Privacy Policy
Shards of Clarity B.V.
Effective 8 August 2026
shardsofclarity.com · hello@shardsofclarity.com
This Privacy Policy explains how Shards of Clarity B.V. collects, uses, shares, and protects personal data when you visit shardsofclarity.com, contact us, or subscribe for First Edition updates.
1. Who We Are
Data controller
- Shards of Clarity B.V.
- Terschellingsestraat 35 B
- 3083 PK Rotterdam, the Netherlands
- KVK: 97516406 · VAT: NL868087464B01
- Email: hello@shardsofclarity.com
2. Scope of this Policy
This Policy applies to the Shards of Clarity website, its contact channels, and its prelaunch email communications. The Website is currently a brand and Kickstarter prelaunch experience. It does not process purchases, pledges, or payments and it does not require a user account.
This Policy does not govern Kickstarter or other third-party websites. Those services apply their own privacy notices. If we later introduce direct sales, an app, or materially different data uses, we will update this Policy before that processing begins.
3. Personal Data We Collect
- Subscription data: your email address and subscription status.
- Consent and preference data: signup source, dates and times, unsubscribe requests, and technical consent evidence such as an IP address or approximate location when collected by our email provider.
- Campaign attribution data: referral information and UTM source, medium, or campaign values connected to a signup.
- Communications: information you include when you email us or otherwise contact us.
- Technical data: IP address, browser and device type, pages requested, timestamps, security logs, and cookie or similar identifiers where applicable.
We do not intentionally request special-category data such as health, biometric, religious, or political information. Please do not send this information through general contact channels.
4. How We Collect Data
- Directly from you when you subscribe, respond to an email, or contact us.
- Automatically through website infrastructure, security logs, cookies, or similar technologies.
- From service providers acting for us, including our email marketing provider.
- From referral links or campaign parameters that identify how a visitor reached the Website.
5. Purposes and Legal Bases
- To send First Edition reveals, Kickstarter updates, and other marketing you requested. Legal basis: consent.
- To record and respect consent, unsubscribe choices, and communication preferences. Legal bases: consent, legal obligation, and our legitimate interest in demonstrating compliance.
- To respond to questions and requests. Legal bases: legitimate interests and, where relevant, steps requested before entering a contract.
- To operate, protect, troubleshoot, and improve the Website. Legal bases: legitimate interests, except where consent is required for optional cookies or analytics.
- To prevent misuse, keep records, establish or defend legal claims, and comply with law. Legal bases: legitimate interests and legal obligation.
6. Email Signup and MailerLite
We use MailerLite to manage our subscriber list and send First Edition and campaign emails. The visible signup form asks for an email address. We may associate the signup with an audience tag and referral or UTM information so we can understand campaign performance.
When you subscribe, you are added to our First Edition list immediately. MailerLite may process technical information needed to provide the service and help us monitor and improve email communications. You can review MailerLite's Privacy Policy.
You may withdraw consent at any time by using the unsubscribe link in an email or contacting us. Withdrawal does not affect processing that was lawful before withdrawal.
7. Cookies and Analytics
The Website may use strictly necessary cookies or similar technologies for security, network management, form operation, and preference storage. Optional analytics or marketing technologies will be used only where a valid legal basis exists and, where required, after your consent.
You can accept, reject, or change optional cookie choices through the Website's consent controls. When non-essential technologies are active, details about their providers, purposes, and durations are available in our Cookie Policy.
8. Kickstarter and Other External Services
The Website may link to Kickstarter, social media platforms, and other external services. When you follow a link or interact on another platform, that provider decides how it processes data under its own privacy notice.
The Website itself does not receive or process Kickstarter pledges or payment-card information. If Kickstarter later provides us with backer data needed to manage campaign rewards, we will process it for campaign administration, fulfilment, support, and applicable legal obligations, subject to the campaign information and this Policy as updated where necessary.
9. Who We Share Data With
- MailerLite, for subscription management and email delivery.
- Website hosting, development, infrastructure, security, and technical support providers.
- Professional advisers such as legal, accounting, and compliance advisers where necessary.
- Public authorities, courts, regulators, or other parties when required by law or necessary to protect legal rights.
- A buyer, investor, or successor in connection with a genuine corporate transaction, subject to appropriate confidentiality and legal safeguards.
We do not sell or rent personal data. Service providers may use data only for the services and purposes permitted by their agreements with us and applicable law.
10. International Transfers
Some providers or their subprocessors may process data outside the European Economic Area. Where required, we use an adequacy decision, approved Standard Contractual Clauses, and appropriate supplementary safeguards. You may contact us for more information about the relevant transfer safeguard.
11. How Long We Keep Data
- Subscriber data is kept while you remain subscribed. After unsubscribing, we stop marketing and delete or anonymise data that is no longer needed, while retaining a minimal suppression or consent record where reasonably necessary to respect your choice and demonstrate compliance.
- General enquiries are normally kept for up to two years after the last substantive contact, unless a longer period is needed for an ongoing matter or legal claim.
- Security logs and technical data are kept for the shortest period reasonably needed for operation, fraud prevention, investigation, and security.
- Cookie data is kept for the period shown in the Cookie Policy or consent settings. Records required by law are kept for the applicable statutory period.
12. Your Privacy Rights
- Access your personal data and receive a copy.
- Correct inaccurate or incomplete data.
- Request deletion or restriction where the legal conditions apply.
- Object to processing based on legitimate interests and object at any time to direct marketing.
- Receive or transfer certain data in a portable format where applicable.
- Withdraw consent at any time without affecting earlier lawful processing.
- Lodge a complaint with the Autoriteit Persoonsgegevens or another competent supervisory authority.
To exercise a right, email hello@shardsofclarity.com. We may ask for information needed to verify your identity. We normally respond within one month, subject to lawful extensions for complex requests.
13. Marketing Choices
You are not required to subscribe in order to browse the Website. Every marketing email will provide a way to unsubscribe. We may still send a non-marketing confirmation of your request or retain the minimum record needed to ensure that marketing does not resume without a new lawful basis.
14. Automated Decisions
We do not use personal data to make decisions based solely on automated processing that produce legal or similarly significant effects. We may use simple audience tags, subscription status, and campaign attribution to organise communications and understand performance.
15. Children
The Website is not directed to children. In the Netherlands, a child under 16 cannot independently give valid consent for consent-based online processing. If you believe a child has submitted personal data without valid parental or guardian consent, please contact us so we can investigate and delete it where appropriate.
16. Security
We use appropriate technical and organisational measures intended to protect personal data against accidental or unlawful loss, misuse, alteration, disclosure, or access. No online system is completely secure, and we cannot guarantee absolute security.
17. Changes to this Policy
We may update this Policy to reflect changes to the Website, campaign, providers, processing activities, or law. The effective date identifies the current version. Where appropriate, material changes will be highlighted on the Website or communicated directly.
18. Contact and Complaints
For privacy questions or requests, email hello@shardsofclarity.com or write to Shards of Clarity B.V., Terschellingsestraat 35 B, 3083 PK Rotterdam, the Netherlands.
You may also complain to the Dutch supervisory authority, the Autoriteit Persoonsgegevens, or to the competent authority in the country where you live or work.
Current version: this Privacy Policy was last updated on 8 August 2026.
