Privacy Policy

1. Data controller and contact

Minilagedi OÜ is the data controller responsible for the processing described here.

Our registered details can be checked in the Estonian Business Register.

2. Data we process and why

Newsletter details

Your email address, subscription and confirmation status, relevant timestamps, consent records and delivery events, including bounces, complaints and unsubscribes. We use these to verify and manage subscriptions and send the updates you requested. Newsletter marketing is based on your consent (GDPR Article 6(1)(a)). We retain limited consent and suppression records where necessary to demonstrate permission and respect opt-outs, based on our legitimate interests in accountable mailing and preventing unwanted messages (Article 6(1)(f)), or a specific applicable legal obligation (Article 6(1)(c)).

Technical and security information

Website and form providers process information such as IP addresses, request times and URLs, browser/device information and security signals. EmailOctopus may associate a subscription IP address and approximate location with a contact. reCAPTCHA evaluates browser and interaction signals to detect automated abuse. We rely on legitimate interests in providing the website and the signup form you request, and protecting them against abuse (Article 6(1)(f)), subject to your rights and interests.

Messages you send us

Your email address, message content and any information you choose to include. We use these to answer enquiries, manage subscription requests and exercise or defend legal rights, based on legitimate interests (Article 6(1)(f)). Handling statutory privacy requests is also necessary to comply with our legal obligations (Article 6(1)(c)). Please avoid sending unnecessary sensitive information.

We receive information directly from you and from the providers involved in delivering the website, form and emails. We do not use this landing page for advertising profiles or decisions producing legal or similarly significant effects.

3. Newsletter and EmailOctopus

Our newsletter contains game news, development updates, exclusive previews, release announcements and occasional communications about TDP Zero: Purgatory. Subscribing is voluntary; you can view the website without subscribing or loading the form.

We use EmailOctopus, operated by Three Hearts Digital Ltd in the United Kingdom, to store the mailing list and manage subscriptions and email delivery. The form asks for your email address and an unchecked consent checkbox. Submitting it requests a confirmation email. You join the active mailing list only after clicking the confirmation link. This double opt-in is our chosen verification method, rather than a universal legal requirement.

You can withdraw consent at any time using the unsubscribe link in a newsletter or by writing to updates@tdpzero.io. You can also request deletion there. Withdrawal does not affect processing that was lawful before withdrawal. An unsubscribe stops marketing; it does not necessarily erase limited records needed to respect that choice or meet legal obligations.

No newsletter campaigns have been created at this pre-launch stage. EmailOctopus enables open tracking (using pixels) and click tracking (using tracked links) by default for new campaigns and automated emails. We plan to send newsletters without these features and will check and disable both before sending each campaign or activating an automated email. Subscription confirmations, delivery, bounce, complaint and unsubscribe events are processed separately to operate the mailing list.

4. Service providers and international transfers

• Cloudflare provides the domain's DNS and email forwarding and is our selected static website hosting, content delivery and security provider. Its global infrastructure processes request and security data. It forwards messages sent to updates@tdpzero.io to the operator's Gmail mailbox. See its privacy notice and data processing addendum.
• EmailOctopus processes mailing-list information on our behalf. It reports primary contact-list storage in Ireland and uses delivery, security and support subprocessors that may process data elsewhere, including the United States. Its data processing terms, privacy notice and current subprocessor list describe these arrangements.
• Google provides reCAPTCHA through the EmailOctopus form to prevent spam and automated abuse. The embed also requests Google Fonts and EmailOctopus-hosted fonts and branding assets. Separately, Gmail receives and stores messages sent to our contact address. Google may process data outside the EEA. See reCAPTCHA's data-processing information, its Cloud Data Processing Addendum and Google's privacy policy for services such as Gmail and Google Fonts.

We do not sell your personal data. Authorised operators and these providers receive information as needed for their services. We may also disclose information when required by law or necessary to establish, exercise or defend legal claims.

