3.2 Wix Analytics

With your consent, Wix Analytics may collect information about how the Website is used. This can include page visits, session and usage information, navigation or click paths, referring sources, browser and device characteristics, screen resolution, timestamps and general geographic information.

This processing helps us understand Website performance and visitor interaction. The legal basis is your consent under Article 6(1)(a) GDPR. Wix Analytics remains enabled as part of the Wix platform. However, analytics cookies and other non-essential analytics technologies used for Wix Traffic and Behaviour reports are not activated for a visitor unless that visitor enables the Analytics category in the cookie settings. Wix may still process essential technical data necessary to operate and secure the Website. You may withdraw Analytics consent at any time through the privacy settings control displayed on the Website. Withdrawal does not affect processing that was lawful before withdrawal.

3.3 Consent management

We use Usercentrics to display the cookie banner, record your cookie preferences and demonstrate that consent was obtained or refused. Consent data may include the date and time of your visit and decision, your consent or refusal, and device information. Local storage or similar technology is used to remember your selection.

The legal basis is Article 6(1)(c) GDPR, in connection with our obligation to document consent, and Article 6(1)(f) GDPR, based on our legitimate interest in maintaining reliable compliance records. Consent data is normally retained for one year.

3.4 Email correspondence

The Website does not contain a contact form. If you choose to contact us directly by email, we process the information you provide, which may include your name, email address, organisation, message and any attachments.

We process this information to respond to your enquiry. Depending on its subject, the legal basis is Article 6(1)(f) GDPR, based on our legitimate interest in handling correspondence, or Article 6(1)(b) GDPR where the communication concerns a contract or steps requested before entering into a contract. Where records must be retained by law, Article 6(1)(c) GDPR applies.

3.5 Creator outreach and prospect records

To identify content creators who may be interested in our games, we use information made publicly available in a professional context. Sources include YouTube and Twitch profiles, channel pages, linked social-media or business websites, and public creator-discovery or analytics services. We may record a creator's name or public channel name, public business email address or contact route, profile and source URLs, audience size and public activity indicators, content focus, our assessment of relevance, outreach priority, contact status, dates of contact or planned follow-up, and responses or notes relating to the potential professional relationship. We organise this information in a creator-prospect spreadsheet and related business records.

We use these records to research suitable creators, avoid irrelevant or duplicate contact, manage individual review-key, editorial-coverage and collaboration proposals, and keep a record of responses. The GDPR legal basis for this research and record-keeping is our legitimate interest in promoting our games and developing relevant professional relationships under Article 6(1)(f) GDPR. We limit the records to professional information relevant to that purpose and do not purchase private contact lists. The GDPR legal basis does not remove any separate consent requirement imposed by electronic-communications law.

We direct outreach only to contact channels expressly presented for business, press, sponsorship or collaboration enquiries and only where the proposal is relevant to that invitation. Before sending a message, we assess whether applicable electronic-communications rules permit it; where prior consent is required, we send marketing communications only on the basis of such consent. At or before the first communication, we identify ourselves, explain the public source of the contact details where it is not already clear, and provide access to this policy. A creator may object at any time by replying to the message or emailing contact@silentclockgames.com. We then stop direct-marketing use of that creator's data and retain only the minimum information needed to honour the objection.

3.6 Wix-hosted video

Video content on the Website is delivered through Wix. Playing a Wix-hosted video may generate the same technical request and delivery data described in section 3.1. The Website does not use an embedded YouTube player, so playing the Website video does not intentionally transfer visitor data to YouTube or Google through an embedded player.

3.7 Is providing personal data required?

You are not legally or contractually obliged to visit the Website or provide personal data simply to browse it. Technical data necessary to establish a connection is transmitted automatically when you access the Website; without that processing, the Website or requested video may not be delivered correctly. Analytics is voluntary, and refusing or withdrawing consent does not prevent you from using the Website. Necessary preference data is processed to remember and apply your cookie choice, including refusal.

Providing information by email is voluntary. Without sufficient contact information and details of your enquiry, we may be unable to respond. If you ask us to take steps towards a contract, the information needed for those steps must be provided for us to proceed. Any statutory or contractual information requirements arising in that context will be explained when applicable.

Creators are not required to provide information to us or respond to outreach. Prospect information is obtained from public professional sources as described in section 3.5. A creator may remove or change a public contact channel at its source and may also ask us to correct or delete our record or object to outreach.

