Legal
Privacy Policy
Effective date: 21 October 2026
Divine Studios ("we", "us", "our") operates the website divinestudios.io and makes the game Fragmented Echoes. This Privacy Policy explains what personal data we collect when you visit the website or play the demo, why we collect it, who processes it for us, and the choices you have.
1. Who We Are
Divine Studios is an independent game development team based in Singapore and Vietnam. It is not currently a registered company. The Divine Studios team is responsible for the personal data collected through this website.
Our data protection contact, who handles all privacy questions and requests, can be reached at hello@divinestudios.io.
2. Information We Collect
2.1 Information You Provide
- Contact form: your name, email address, subject, and message.
- Newsletter: your email address when you subscribe.
- Emails you send us: whatever you choose to include when you write to us directly.
2.2 Information Collected Automatically
- Analytics: we use Cloudflare Web Analytics, which does not use cookies and does not track you across sites. It gives us aggregated figures such as page views, referrers, browser type, and country.
- Server and security logs: Cloudflare, which hosts the website and its downloads, processes your IP address, timestamps, and requested URLs to deliver pages and protect against abuse.
- Spam protection: when you submit the contact or newsletter form, Cloudflare Turnstile checks that you are not a bot. It processes your IP address and basic browser signals for this check.
- Embedded and third-party content: some pages load content from other providers, which receive your IP address and browser information when they do:
- the trailer on our home page is played through YouTube (Google) in its privacy-enhanced mode;
- fonts are loaded from Google Fonts;
- the blog loads a text-formatting library from the jsDelivr content network.
2.3 In the Fragmented Echoes Demo
The first time you start the demo, it asks whether to share play data. Nothing below leaves your PC until you answer, and you can change your answer at any time in the game's Settings.
- Share play stats: how your sessions go (rooms and checkpoints reached, time played, deaths and what caused them, boss attempts, the items and weapons you pick up and use, settings you change), the path your character walks in each room, frame rate, loading times, and your PC's graphics card, processor, memory and operating system. Crash reports are included.
- Crash reports only: when the game crashes or freezes, the error, the game's log with your Windows user name removed, and the same PC details.
- Don't share: nothing is sent.
- Feedback you send from the game (F1, the pause menu or the end screen) is always sent, because you choose to send it, with an optional screenshot.
Each copy of the game gets a random ID. We don't collect your name, Steam account, email or IP address with play data, and we use it only to find bugs and make the game better.
3. How We Use Your Information
- To reply to messages you send through the contact form or by email.
- To send the newsletter you signed up for. You confirm your subscription by clicking a link in a confirmation email, and every newsletter includes an unsubscribe link.
- To understand how the website is used and improve it.
- To keep the website and its forms secure and free of spam.
We do not use your data for advertising, and we do not make automated decisions about you.
4. Legal Basis for Processing
Where the EU or UK General Data Protection Regulation applies to you, we rely on:
- Consent: for the newsletter, when you choose to contact us, and for play data and crash reports from the demo. You can withdraw consent at any time.
- Legitimate interests: for analytics, security, spam protection, and delivering the website, where these do not override your rights.
For everyone else, we collect, use, and disclose personal data with your consent or as otherwise permitted under Singapore's Personal Data Protection Act 2012 (PDPA).
5. Who Processes Your Data
We do not sell, trade, or rent your personal information. We use these service providers to run the website:
- Cloudflare: website hosting, downloads, DNS, security, spam protection (Turnstile), and analytics.
- Resend: sends our emails and stores the newsletter subscriber list. Contact form messages are delivered to us by email through Resend. Resend may record whether an email was delivered or opened.
- Google: YouTube video playback and Google Fonts.
- jsDelivr: delivers a library used on the blog.
Each provider processes data under its own privacy policy and applicable data protection laws. Links to Steam, Discord, X, YouTube, and other sites take you to services with their own privacy practices.
6. Cookies and Similar Technologies
We do not set advertising or tracking cookies, and Cloudflare Web Analytics is cookie-free. Cloudflare may set strictly necessary cookies for security and bot protection.
The home page trailer uses YouTube's privacy-enhanced mode, which does not set YouTube cookies until you interact with the video. YouTube may still store some data in your browser for playback to work. On phones the trailer is not embedded; it opens on YouTube only if you tap it.
7. Data Retention
- Contact form messages and emails: kept as long as needed to deal with your enquiry, then for up to 12 months.
- Newsletter subscriptions: kept until you unsubscribe or ask us to delete your address.
- Analytics: aggregated only; it does not identify you.
- Server and security logs: kept by Cloudflare for a limited period under its own retention policy.
- Demo play data: session figures are kept while the game is in development; the paths your character walks are deleted after 90 days, game logs after 180 days, and crash files 90 days after the crash is fixed.
8. How We Protect Your Data
The website is served only over encrypted connections (HTTPS). Access to subscriber lists, messages, and admin tools is restricted to the Divine Studios team and protected by sign-in. No method of transmission or storage is completely secure, but we take reasonable steps to protect your data.
9. Your Rights
Depending on where you live, you may have the right to:
- Access: get a copy of the personal data we hold about you.
- Correction: have inaccurate data corrected.
- Deletion: have your personal data deleted.
- Withdraw consent: at any time, for example by unsubscribing from the newsletter.
- Data portability: receive your data in a structured, machine-readable format.
- Objection and restriction: object to, or ask us to limit, processing based on legitimate interests.
In the demo, Settings shows your data ID and has a button that deletes everything your copy of the game has sent us.
To exercise any of these rights, email hello@divinestudios.io. We aim to respond within 30 days.
You can also complain to a data protection authority: in Singapore, the Personal Data Protection Commission (PDPC); in the EU or UK, the authority where you live or work. We would appreciate the chance to resolve your concern first.
10. International Data Transfers
Divine Studios works from Singapore and Vietnam, and our service providers operate globally, including in the United States and the European Union. Your data may therefore be processed outside your country. Where the law requires it, we rely on our providers' standard safeguards for international transfers, such as the EU Standard Contractual Clauses, and we handle your data in line with the PDPA, the GDPR where it applies, and Vietnam's personal data protection rules.
11. Children's Privacy
The website is not directed at children under 13, and our newsletter is not intended for anyone under 16. We do not knowingly collect personal data from children. If you believe a child has given us their data, contact us and we will delete it promptly.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with a new effective date. If we make significant changes to how we use subscribers' data, we will also let subscribers know by email.
13. Contact
For questions about this Privacy Policy or your personal data:
- Email: hello@divinestudios.io
- Website: divinestudios.io