Privacy policy
Last updated · April 20, 2026
Improbability Works (“we”, “us”) is committed to protecting your personal data. This policy describes what data we collect, why, how long we keep it, who has access, and the rights you hold under the EU General Data Protection Regulation (GDPR / Regulation (EU) 2016/679) and the French Data Protection Act (Loi Informatique et Libertés, as amended).
Data controller
The data controller is:
Improbability Works — William Pottier
87 avenue Léon Blum, 33110 Le Bouscat, France
SIREN 515 215 390
Contact: hello@improbabilityworks.studio
We have not designated a Data Protection Officer (DPO), as our processing activities fall below the thresholds making such designation mandatory. All privacy-related requests should be directed to the contact above.
Scope of this policy
This policy covers two distinct contexts, each with its own data-collection profile:
-
The studio website (improbabilityworks.studio) — a static informational site with a newsletter subscription form. No user accounts, no purchases, no in-browser game sessions.
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Improbability Works games (including Velvet Door) — distributed via Steam and/or Epic Games Store. Games involve online multiplayer sessions and are subject to their distribution platforms’ own privacy policies.
Website — data collected
Newsletter subscription
The newsletter (“the Dispatch”) is not currently active. When it opens, this section will be updated to describe the data collected (email address, consent timestamp), the provider used, and the applicable legal basis before any subscription form goes live.
Hosting and server logs
Our hosting provider automatically records standard HTTP request logs (IP address, HTTP method, URL requested, response code, user-agent, timestamp) for the purpose of operating and securing the service. These logs are held by the provider and are not cross-referenced with newsletter data.
Analytics
We do not currently use any analytics tool. Should we activate privacy-friendly, cookieless analytics (such as Plausible or Umami) in the future, this policy will be updated before the tool goes live.
Cookies and local storage
This website sets no tracking or advertising cookies. A minimal localStorage entry may be used to remember your language preference (English / French); it contains no personal data and is never sent to a server. No cookie consent banner is displayed, consistent with CNIL guidance on strictly necessary cookies.
Games — data collected
Platform-managed data
Games distributed through Steam (Valve Corporation) and/or Epic Games Store (Epic Games Inc.) are subject to those platforms’ own privacy policies. Each platform may collect account data, purchase history, playtime, and usage statistics independently. We encourage you to review:
- Valve Privacy Policy: https://store.steampowered.com/privacy_agreement
- Epic Games Privacy Policy: https://www.epicgames.com/site/en-US/privacypolicy
Multiplayer session data
When you participate in an online multiplayer session in Velvet Door (cooperative play for 2–4 players), the following technical data is processed to establish and maintain the session:
- IP addresses of connected players, processed transiently to route game traffic. IP addresses are not stored beyond the duration of the active session.
- Platform identifiers (Steam ID or equivalent), used to identify players within a session and enforce platform-level restrictions (bans, etc.).
- Session metadata (connection timestamps, latency measurements, session duration), retained for a maximum of 30 days for the purpose of diagnosing connectivity issues.
No persistent player profiles, behavioural analytics, or advertising identifiers are maintained by Improbability Works from in-game data.
Save data and game state
Game progress is stored locally on your device and, where Steam Cloud is enabled, synchronised to Valve’s servers under their own privacy policy. Improbability Works does not have access to your local save data.
Crash reports and diagnostics
Crash reporting at launch is handled exclusively through the platform SDKs integrated in the Game — specifically the Steamworks SDK (Valve Corporation) and the Epic Online Services SDK (Epic Games Inc.). Crash data collected through these integrations is processed by the respective platform under their own privacy policies, not by Improbability Works directly.
Improbability Works does not independently receive, store, or process crash dumps or diagnostic reports. Should we integrate a standalone crash-reporting tool in a future update, this policy will be updated before the feature ships and collection will be clearly disclosed in-game.
Third-party processors
We rely on the following sub-processors:
| Processor | Role | Location | Privacy policy |
|---|---|---|---|
| Valve Corporation | Game distribution, multiplayer (Steam) | USA | Link |
| Epic Games Inc. | Game distribution (EGS) | USA | Link |
| Cloudflare, Inc. | Website hosting and CDN | USA (global PoPs) | Link |
We do not sell, rent, or share your personal data with any third party for marketing or advertising purposes.
Legal basis for processing
| Processing activity | Legal basis (GDPR art. 6) |
|---|---|
| Server logs — site security | Legitimate interest — art. 6(1)(f) |
| Multiplayer session routing | Contract performance / legitimate interest — art. 6(1)(b)/(f) |
| Session diagnostics | Legitimate interest — art. 6(1)(f) |
Where we rely on legitimate interest, we have assessed that our interest does not override your rights and freedoms as a data subject.
Data retention
| Data | Retention period |
|---|---|
| Server logs | As required by Cloudflare for security (typically ≤ 30 days for edge logs) |
| Multiplayer session metadata | 30 days maximum |
| IP addresses (session routing) | Not stored beyond the active session |
International data transfers
Some processors are established outside the European Economic Area, notably in the United States. Where personal data is transferred outside the EEA, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission; and/or
- The EU–US Data Privacy Framework, where the recipient is certified.
You may request a copy of the applicable safeguards by contacting hello@improbabilityworks.studio.
Your rights
Under the GDPR and French law, you have the right to:
- Access — obtain confirmation of whether we process data about you, and receive a copy;
- Rectification — request correction of inaccurate or incomplete data;
- Erasure (“right to be forgotten”) — request deletion of your data, where no legal ground overrides;
- Restriction — request that we limit processing in certain circumstances;
- Portability — receive your data in a structured, machine-readable format;
- Objection — object to processing based on legitimate interest;
- Withdrawal of consent — withdraw any consent given, at any time, without affecting the lawfulness of prior processing.
To exercise any of these rights, contact hello@improbabilityworks.studio. We will respond within 30 days (extendable to 3 months for complex requests, with prior notice).
If you believe your rights have not been respected, you may lodge a complaint with the CNIL (Commission Nationale de l’Informatique et des Libertés): https://www.cnil.fr.
Children's privacy
Our games are not directed at children under 13, and we do not knowingly collect personal data from children under 13 (or under 16 in jurisdictions where a higher age applies for consent). If we become aware that a child under the applicable age has provided personal data without verifiable parental consent, we will delete that data promptly.
If you believe a child has submitted data to us, please contact hello@improbabilityworks.studio.
Updates to this policy
We may update this policy to reflect changes in our practices, services, or applicable law. The “Last updated” date at the top of this page reflects the most recent version. For material changes, we will provide reasonable notice on our website or through in-game notifications. Continued use of the website or our games after a material change constitutes acceptance of the updated policy.
Contact
For any question about this policy or to exercise your rights, contact:
hello@improbabilityworks.studio
Improbability Works — William Pottier
87 avenue Léon Blum, 33110 Le Bouscat, France