Privacy policy
Draft — placeholder text pending legal review. Not legally binding.
Last updated: [Date]
1. Controller
The controller responsible for processing personal data on this website (stationkeeper.gg and its subdomains soon., api. and news.) is:
[Name of the operator][Street and number]
[Postcode, city]
[Country]
E-mail: hello@stationkeeper.gg
Placeholder for legal review
[Data protection officer, if one is required]
2. What we process and why
Stationkeeper has not opened yet. Before the launch this website does three things: it describes the service, it takes sign-ups for the waitlist, and it sends the e-mails that belong to them.
2.1 Visiting this website: server logs
Our web server records each request in an access log: your IP address, the time, the address you asked for (without anything after a “?”, which we cut off), the method, the answer's status, size and duration, your browser's user agent and the page you came from (also cut off at its “?”). On news.stationkeeper.gg, where a page's address carries your subscriber id, that id is blanked in the log too. We use the log to run the servers, to find faults and to recognise attacks.
To stop a flood of requests, the server counts requests per IP address for a few minutes, in memory only. The application behind the form keeps no IP address in its logs.
2.2 The waitlist and the news
When you join the waitlist we store, in our own installation of the newsletter software listmonk on our server:
- your e-mail address and the language of the page you used;
- a code of your own, for the link you can share, and the code of the link you came through, if any (another waitlist entry's or a creator's);
- when you joined, when we sent you the confirmation mail and, after you confirmed, when we sent the welcome mail;
- your subscription to two lists, the launch invite and the news about Stationkeeper, with their status (unconfirmed, confirmed, unsubscribed).
Your address is on the lists only after you click the button in the confirmation mail (double opt-in). As proof of your consent we record the time and the IP address of that confirmation. If you came through someone else's link, your sign-up counts for their link once you have confirmed; we do not tell them your address.
We use the address to send you the invite when Stationkeeper opens and news about Stationkeeper. At the launch the waitlist moves, with its consent records, to the Stationkeeper service's own database (same controller, same hosting provider).
Placeholder for legal review
[What a referral earns, once decided; whether the launch opens in waves]
2.3 Keeping bots out of the form
Before the form is sent, your browser solves a small computing puzzle (a proof of work in the format of the open-source project ALTCHA). The puzzle comes from our own server and is checked there; no third party is involved, and it sets no cookie. To accept each solved puzzle only once, our server stores the puzzle itself (a random value that says nothing about you) until it has expired.
2.4 The e-mails we send
We send the confirmation mail, the welcome mail with your link, the launch invite and the news through the e-mail delivery service Lettermint (Netherlands), which receives your address and the mail and delivers it for us. Lettermint tells our listmonk when a mail could not be delivered (a bounce) or was marked as spam; after a permanent failure or a spam complaint we send nothing more to that address, and after the third temporary failure it is unsubscribed. We do not track whether you open our mails or click their links. Every mail has a link to unsubscribe.
Placeholder for legal review
[Confirm that open and click tracking is off on Lettermint's route, and what Lettermint's own unsubscribe link adds]
2.5 E-mails to us
If you write to us (for example to hello@stationkeeper.gg, or by replying to one of our mails), your message is stored in our mailbox at Proton (Proton AG, Switzerland), and we use it to answer you.
2.6 Cookies and your device
This website sets no cookies and loads nothing from other servers: its fonts and scripts come from our own. If you choose a theme (dark, light or system) in the footer, your browser keeps that choice on your device under “sk.theme” (local storage); it is never sent to us.
3. Legal bases
- the waitlist and the news, and the mails we send for them: your consent, Art. 6(1)(a) GDPR, which you can withdraw at any time with effect for the future;
- the record of your consent: our legal obligation to be able to prove it, Art. 6(1)(c) and Art. 7(1) GDPR;
- server logs, the request counting, the bot check and the handling of bounces and spam complaints: our legitimate interest in secure, working servers and in not mailing addresses that do not want or cannot receive our mails, Art. 6(1)(f) GDPR;
- your theme choice on your device: § 25(2) no. 2 TDDDG, as you ask for it.
Placeholder for legal review
[The legal bases as the lawyer words them, including the consent required for advertising e-mail under § 7 UWG]
4. Recipients and processors
We use these processors:
- hosting of our server in Germany: Hetzner Online GmbH, Gunzenhausen, Germany;
- sending our e-mails: Lettermint, [company name and address], Netherlands;
- our mailboxes: Proton AG, Geneva, Switzerland.
listmonk and the bot check are software we run ourselves on our server; their makers receive no data. Nobody else receives your address, and we do not sell or share it.
Placeholder for legal review
[Full names and addresses of the processors, and the processing agreements]
5. Transfers to third countries
Our mailboxes are at Proton AG in Switzerland, for which the European Commission has decided that it ensures an adequate level of data protection. Our server and Lettermint are in the EU. We transfer no data to other countries.
Placeholder for legal review
[Confirm the location of Lettermint's processing and any sub-processors]
6. How long we keep data
- server logs: 7 days, then deleted;
- the request counts: a few minutes, in memory only;
- a solved puzzle: until one hour after it expired (it expires 20 minutes after it was handed out);
- your waitlist entry: until you unsubscribe from both lists, delete it on your preferences page or ask us to, or until we close the waitlist; an entry that is never confirmed is deleted after [period];
- the record of your consent: as long as you are subscribed, then [period, for the proof of consent];
- e-mails to us: as long as needed to answer them, and as the law requires.
Placeholder for legal review
[Lettermint's own retention of delivery logs, and the periods above as the lawyer sets them]
7. Your rights
You have the right of access, rectification, erasure, restriction of processing, data portability and objection, and you can withdraw your consent at any time with effect for the future.
Every mail we send has a link to unsubscribe, from the launch invite or the news or both. The page behind it also lets you download what listmonk stores about you and delete it. Or write tohello@stationkeeper.gg.
Placeholder for legal review
[How to exercise these rights, and the right to object under Art. 21 GDPR in full]
8. Complaint to a supervisory authority
You have the right to lodge a complaint with a data protection supervisory authority.
Placeholder for legal review
[Competent supervisory authority and its address]