Data is not guaranteed to remain within the EEA. Transfers to countries covered by an applicable European Commission adequacy decision may rely on that decision. Other restricted transfers require appropriate safeguards, such as the EU Standard Contractual Clauses and any necessary supplementary measures. Cloudflare's addendum includes EU clauses; EmailOctopus's terms describe UK adequacy and safeguards for onward transfers. The safeguard applicable to a transfer depends on the provider, receiving entity and service. Contact us for information about relevant safeguards and how to obtain a copy.

5. Cookies, external resources and your choice

The landing page's own code sets no cookies or local-storage identifiers. Video, music and the game logo are served with the website. We have not installed website analytics, advertising pixels or social-media embeds. Links to other websites open those services only when followed.

The external newsletter form loads when you open Updates. It then contacts EmailOctopus, Google reCAPTCHA and font/asset hosts. These requests disclose technical information even if you do not submit your email. Google documents reCAPTCHA security storage, including _GRECAPTCHA / _grecaptcha identifiers; other Google cookies already present in your browser may also be involved. Actual storage and duration depend on the service and your browser. Opening the form does not subscribe you: newsletter marketing requires the separate unchecked consent box and email confirmation.

You can browse the website and read this policy without opening Updates. Once loaded, the form remains initialised in the current tab, including when you close its dialog or navigate to this policy using the site's links. Reloading the page stops that instance; it will load again only if you reopen Updates. Reloading cannot erase information already sent or third-party cookies; those can be managed through your browser. You can also email us about subscribing.

Cloudflare may use security cookies when its protection features require them. See Cloudflare's cookie information. No site-wide optional-cookie banner is currently used. If we introduce non-essential tracking, we will update this policy and obtain consent where required before activating it.

6. How long we keep data

• Active subscriptions: while you remain subscribed and we continue the relevant newsletter purpose.
• Unconfirmed requests: only as needed to complete or resolve confirmation, prevent abuse and administer pending requests; they are not active newsletter recipients.
• Withdrawn subscriptions and consent records: limited information where necessary to honour opt-outs, demonstrate consent or handle legal claims, rather than continue marketing.
• Enquiries and privacy requests: as needed to answer and resolve the matter and satisfy applicable legal obligations or claims.
• Security and service logs: according to the relevant provider's applicable settings and retention rules, and as necessary to investigate abuse or incidents. Provider backups may retain deleted information until their normal deletion cycle completes.

Retention depends on the purpose, necessity, account settings and applicable obligations. We do not promise a single fixed retention period for all records. Contact us about deletion or the retention applicable to your information.

7. Your rights

Subject to the GDPR's conditions and exceptions, you can request access, correction, erasure, restriction of processing and data portability where applicable. You can object to processing based on legitimate interests and object at any time to direct marketing. You can withdraw consent without affecting the lawfulness of earlier processing.

Contact updates@tdpzero.io. We may need proportionate information to verify your identity. We normally respond within one month; the GDPR permits an extension for complex or numerous requests, in which case we will explain it within that first month.

You can complain to Estonia's supervisory authority, the Data Protection Inspectorate (Andmekaitse Inspektsioon), or another competent authority, including in the EU country where you live or work or where an alleged infringement occurred.

8. Children and minors

The newsletter is for people interested in the game's development who can give valid consent under applicable law. We do not operate an age-verification system. Where parental authorisation is required, a child should not subscribe independently; a parent or guardian should contact us. If you believe a child has subscribed without required authorisation, contact us so we can investigate and remove the information where appropriate.

9. Security and changes to this policy

We use measures appropriate to the information and risks, including limiting access to people who need it and using managed hosting and mailing services. The public website and provider connections are intended to use HTTPS. No method of transmission or storage is completely secure.

We may revise this policy when our services or processing change. The revision date appears above. We will provide additional notice or seek new consent when required. For questions, contact Minilagedi OÜ at the registered address above or updates@tdpzero.io.