4. Cookies and similar technologies

The Website uses cookies and similar browser technologies. The current categories and services are displayed in the Usercentrics privacy settings available on the Website.

4.1 Essential technologies

Essential technologies support functions such as website delivery, security, network management and storage of your privacy preferences. They cannot be disabled through the cookie banner because the Website or requested privacy controls may not function correctly without them. They are not used by us for third-party advertising. We rely on the exemption for storage or access necessary for transmission or for a service requested by you under Article 399(3) of the Polish Electronic Communications Law (Prawo komunikacji elektronicznej). This exemption is separate from the GDPR legal bases described in section 3.

4.2 Analytics technologies

Wix Analytics remains enabled as a Wix platform feature, but analytics cookies and other non-essential analytics technologies used for Wix Traffic and Behaviour reports are optional and are not activated for a visitor until that visitor enables the Analytics category. Refusing Analytics does not prevent access to the Website. Consent to storing or accessing optional information on a visitor's device is obtained under Articles 399 and 400 of the Polish Electronic Communications Law; consent-based personal-data processing is described in section 3.2.

4.3 Managing your preferences

You can accept, reject or change optional cookie preferences through the Usercentrics banner and the privacy settings control available on the Website. You can also delete stored cookies and local storage through your browser settings. Browser deletion may cause the Website to ask for your preferences again.

The Usercentrics privacy settings form part of our cookie information and provide service and technology details, including providers, purposes and storage durations. You can reopen these settings at any time. Cookie or local-storage expiry is not necessarily the same as the retention period for information already sent to a provider; see section 7.

5. Service providers and recipients

5.1 Wix

The Website is created, hosted and delivered using services provided by Wix.com Ltd. Wix processes personal data on our behalf where it provides hosting, content delivery, security, analytics and video-delivery functions. Wix may also process limited information for its own lawful platform, security and service-administration purposes. More information is available in Wix's privacy policy at https://www.wix.com/about/privacy.

5.2 Usercentrics

Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany, processes consent data on our behalf to operate the cookie banner and document your choices. More information is available at https://usercentrics.com/privacy-policy/.

5.3 Business email, spreadsheet and research tools

We use Google Workspace for business email and related productivity functions. We also use OpenAI services for assisted creator research and for storing or working with creator-prospect files. These providers may process the public professional information, outreach records and correspondence described in sections 3.4 and 3.5 on our behalf under their applicable data-processing terms. Access is restricted to people and service providers who need it for these purposes. More information is available at https://policies.google.com/privacy and https://openai.com/policies/privacy-policy/.

5.4 Other disclosures

We may disclose personal data to professional advisers, email-hosting and technical service providers or public authorities where this is necessary to operate the Website, protect legal rights, comply with law or respond to a lawful request. We do not sell Website visitors' personal data.

6. International data transfers

Wix operates internationally. Website visitor data may be processed or stored in Ireland, Israel, the United States, South Korea and Taiwan, and in other locations used to deliver Wix services. Ireland is within the European Economic Area (EEA). For transfers outside the EEA, Wix relies on European Commission adequacy decisions where they cover the destination and recipient, including applicable transfers to Israel and South Korea. Taiwan is not covered by an EU adequacy decision. US adequacy applies only to recipients covered by the EU-US Data Privacy Framework. Where an adequacy decision does not cover the transfer, Wix states that it uses the European Commission's Standard Contractual Clauses, as set out in its Data Processing Agreement.

Usercentrics states that consent data for this service is stored in the European Union. Information about the providers' current processing locations and safeguards is available in their privacy and data-processing documentation.

Google and OpenAI operate internationally, and creator-prospect records or correspondence may be processed in the EEA, the United States or other locations used to provide their services. Where personal data is transferred outside the EEA, the transfer is based, as applicable, on an adequacy decision covering the recipient, the European Commission's Standard Contractual Clauses, or another safeguard permitted by Chapter V GDPR. Current information is available in the providers' privacy and data-processing documentation.

You can request information about the safeguards applicable to your data and a copy of those safeguards by emailing contact@silentclockgames.com. Copies may be redacted where necessary to protect confidential information or other persons' rights. Wix's transfer information and access to its Data Processing Agreement are available at https://support.wix.com/en/article/preparing-your-wix-site-for-the-gdpr.

