Privacy Policy

Effective date: November 20, 2024

Privacy is a fundamental human right, and safeguarding it is our shared responsibility. In order to provide you with some of our services, we may collect limited amounts of personal information about you, with your consent. This policy describes what data we collect, and how we store and use it. By using any of our services that require or allow providing personal information (such our mailing list or this website) you agree to the usage of your personal information as outlined by this policy.

1. Jurisdiction and Governing Law

Prelude Ltda. is a Brazilian company, and as such this policy is primarily governed by Brazilian law, specifically the General Data Protection Law (“Lei Geral de Proteção de Dados” — LGPD). If you're accessing our services from outside Brazil, please be aware that your personal information may be transferred to, stored, and processed in Brazil.

If you're a resident of the European Economic Area (EEA) and the United Kingdom, or the State of California in the United States, you may have additional rights under the General Data Protection Regulation (GDPR), Data Protection Act 2018 (“UK GDPR”), or the California Consumer Privacy Act (CCPA). Please refer to sections 3.2 and 3.3 below for more information.

2. Data we Collect

2.1 Access Logs

As part of providing you with this website, we and our hosting provider collect access logs. These logs include your IP address, your ISP, an inferred rough geographic location, (a.k.a. “GeoIP”) the date and time of your requests, the pages you accessed, the user agent string sent by your browser, and your language preferences. These are used to monitor website performance, troubleshoot issues, and prevent abuse such as denial of service (“DoS”) attacks. They're also used in aggregate to generate anonymized statistics, that we use to guide our business efforts.

2.2 Mailing List

If you choose to subscribe to our mailing list, we collect your email address, preferred language, and optionally a name or pseudonym. This information is used to send you updates about our games, services, and other news. We use a third party service provider (EmailOctopus) to manage our mailing list, and your information is stored on their servers. You can unsubscribe from our mailing list at any time by following the instructions in the emails we send you. EmailOctopus offers an optional “Open tracking” feature that we do not use, as well as a “Click tracking” feature that we do use to measure the click-through rate of specific links in our emails. (We believe this strikes a good balance between not being overly creepy but still being able to measure the effectiveness of our communications.)

2.3 Crash Logs and Telemetry

Some of our game builds may include (optional) crash reporting and telemetry functionality. If you choose to enable this functionality, the reports sent back to us may include information about your hardware, operating system, resource utilization, game settings, game progress and internal logic state. This information will be used to diagnose and fix bugs in our games, to prioritize development and optimization efforts, and to better understand how our games are being played.

2.4 Payment and Storefront Information

We don't collect your payment information directly. When you purchase our games, or any other product, the transaction is processed by a third party storefront (such as Steam). These storefronts may collect and store your payment information according to their own privacy policies, and share limited information with us, such as your username, the fact that you purchased our game, or specific order details.

2.5 Physical Addresses (for Merchandise and Giveaways)

If you choose to purchase physical merchandise from us or our merchandising partners, or participate in a giveaway, we may need to collect and store a shipping address in order to fullfil your order. We'll keep this information around for the minimum amount of time necessary, and then delete it. If you're uncomfortable sharing this information, you can use a P.O. Box or similar mail forwarding service, a business/work address, or choose a comparable digital-only reward instead. (Whenever available.)

2.6 Information We Did Not Request

When you interact with us via social media, email or online communities, such as Discord or Steam, you may voluntarily share with us information that we did not request, such as your name, email, username, profile picture, location, “bio” details, email signature, message or post content, or any other personal or protected information that you choose to include in (or is trivially inferrable from) your interactions.

We will not use this information for any purpose other than to engage with you on the platform where you shared it, e.g. by “liking”, replying, reposting, addressing or “mentioning” you, commenting on your content, or to prevent abuse (see the “Moderation Logs” section below). For any other uses, we'll explicitly request prior written consent.

2.7 Moderation Logs

To provide everyone with a safe and enjoyable experience, and to address persisent abuse, harassment, or other violations of our community standards, we may collect and persistently store information regarding violations of our community guidelines, including correlating it across multiple accounts or platforms. This information will be used solely to enforce our guidelines and keep our community safe.

You may choose to use a pseudonym or a preferred name when interacting with us, such as when subscribing to our mailing list or participating in our online community. As a rule of thumb, we don't require you to provide your legal name unless strictly necessary (e.g. for tax or official purposes). Under these rare circumstances, we'll do our best limit the use of your legal name solely to the purposes for which it was collected, and will continue to use your preferred name or pseudonym in all other interactions.

3. Your Rights

3.1 LGPD Rights

The Brazilian General Data Protection Law (“Lei Geral de Proteção de Dados” — LGPD) grants you the following rights:

  1. Confirmation of the existence of processing: You have the right to obtain confirmation from us that your personal information is being processed;
  2. Access to data: You have the right to access the personal information we have about you;
  3. Correction of incomplete, inaccurate, or outdated data: You have the right to request that we correct any incomplete, inaccurate, or outdated personal information we have about you;
  4. Anonymization, blocking, or deletion of unnecessary or excessive data: You have the right to request the anonymization, blocking, or deletion of personal information that is unnecessary or excessive;
  5. Data portability to another service or product provider: You have the right to request assistance in the transfer of your personal information to another service or product provider;
  6. Deletion of personal data processed with the consent of the data subject: You have the right to request the deletion of personal information processed with your consent;
  7. Information about public and private entities with which the Controller has shared data: You have the right to request information about the public and private entities with which we have shared your personal information;
  8. Information about the possibility of not providing consent and the consequences of refusal: You have the right to be informed about the possibility of not providing consent and the consequences of such refusal;
  9. Revocation of consent: You have the right to revoke your consent at any time.

