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Privacy Policy

1. Controller and Supervisory Authority

The controller responsible for data processing on this website within the meaning of the GDPR is:

The Snuggery Studio – Rudolf Latikan
Dennhäuser Str. 116, 34134 Kassel, Germany
Email: hello@smolvale.com · further details in the Legal Notice

Competent data protection supervisory authority:

Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (HBDI)
(The Hessian Commissioner for Data Protection and Freedom of Information)
Gustav-Stresemann-Ring 1, 65189 Wiesbaden, Germany

2. Hosting (Server Log Files)

This website is operated on a server provided by Hostinger. When you visit the site, the web server automatically processes technical access data transmitted by your browser (IP address, date/time of the request, page requested, referrer URL, browser type/version, operating system). This processing is necessary for the secure and stable operation of the website (error analysis, IT security) and is based on our legitimate interest (Art. 6(1)(f) GDPR). This data is not combined with other data sources. [TODO: finalize the location/data processing agreement with Hostinger and add it here if needed for the final version.]

3. Cookies and Tracking

3.1 Cookie-free basic analytics (always active, no consent required)

This website first uses a self-hosted, cookie-free analytics script ("Codex Analytics Beacon", operated at cms.latikan.com) that transmits only the visited page URL and the type of event (page view/click) to our own server when a page is loaded or certain elements are clicked — without cookies, without a unique identifier/fingerprinting, and without building user profiles. Because no personal reference is established, this script is technically necessary and permitted without consent; our legitimate interest in traffic measurement (Art. 6(1)(f) GDPR) additionally applies. The internal editorial preview (/blog/preview) is excluded from this measurement.

3.2 Cookies and tracking after consent

In addition, we show a cookie consent banner on your first visit. Only if you actively click "Accept" do we load the services listed below (legal basis: consent, Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG (German Telecommunications-Digital-Services-Data-Protection Act) for accessing information on your device). If you click "Reject", these services are not loaded and any tracking cookies already set are actively deleted from your browser. You may withdraw or change your choice at any time via the "Cookie Settings" link in the footer (Art. 7(3) GDPR).

a) Google Analytics 4 — Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (parent company: Google LLC, USA).
Purpose: traffic measurement/statistics to improve the website.
Cookies: _ga (2 years), _ga_<container-id> (2 years), _gid (24 hours); IP anonymization is enabled.
Transfer to third countries: USA — EU Standard Contractual Clauses (Art. 46 GDPR) apply, and/or Google LLC's certification under the EU-U.S. Data Privacy Framework serves as an additional safeguard.
[TODO: Rudi — add Smolvale's own GA4 measurement ID once a property has been created. Until then, only a placeholder is stored in the code and no real data is sent to Google.]

b) Meta Pixel (Facebook/Instagram) — Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
Purpose: traffic measurement and retargeting for Meta advertising.
Cookies: _fbp (3 months), _fbc (3 months, if set via an ad click).
Transfer to third countries: USA (Meta Platforms, Inc.) — EU Standard Contractual Clauses.
[TODO: Rudi — add Smolvale's own Pixel ID once an ad account/pixel exists.]

Joint controllership with Meta: under the CJEU ruling "Fashion ID" (C-40/17), joint controllership with Meta Platforms Ireland Limited within the meaning of Art. 26 GDPR applies to the collection and transmission phase of Meta Pixel data. The essential terms of the corresponding agreement ("Controller Addendum") are made available by Meta at facebook.com/legal/controller_addendum.

c) LinkedIn Insight Tag — LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin, Ireland.
Purpose: traffic measurement and campaign performance measurement for LinkedIn advertising.
Cookies: li_gc (2 years), lidc (24 hours), bcookie (2 years).
Transfer to third countries: USA (LinkedIn Corporation) — EU Standard Contractual Clauses.
[TODO: Rudi — add Smolvale's own LinkedIn partner ID once a campaign account exists.]

4. Note on "Notify me at launch" (Steam wishlist substitute)

The "Notify me at launch" button only opens your device's local email application (mailto:) with a pre-filled draft addressed to hello@smolvale.com. No data is transmitted to, stored on, or entered into a form/newsletter list on this website's servers — whether and when you actually send the email is entirely up to you in your own email application. There is currently no server-side wishlist or newsletter sign-up on this website. Should a real sign-up form be added in the future, this section will be updated before it goes live to include consent (Art. 6(1)(a) GDPR, § 7(2) UWG (German Act Against Unfair Competition)), a double opt-in process, an unsubscribe link in every email, and an age confirmation checkbox ("I am at least 16 years old", Art. 8 GDPR).

5. Google Fonts

This page loads fonts from Google Fonts (fonts.googleapis.com / fonts.gstatic.com). This may establish a connection to Google LLC's servers (USA) and transmit your IP address. [TODO: evaluate whether to self-host the font files instead, to avoid any third-party connection entirely — this would be the more privacy-friendly solution and can be retrofitted without much effort.]

6. Contact by Email

If you contact us by email, we process the data you provide (email address, message content) solely to handle your inquiry (Art. 6(1)(b) or (f) GDPR).

7. Your Rights

You have the right to access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), and data portability (Art. 20 GDPR) regarding your personal data, as well as the right to lodge a complaint with a data protection supervisory authority (see Section 1), in particular in the member state of your habitual residence.

Right to object (Art. 21 GDPR): You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(f) GDPR. You may also withdraw your consent to the consent-based tracking services described in Section 3.2 at any time, informally and with effect for the future, via the "Cookie Settings" link in the footer.

Last updated: September 23, 2026