7. How long we keep personal data

Technical and security data is retained for the period needed to deliver the Website, investigate faults or security incidents and prevent abuse. The criteria are the type of log, the troubleshooting or security issue involved, whether an investigation remains open, and any applicable legal preservation requirement. Routine data is deleted or anonymised when no longer needed for those purposes, subject to the retention controls available through Wix.

Analytics personal data is retained only while consent remains valid and the information is needed to assess Website traffic and behaviour, subject to Wix's available retention and deletion controls. The criteria are the reporting period being analysed, the level of detail needed and whether the information can be irreversibly anonymised. Browser technology durations are shown separately in the cookie settings. On withdrawal, future consent-based collection stops and personal data processed solely on that consent must be erased unless another lawful ground requires or permits its retention. Withdrawal does not make past lawful processing unlawful. Irreversibly anonymised statistics are no longer personal data.

Consent records are normally retained for one year. Ordinary email enquiries are generally retained for up to 12 months after the last substantive contact. Information may be retained longer where necessary to perform a contract, comply with accounting or other legal obligations, or establish, exercise or defend legal claims, but no longer than the applicable statutory period.

Creator-prospect records are reviewed at least annually and are normally deleted within 24 months after the last verification or substantive contact if no active professional relationship or campaign justifies keeping them. Records may be kept longer where needed to manage an ongoing collaboration, perform a contract or establish, exercise or defend legal claims. If a creator objects to direct marketing, we may retain a minimal suppression record, such as the relevant email address or channel identifier and the date of objection, for as long as reasonably necessary to avoid contacting that person again.

8. Your rights

Subject to the conditions in applicable data-protection law, you may request access to your personal data, correction of inaccurate data, deletion, restriction of processing and data portability.

Right to object

Where we process your personal data on the basis of legitimate interests, you have the right to object at any time for reasons relating to your particular situation. We will stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is necessary to establish, exercise or defend legal claims. Where personal data is processed for direct marketing, including creator outreach, you may object at any time without giving a reason. Once you object, we will no longer process the data for direct-marketing purposes, except to retain the minimum suppression information needed to honour your choice. To object, reply to an outreach message or email contact@silentclockgames.com.

How to exercise your rights

Where processing is based on consent, you may withdraw that consent at any time. To exercise your rights, contact contact@silentclockgames.com. We may need to request information reasonably necessary to verify your identity before fulfilling a request. We respond without undue delay and normally within one month. If a lawful extension is necessary because of the complexity or number of requests, we will explain it within that month. Requests are normally free of charge.

You also have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland, at https://uodo.gov.pl/. You may also complain to a competent supervisory authority in the EU Member State of your habitual residence, place of work or the alleged infringement.

9. Automated decision-making

We do not use personal data collected through the Website, email correspondence or creator outreach to make decisions that produce legal effects or similarly significant effects through solely automated processing. We may use public professional information to organise or rank the relevance of creator prospects for manual review, but this does not produce legal or similarly significant effects for those creators.

10. External links

The Website may contain ordinary links to external services, including Steam and social-media websites. A link does not load the external service merely because it appears on the Website. If you follow a link, the destination service will process information under its own privacy policy and cookie settings. We are not responsible for the privacy practices of independent third-party websites.

11. Children and young visitors

The Website does not offer accounts, newsletter registration or submission forms for children. We do not knowingly request personal information directly from children, and creator outreach is not intentionally directed to children. Technical data may nevertheless be processed when any visitor accesses the Website, as described above. Where parental authorisation is required by applicable law for consent-based processing, optional Analytics must not be enabled without that authorisation. A parent or guardian who believes a child's personal data has been processed unlawfully can contact contact@silentclockgames.com so that we can investigate and take appropriate action.

12. Changes to this policy

We may update this policy when the Website, its services or legal requirements change. The current version will be published on the Website with an updated revision date. Material changes may also be highlighted on the Website where appropriate. If we intend to process existing personal data for a new purpose, we will provide the required information before doing so and obtain fresh consent where required.

13. Contact

Questions about this policy or the processing of your personal data can be sent to:

Filip Szafran Software Development
Trading as Silent Clock Games
Jastrzębia 6/8/14, 53-148, Wrocław, Poland
Email: contact@silentclockgames.com