3.2 California Residents

If you're a resident of the State of California in the United States, the California Consumer Privacy Act (CCPA) grants you the following rights:

  1. The Right to Know: You can request that we disclose the categories of personal information we collect, the sources from which we collect it, the purposes for which we use it, and the categories of third parties with whom we share it;
  2. The Right to Delete: You can request that we delete the personal information we have about you, subject to certain exceptions;
  3. The Right to Opt-Out: You can opt-out of the sale or sharing of your personal information;
  4. The Right to Non-Discrimination: We won't discriminate against you for exercising your privacy rights;
  5. The Right to Correct: You can request that we correct the personal information we have about you;
  6. The Right to Limit: You can request that we limit the use and disclosure of sensitive personal information.

3.3 EEA and UK Residents

If you're a resident of the European Economic Area (EEA) and the United Kingdom, either the General Data Protection Regulation (GDPR) or the Data Protection Act 2018 (“UK GDPR”) grant you the following rights:

  1. The Right to Be Informed: You have the right to obtain confirmation from us that your personal information is being collected and processed;
  2. The Right of Access: You have the right to access the personal information we have about you;
  3. The Right to Rectification: You have the right to correct the personal information we have about you;
  4. The Right to Erasure: You have the right to request that we delete the personal information we have about you;
  5. The Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain circumstances;
  6. The Right to Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format, to migrate it to another service provider;
  7. The Right to Object: You have the right to object to the processing of your personal information under certain circumstances;
  8. Rights in Relation to Automated Decision Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, which produces legal effects concerning you or similarly significantly affects you.
  9. The Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority.

3.5 Requests

For requests regarding any of the above rights, or if you have any questions or concerns about your personal information, please contact us at [email protected].

We'll do our best to comply to requests within a reasonable timeframe. We may ask you to verify your identity before proceeding, by for example requiring you to contact us from the email address we have on record. Please note that in the case of deletion requests we may still have to retain some information for legal, regulatory or administrative purposes. (e.g. tax records)

4. Security and Data Breaches

We use industry-standard security measures to protect your personal information. These includes encryption, access controls, regular software updates and two-factor authentication. Despite that, no Internet-connected computer system can be guaranteed to be 100% secure, so there is always a risk of unauthorized access.

We will responsibly notify you if we become aware of any data breaches that may affect your personal information.

5. Data Sharing

We may disclose your personal information in response to a valid legal request, such as a court order, search warrant, or subpoena. We'll do our best to notify you of any such requests, unless we're legally prohibited from doing so.

Under extreme circunstances, such as repeated abuse, harassment, unlawful behavior, or imminent threats to life or safety of our community members, we may also opt to responsibly disclose information to relevant authorities.

5.2 Third-Party Providers

To enable our services, we make use of third party providers. By using our services, you agree that your personal information may be shared with or stored by these providers insofar as required for the specific service(s) they provide.

For a full list of third-party providers we use, and links to their respective privacy policies, refer to Appendix A. Please be aware that these providers may in turn use sub-providers to enable their services, and so forth.

We'll do our best to keep this provider list up-to-date and complete as we add or remove service providers. However, under exceptional circumstances (such as disaster recovery, dealing with an outage) we may need to migrate to or temporarily use additional service providers not listed on it without prior notice. We'll notify you of any such changes as soon as possible.

5.3 Tracking, Targeted Advertising

We do not:

We may:

5.4 Video Embeds

To provide you with high quality video in a cost-effective and performant manner, we may link to or integrate into our website content hosted by third-party specialized video hosting platforms (such as YouTube) via their embeddable players. As these players are known to track your activity, we implement a “click-through” mechanism that requires explicit interaction from you before the player is loaded.

By clicking through to load the player, you acknowledge and accept that the third-party video hosting platform may collect personal information about you. We encourage you to review the privacy policies of these platforms before interacting with their content.

6. Minors and Online Safety

In order to provide informed consent to this policy, you must be of legal age to do so in your jurisdiction. If you're under legal age, please ask a parent or guardian to review and approve this policy for you (or to contact us with any questions) before you use any of our services that require or allow providing personal information.

We do not knowingly collect personal information from minors under the age of 13. If you are under 13, you may not use any of our services that require or allow providing personal information. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at [email protected] so that we can take the necessary steps to remove the information.

7. Changes to this Policy

We reserve the right to update this policy at any time. We'll do our best to notify you ahead of time of any changes, either by email, the "News" section of our website, or the announcements channel of our online community. We encourage you to review this policy periodically for any changes, and for that purpose we provide a changelog at the end of this document, on Appendix B. Feel free to keep copies of this policy for your own personal records.

Your continued use of our services after any changes to this policy constitute your acceptance of those changes.

Appendix A. Third Party Providers

Appendix B. Changelog