Effective from
Privacy
This policy explains what happens to your data when you use the Fulgur Studio website. We describe what the site actually does, with no filler. If something changes on the site, this page changes with it.
1. Who is the controller
Fulgur Studio, an independent game studio, São Paulo, Brazil.For any privacy matter, including data subject requests and questions about data protection, write to contato@fulgurstudio.com.br.
2. What data we process, why and on which legal basis
| Processing | Data | Purpose | Legal basis |
|---|---|---|---|
| Google Analytics 4 (GA4) | Pseudonymous identifier in a cookie, page views, traffic source, approximate location, device type. GA4 itself does not log or store IP addresses. | Measure site usage in more detail. | Consent (LGPD art. 7, I; GDPR art. 6(1)(a)). Only runs if you accept. |
| Contact emails | Name, email address and the content of the message you send. | Answer your message and follow up. | Legitimate interest (LGPD art. 7, IX; GDPR art. 6(1)(f)), or steps taken at your request before a contract (LGPD art. 7, V; GDPR art. 6(1)(b)) when the conversation is about a partnership or a service. |
| Hosting technical logs (Cloudflare) | IP address, date and time, requested page, browser (user agent). | Deliver the site, keep it secure and prevent abuse. | Legitimate interest (LGPD art. 7, IX; GDPR art. 6(1)(f)). |
Current GA4 status: Google Analytics is not active on this site yet. Until it is, no Google script is loaded and the cookie banner does not appear. When GA4 is turned on, the processing described in the table applies, always subject to your consent.
YouTube videos (when there are any) are loaded only after you click to watch, in enhanced privacy mode (youtube-nocookie.com). Before the click, no request is made to YouTube. After it, Google’s and YouTube’s rules apply.
The site has no ads, does not build behavioral profiles for advertising and does not sell data.
3. How consent works
When GA4 is enabled, it is loaded only after you click “Accept” on the banner. The Accept and Reject buttons have equal prominence. Rejecting does not limit access to the site. While GA4 is enabled, you can change your mind at any time with “Manage cookies” in the footer of any page: when you reject or withdraw, GA4 goes back to the denied state and the _ga cookies are deleted. The full list of cookies is in the cookie policy.
4. Who we share data with
- Cloudflare, Inc.: website hosting, content delivery, security.
- Google LLC: Google Analytics 4 (only with your consent) and YouTube (only after your click).
- Authorities, when there is a legal obligation or a court order.
We do not share data with third parties for advertising.
5. International transfers
Cloudflare and Google run infrastructure outside Brazil, including in the United States, so your data may be processed outside Brazil (and outside the European Economic Area, if you are in it). International transfers require a valid mechanism under LGPD art. 33 and, where applicable, GDPR chapter V. You may request information about the applicable safeguards and how to obtain a copy using the contact above.
6. How long we keep data
- Hosting logs: for the period Cloudflare defines for its services. We keep no copy of these logs.
- GA4: when enabled, user-level and event-level data retention depends on the property settings (2 or 14 months for standard properties). This setting does not cover standard aggregated reports.
- Contact emails: for as long as needed to handle the matter and then for up to 2 years for record keeping, or longer if the law requires. You can ask for deletion earlier.
- Consent cookie (
cc_cookie): 180 days (about 6 months).
7. Your rights
Under the Brazilian LGPD (art. 18) you may, at any time and on request:
- confirm whether we process your data and access it;
- correct incomplete, inaccurate or outdated data;
- ask for anonymization, blocking or deletion of unnecessary data or data processed unlawfully;
- ask for data portability;
- ask for deletion of data processed on the basis of your consent;
- know who we share data with;
- know that you may refuse consent and what follows from that;
- withdraw consent;
- object to processing that does not require consent if it does not comply with the LGPD.
Where our processing falls within the territorial scope of the GDPR, you also have the right of access (art. 15), rectification (art. 16), erasure (art. 17), restriction of processing (art. 18), data portability (art. 20), objection (art. 21) and to withdraw consent at any time (art. 7(3)), and you may lodge a complaint with your local supervisory authority.
Withdrawal does not affect the lawfulness of processing before withdrawal. Rights are subject to applicable legal conditions and exceptions, including lawful retention obligations.
You may also complain to the Brazilian National Data Protection Authority (ANPD).
8. How to exercise your rights
Write to contato@fulgurstudio.com.br saying what you want to request. We may ask for extra information to confirm the request is yours. Requests are free of charge, subject to legal exceptions. Under the LGPD, confirmation and access are provided immediately in simplified form or in a full response within 15 days (art. 19). Where the GDPR applies, we normally respond within one month; a necessary extension of up to two further months will be explained within the first month.
Providing contact details is voluntary, but we may need them to reply. We do not make decisions based solely on automated processing that have legal or similarly significant effects. Under GDPR art. 21, you may object to processing based on legitimate interests on grounds relating to your particular situation.
9. Children
The site is not directed at children and we do not knowingly collect data from minors. If you think a child has sent us data, tell us at the address above and we will delete it.
10. Updates
We may update this policy when the site or the law changes. The effective date is at the top of the page. Relevant changes, such as a new kind of processing, will be highlighted on the site itself.