Who is responsible
The controller of the personal data processed through mithrall.com is AnkleBreaker Consulting, a French SAS trading as AnkleBreaker Studio, 34 rue du Président Wilson, 78230 Le Pecq, France, RCS Versailles 912 705 860.
For any question about this policy or about your data, write to hello@anklebreaker-studio.com.
What the site does not do
- It has no account, no form, no newsletter and no comments: it never asks who you are.
- It does no audience measurement, loads no advertising tag and no social-network widget, and sets no cookie on your device.
- It serves its typefaces, pictures and videos from mithrall.com itself, not from another company’s servers.
Delivering and protecting the site
Like any website, mithrall.com receives what your browser sends with each request: your IP address, the page asked for, your browser and system as it describes them, your preferred language and the address of the page you came from. AWS uses them to send you the page through the nearest point of its CloudFront network, and its firewall, AWS WAF, uses your IP address to limit how many requests one address can send to some parts of the site and to turn away addresses on AWS’s list of known malicious sources.
Legal basis: our legitimate interest in showing you the pages you ask for and keeping the site available and secure (GDPR, Article 6(1)(f)).
Technical logs
When something goes wrong, the site’s servers write a technical error report to Amazon CloudWatch Logs, in the AWS Europe (Ireland) region. Our code writes no IP address, and nothing that identifies a visitor, to these logs. Legal basis: the same legitimate interest in keeping the site working.
Messages you send us
If you write to hello@anklebreaker-studio.com, we use your address and your message to answer you. Legal basis: our legitimate interest in answering the people who write to us or, when you exercise one of your rights, our legal obligation to respond (GDPR, Article 6(1)(f) and (c)).
The trailer
The trailer player on the home page shows a moving picture served by mithrall.com until you press play. Only then does your browser load YouTube’s player, from youtube-nocookie.com: Google then receives your IP address and details of your browser, and may store identifiers on your device, under its own privacy policy. Google Ireland Limited is responsible for that processing. The other YouTube links open youtube.com itself.
The studio’s devlogs
The site’s server reads the studio’s public devlog feed and the posts’ cover pictures from anklebreaker-studio.com, then shows them from mithrall.com. Nothing about you is sent with these requests: your browser only contacts the studio’s site if you follow a link to it.
Links to other sites
Links to Steam, Discord, YouTube and the other AnkleBreaker sites take you to services that run under their own privacy policies. Most links to the Steam page, the Discord server and the other AnkleBreaker sites carry a short tag (utm_source=mithrall_website and the place of the link on the page), so that those services’ statistics show which link brought a visit; the tag says nothing about you. Following a link to another AnkleBreaker site also tells that site you came from mithrall.com.
Who handles your data
- Amazon Web Services EMEA SARL (Luxembourg), our host, which delivers the site (Amazon CloudFront), protects it (AWS WAF) and keeps its technical logs (Amazon CloudWatch), on our behalf.
- Google, whose Google Workspace service hosts the studio’s mailboxes, for the messages you send us, on our behalf.
- Google Ireland Limited, on its own account, only if you press play on the trailer.
We do not sell or rent your data and share it with no advertiser. We would disclose it to an authority only where the law requires it.
Transfers outside the European Union
The site and its logs are hosted in Ireland. CloudFront and AWS WAF are worldwide services: a request may be handled at an AWS location outside the European Union, including in the United States. AWS covers such transfers with the European Commission’s standard contractual clauses, part of its data processing terms, and takes part in the EU-US Data Privacy Framework. Google relies on the same safeguards for Google Workspace and YouTube.
How long data is kept
- Requests to the site: no access log is kept. AWS WAF keeps a sample of recent requests, with their IP address, for three hours.
- Technical error logs: one month.
- Your messages: as long as we need to answer you and deal with any follow-up.
- Choices stored in your browser: until you clear them (pause motion) or close the tab (opening gates).
Your rights
Under the General Data Protection Regulation (GDPR) and the French Data Protection Act (loi Informatique et Libertés), you have the right to:
- access your data (GDPR, Article 15);
- have it rectified (Article 16);
- have it erased (Article 17);
- have its processing restricted (Article 18);
- object at any time to processing based on our legitimate interest (Article 21);
- receive the data you gave us in a machine-readable format, where processing rests on your consent or a contract (Article 20);
- set instructions for what happens to your data after your death (Article 85 of the French Data Protection Act);
- withdraw your consent at any time, where processing rests on it.
Write to hello@anklebreaker-studio.com. We answer within one month, which can be extended by two months for a complex request, and ask for proof of identity only if we have a reasonable doubt about who is asking. As the site keeps no account and no visitor identifier, the only data we can usually link to you is the messages you have sent us.
Complaints
If you think your data is not handled lawfully, you can lodge a complaint with the French data protection authority, the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France (cnil.fr), or with the data protection authority of the EU country where you live or work.
Changes to this policy
We update this page whenever the site starts handling data differently, and the date at the top of the page changes with it.
