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Privacy Policy

Because your privacy is important to us.

Ember Crows Ltd

Last updated: 13 February 2025

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Ember Crows Ltd (“Ember Crows”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and your rights.

This policy applies to our website, newsletter, press and creator resources, recruitment activities (including spontaneous applications), and any related communications.

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1. Who we are

Data Controller: Ember Crows Ltd
Registered address: 124 City Road, London, EC1V 2NX, United Kingdom
Company contact: contact@embercrows.com
Privacy contact: privacy@embercrows.com

If you contact us about your privacy rights, we may ask you for information to confirm your identity.

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2. The personal data we collect

We may collect and process the following categories of personal data:

 

A. Information you give us

  • Newsletter signups: email address, language preference, subscription preferences, and optional fields you choose to provide (for example, name).

  • Contact forms and enquiries: name, email, message content, and any information you include.

  • Press and creator enquiries: name, outlet or channel name, email, social links, and message content.

  • Recruitment and spontaneous applications: name, email, CV, portfolio links, cover letter, employment history, skills, and any other information you provide.

  • Event or partnership enquiries: name, organisation, role, email, and message content.

 

B. Information we collect automatically

When you use our website, we may collect:

  • Device and usage data: IP address, browser type, device type, operating system, pages viewed, referral source, and approximate location (derived from IP).

  • Cookies and similar technologies: see Section 9.

 

C. Information from third parties

We may receive limited information from third parties when you interact with our official profiles or content on social platforms (for example, engagement metrics). We use this data in line with each platform’s settings and your choices.

 

3. How we use your personal data

We use personal data for the following purposes:

 

A. To operate and improve our website

  • to provide website functionality

  • to maintain security and prevent fraud

  • to understand how visitors use the site and improve performance

 

B. To communicate with you

  • to respond to enquiries

  • to provide press and creator support

  • to send operational emails (for example, a download link you requested)

 

C. To send newsletters and updates

  • to send updates about development milestones, announcements, and opportunities to support the project (for example, Steam and Kickstarter notifications when available)
    You can unsubscribe at any time using the link in our emails.

 

D. To manage recruitment and applications

  • to evaluate your application

  • to communicate with you about roles

  • to maintain a talent pool for future opportunities if you choose to submit a spontaneous application

 

E. To protect our legal interests

  • to establish, exercise, or defend legal claims

  • to comply with legal obligations (for example, lawful requests by authorities)

 

4. Lawful bases for processing

Under UK GDPR and GDPR, we rely on the following lawful bases:

  • Consent: for newsletter marketing and for non-essential cookies where required. You can withdraw consent at any time.

  • Contract: where processing is necessary to take steps at your request before entering a contract or to perform a contract (for example, responding to a service request).

  • Legitimate interests: where processing is necessary for our legitimate interests and does not override your rights, such as improving our website, maintaining security, handling enquiries, and running recruitment in a proportionate way.

  • Legal obligation: where we must comply with the law.

 

5. Marketing preferences

If you subscribe to our newsletter, we will send you emails based on your preferences.

  • You can unsubscribe at any time using the unsubscribe link in any email.

  • If you withdraw consent, we may still send non-marketing messages where necessary (for example, a response to a direct enquiry).

 

6. Recruitment and spontaneous applications

If you apply for a role or submit a spontaneous application, we use your personal data to assess suitability and manage recruitment.

 

We may keep a record of your application for a limited period to:

  • manage recruitment decisions

  • consider you for future roles where relevant

  • maintain an audit trail of recruitment activity

You can request deletion of your recruitment data at any time, subject to legal and operational requirements.

 

7. Sharing your personal data

We do not sell your personal data.

We may share personal data with trusted service providers who help us operate our website and communications, such as:

  • website hosting and infrastructure providers (for example, Wix)

  • email and newsletter providers (for example, [INSERT PROVIDER])

  • analytics providers (for example, [INSERT PROVIDER])

  • file hosting or download delivery providers (if you download press materials)

  • professional advisers (legal, accounting, or insurance) where necessary

 

These providers act as processors and are contractually required to protect your information and use it only for the services they provide to us.

 

8. International transfers

Some of our service providers may process data outside the UK. Where personal data is transferred internationally, we use appropriate safeguards required by UK GDPR and GDPR, such as the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses with the UK Addendum, and additional security measures where appropriate.

Wix states it relies on Standard Contractual Clauses together with additional safeguards for international data transfers where no adequacy decision applies.

 

9. Cookies and analytics

We use cookies and similar technologies to:

  • make the site work properly

  • understand traffic and usage

  • improve performance and user experience

 

Cookies may be:

  • strictly necessary (required for core functionality)

  • analytics and performance cookies

  • functional cookies (preferences)

  • marketing cookies (only if you use them and where required)

 

You can control cookies through:

  • your browser settings

  • any cookie banner or preference tool we provide on the site

 

If you use a cookie banner, ensure it is configured so non-essential cookies are not placed until consent is given, where required.

 

10. Data retention

We keep personal data only as long as necessary for the purposes described in this policy, including legal and operational requirements. Typical retention periods:

  • Newsletter subscribers: until you unsubscribe, then we may retain a minimal suppression record to respect your preferences.

  • Contact enquiries: typically up to 24 months after the last interaction, unless needed longer for legal reasons.

  • Press and creator enquiries: typically up to 24 months after the last interaction.

  • Recruitment applications: typically up to 12 months after the recruitment process ends, unless you ask us to delete it sooner or we need to keep it longer for legal reasons.

  • Analytics data: typically 14 to 26 months depending on the tool configuration.

 

You can request deletion earlier and we will assess your request in line with our legal obligations.

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11. Your data protection rights

Depending on your location and circumstances, you may have the right to:

  • Access your personal data

  • Rectification of inaccurate or incomplete data

  • Erasure (delete your data)

  • Restriction of processing

  • Data portability (receive a copy in a usable format)

  • Object to processing based on legitimate interests

  • Withdraw consent (where processing is based on consent)

  • Lodge a complaint with a supervisory authority

 

To exercise your rights, contact us at privacy@embercrows.com. We may ask for identity verification to protect your data.

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12. Complaints

We encourage you to contact us first so we can address your concerns.

You also have the right to complain to the UK Information Commissioner’s Office (ICO). The ICO provides guidance on how to make a complaint and offers a helpline and online complaint process.

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13. Security

We use appropriate technical and organisational measures to protect personal data, including access controls and secure handling procedures. No system is completely secure, but we work to protect your information and limit access to those who need it.

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14. Children

Our website and content are not intended for children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will take appropriate steps.

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15. Links to third-party sites

Our website may link to third-party websites or social platforms. Their privacy practices are governed by their own policies. We are not responsible for how third parties handle your personal data.

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16. Changes to this policy

We may update this Privacy Policy from time to time. We will post the latest version on this page and update the “Last updated” date.

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