WORKING DRAFT — Not legal advice. This document was prepared as a first-pass studio draft for human review and future attorney review. It is not a substitute for counsel. Do not treat it as jurisdiction-specific legal advice. Contact: legal@paintedthorn.net
1. Who we are
Painted Thorn ("Painted Thorn," "we," "us," or "our") operates the website paintedthorn.net (the "Site") and develops games, including the work-in-progress title Clean Up My Bulk.
For privacy questions or requests, contact: legal@paintedthorn.net
Governing context for this draft: operations are currently associated with Florida, United States. A business entity in Texas is planned. When the formal entity and principal place of business are finalized, this Policy should be updated by counsel to name the legal entity, mailing address, and governing details.
2. Scope
This Privacy Policy describes how we handle information in connection with:
- the Site (paintedthorn.net and pages we control there); and
- our games, including Clean Up My Bulk, to the extent we control data collection for those games.
This Policy does not cover third-party platforms we do not control. In particular, if you play our games through Steam or other storefronts, those platforms' privacy policies and terms apply to data they collect (including Steam analytics and account data).
3. Information we collect
3.1 Website
We do not run account sign-ups, purchase flows, or first-party tracking analytics on the Site.
Email list / newsletter. If you sign up on the Site for studio or game updates, we collect the email address you submit (and standard signup metadata our email provider records, such as signup time and IP if provided by the form or provider). Signing up is optional and requires your consent (for example, by submitting the signup form).
We send those emails from games@paintedthorn.net using Resend (our email delivery provider). Message content is limited to Painted Thorn studio and game information and updates (for example news about Clean Up My Bulk or the studio). We do not invent product features in these drafts or in list mail — only information we actually choose to announce.
You can unsubscribe at any time using the unsubscribe link in those emails, or by contacting us (see Section 10). We will stop promotional/list sends to that address after an unsubscribe is processed.
Other email to us. If you email us directly (for example via press@, support@, development@, sponsors@, legal@, or games@ at paintedthorn.net), we receive whatever you choose to include in that message. We use that information only to respond and manage the request.
Contact form submissions (name, email, subject, topic, and message) are routed to the matching studio inbox and handled like email to us.
Hosting logs. Our hosting provider may automatically process standard technical logs (such as IP address, browser type, dates/times of access, and pages requested) as part of operating a website. We do not use those logs to build marketing profiles. Retention of host logs follows the host's defaults unless we configure otherwise.
3.2 Games and Steam analytics
We do not operate our own in-game personal-data collection for Clean Up My Bulk (or our other titles) at this time, other than analytics provided by Steam when a game is distributed on Steam.
Steam analytics and related Steam account, purchase, and play data are collected and processed by Valve / Steam under Steam's own privacy policy and terms. We may receive aggregated or developer-facing analytics from Steam as part of publishing on that platform. For details on what Steam collects, see Steam's privacy documentation.
3.3 What we do not collect (current state)
We do not currently collect through the Site or our own game clients:
- account usernames/passwords for Painted Thorn services (beyond optional email-list signup);
- payment card data;
- precise geolocation;
- contacts, photos, or device address books;
- advertising identifiers for third-party ad networks operated by us.
3.4 Future features
Our games are not multiplayer today. Multiplayer and related online features may be added later. If we introduce accounts, cloud saves, voice/text chat, matchmaking, user-generated content, or other features that require additional personal data, we will update this Policy before or when those features launch.
4. How we use information
We use information only as needed to:
- operate and secure the Site;
- send studio/game update emails you signed up for (from games@paintedthorn.net via Resend);
- respond to emails and support/press/business inquiries;
- understand aggregated Steam analytics for development and publishing decisions;
- comply with law and enforce our Terms;
- protect rights, safety, and security.
We do not sell personal information. We do not share personal information for cross-context behavioral advertising.
5. Cookies and similar technologies
The Site does not currently use first-party analytics cookies or advertising cookies operated by us. If a future update adds cookies or similar technologies, we will update this Policy and, where required, provide appropriate notices or controls.
6. How we share information
We may share information only with:
- Service providers who help us run the Site or studio operations — including Resend for email list delivery and our hosting/email infrastructure — under obligations to use the information only for providing their services;
- Platforms such as Steam, when you use our games there (their processing is under their policies);
- Professional advisors (legal, accounting) when needed;
- Authorities or other parties when required by law, legal process, or to protect rights and safety;
- A successor entity in connection with a merger, acquisition, or asset transfer, subject to this Policy's spirit and applicable law.
We do not sell your personal information.
7. Retention
Email-list addresses are kept until you unsubscribe or we shut down the list, and for a short period afterward as needed for suppression (so we do not email you again by mistake) and legal obligations. One-off email correspondence is kept as long as needed to handle the inquiry and for ordinary business records. Hosting logs follow provider defaults unless we set a shorter period. Steam analytics retention is controlled by Steam. Resend retains delivery-related data per its own practices and our configuration.
When we no longer need information for these purposes, we delete or de-identify it where reasonably practicable.
8. Security
We take reasonable administrative and technical measures appropriate to our size and the limited data we handle. No method of transmission or storage is completely secure. Please use official paintedthorn.net addresses and do not send sensitive personal data by email unless necessary.
9. Children
Our Site and games are intended for young adults and a general audience of adults. We do not knowingly collect personal information from children under 13 on the Site, including via the email list. If you believe a child under 13 has provided personal information to us directly, contact legal@paintedthorn.net and we will take appropriate steps to delete it.
Parents and guardians: game purchases and Steam accounts for minors are subject to Steam's and the applicable platform's rules.
10. Your choices and rights
Email list. Unsubscribe using the link in our emails, or email games@paintedthorn.net or legal@paintedthorn.net and ask to be removed. Privacy rights requests (access, correction, deletion, and similar rights where they apply) can be sent to legal@paintedthorn.net.
Depending on where you live, you may have rights to request access, correction, deletion, or other actions regarding personal information we hold about you. Include enough detail for us to locate your information (for example, the email address you used to sign up or contact us). We may need to verify your identity.
For Steam account or Steam analytics data, contact Steam / Valve through their published channels.
11. International visitors
The Site is operated from the United States. If you access it from outside the U.S., you understand that information you send us (such as email or list signup) may be processed in the United States, including by our email provider.
12. Changes
We may update this Privacy Policy from time to time. We will post the updated version on the Site and revise the "Last updated" date. If changes are material, we will take additional steps when appropriate (for example, a notice on the Site).
13. Contact
Painted Thorn
Privacy / legal: legal@paintedthorn.net
Email list: games@paintedthorn.net (or use unsubscribe in the message)
Website: https://paintedthorn.net