Latest update: February 15, 2019
Governments and lawyers wanted to make this complicated. But in fairness, it became complicated in an attempt to protect your rights as a User. We’re gonna do our best to keep this simple.
…Still with us?
Contacting the User. When you fill in the contact form with your Data, you authorize us to use these details to reply to your requests for information, work quotes, or any other kind of request as indicated by the form’s header. That makes sense, right? Or when explicitly registering on the mailing list or for the newsletter, the User’s email address will be added to the list of contacts of those who may receive occasional email messages from us, containing information of commercial or promotional nature concerning our Sites. For example, we’d love to be able to tell you about cool new projects of ours.
Site Analytics using Google Analytics (Google LLC or Google Ireland Ltd.) We will use your Cookies or Usage Data from those tracking tools for the purpose of improving the functionality of these Sites to all Users in future updates. The third-party services referred to here and in #6 are what enable us to monitor and analyze web traffic, and it can be used to keep track of User navigation behavior on the website.
To dig into this a little bit more: what does “track navigation behavior” mean? We wish more companies would be transparent about this. For our Sites, this does not mean we saw your screen or could see out what sites you visit on the internet. For our Sites, tracking means we’re able to get a report—in aggregate—of the patterns when people click through the links on our Sites. For example, perhaps a majority of visitors never click on the Help button. That will help us design a better interface next time, so we can deliver what actually helps our readers.
In fact, the way we integrate Google Analytics on the Sites is configured to anonymize your IP address as it is being processed by Google. It works by shortening the IP addresses to leave off the final digits. In this way there is no numerical address saved by Google which itself identifies the Users’ computer or constitutes “Personal Data”. At that point it is a number that could refer to a huge pool of people.
Really mundane IT operations. For operation and maintenance purposes, this website and our third-party hosting service may generate text files on the Unix server that records your computer’s interaction with this website (System logs) and it may contain the IP Address for this purpose.
The Data is processed at the Owner’s computers operating in California, USA, and in any other places where third parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. For the Data processed by Google Analytics, it is processed in the United States; except for Users who are browsing from the European Economic Area or Switzerland, in which case it is processed in Ireland. For the Data processed by The Rocket Science Group, LLC, it is processed in the United States. For the Data you provide to Patreon Inc., it is processed in the United States.
We store personal information on secure servers that are managed by our service providers. Personal information that we store or transmit is protected by HTTPS security and access controls for only those authorized employees, including username and password authentication, two-factor authentication, and data encryption where appropriate.
Personal Data will be processed and stored for as long as required by the purpose they have been collected for. So, for Cookie and Usage Data: processed and stored for up to 26 months from the User’s visit to the site. For Personal Data in the form of names, profession, state, and email addresses: processed and stored indefinitely whenever the User has given consent to receive occasional newsletters via email (as originally requested by the User) for as long as such consent is not withdrawn. The User can always request that we unsubscribe their email, or suspend or remove that data.
Furthermore, we may be obliged to retain Personal Data for a longer period if required by an official legal authority to do so.
Once the retention period expires, that Personal Data shall be deleted.
Ummm… how about never? Except as discussed in #10 and #11, we will NOT disclose your Data outside our organization. The Data processing is carried out following organizational procedures strictly related to the purposes indicated. The Data may be accessible to certain types of persons at the studio in charge of the operation of the Sites (such as marketing, legal, system administration) or to external parties (such as the website’s hosting provider) appointed by us when necessary as Data Processors for the operation of the Sites. The updated list of these parties may be requested from us at any time.
Our lawyers insist that we point out two exclusions here: The User’s Personal Data may be used for legal purposes by us in court (or in the stages leading to possible legal action) with a third party arising from improper use of this website or the related services. The User must be aware that we may be required to reveal Personal Data to a third party upon a court order from official public authorities.
Any requests to exercise your rights can be directed to the Owner through the contact details provided at the top of this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
More details concerning the collection or processing of Personal Data may be requested from the Owner. Please see the contact information at the beginning of this document.
This website’s third-party Data processor, Google Analytics, does not support the “Do Not Track” requests as implemented in some browsers. This website’s third-party Data processor, MailChimp, also does not support these “Do Not Track” requests. To determine whether any of the other third-party services honor the “Do Not Track” requests, please read their privacy policies.
That said, we absolutely commit that any change to this policy will NEVER involve suddenly allowing us to sell or give out your email. And if in some post-apocalyptic scenario — an alien invasion, or maybe a hostile takeover — we hereby require any new controlling force of our studio to obtain your explicit permission before sharing your data with another organization.
Should the policy changes affect our activities that are performed on the basis of the User’s consent (like the newsletter), we will collect new consent from you where required.
The Owner of these Sites is not based in the EU. But the broader privacy protections in the EU are applicable where the Personal Data is that of users who are in the EU and to the extent it allows the Owner to monitor such Users’ behavior taking place in the EU. This is relevant to our Cookie and Usage Data, discussed in #6. Because all IP addresses have been anonymized, destroying their purpose as identifying pieces of Personal Data, there is no Data to apply the broader rights of consent, rectification, erasure, or transfer.
The Owner uses the following legal justifications for processing the Personal Data of its users in the EU. Either: (1) For web forms: those Users have given us their consent for one or more specific purposes; (2) For client work: the provision of Personal Data will be necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; (3) For a legal court order: processing of that Personal Data is necessary for compliance with a legal obligation to which the Owner is subject; or (4) For Cookie and Usage Data: processing is necessary for the purposes of the legitimate interests pursued by the Owner (usability improvements to our products).
Users in the EU have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Users in the EU may pursue any of the rights of the General Data Protection Regulation 2016/679 using the contact information at the beginning of this document or as described in #17.