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Privacy Policy

Proxima Studio

Last updated: 17 July 2026

1. Who we are

Proxima Studio Ltd ("Proxima", "we", "us", "our") is an independent game development studio based in the United Kingdom. We develop and publish video games, including Warship Jolly Roger.

This privacy policy explains how we collect, use, and protect your personal data when you visit our website, sign up to our communications, play our games, or otherwise interact with us. We are the "data controller" for the purposes of UK data protection law, which means we are responsible for deciding how and why your personal data is used.

Legal entity: Proxima Studio Ltd, a private limited company registered in England and Wales (company number 13877737)

Registered address: Office 43, 1000 Lakeside, North Harbour, Portsmouth, Hampshire, PO6 3EZ, United Kingdom

Contact email: harvey@proxima.studio

ICO registration number: 00014818735

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. The data we collect

We aim to collect as little personal data as we can. Depending on how you interact with us, we may collect:

When you visit our website

  • Technical data such as your IP address, browser type, device type, and pages visited
  • Analytics data about how you use the site (see section 7 on cookies and analytics)

When you sign up to our mailing list

  • Your name (if provided) and email address, which we use to send you news and updates about our games, including release and wishlist reminders
  • Records of the emails we send you and whether you open or click them

When you contact us

  • Your name, email address, and the contents of your message

When you play our games

  • Warship Jolly Roger is currently in development and has not yet been released. It does not collect any personal data. If this changes when the game launches (for example, crash reporting or online features), we will update this policy before release.

When you follow or interact with us on social media or community platforms

  • Your public profile information and the content of your interactions with us on platforms such as YouTube, Discord, X, Instagram, TikTok, Threads, and BlueSky. Those platforms are separate controllers of your data and have their own privacy policies.

We do not knowingly collect special category data (such as health or political information) and we ask that you do not send it to us.

3. How we use your data and our lawful bases

Under UK GDPR we must have a lawful basis for each use of your personal data. Set out below is each thing we do with your data, followed by the lawful basis we rely on for it:

  • Running and securing our website — Legitimate interests (keeping our site working and safe)
  • Sending you our newsletter and game updates — Consent (you can withdraw at any time via the unsubscribe link in any email)
  • Responding to your enquiries — Legitimate interests (responding to people who contact us)
  • Marketing and promotional campaigns — Consent, or legitimate interests where permitted for existing contacts under the "soft opt-in" rules
  • Analytics and improving our website and games — Legitimate interests (understanding how our site and games are used), or consent where required for cookies
  • Complying with legal obligations (e.g. tax and accounting records) — Legal obligation

We do not sell your personal data, and we do not use it for automated decision-making that has legal or similarly significant effects on you.

4. Who we share your data with

We share personal data only where necessary, and only with organisations that provide services to us under contracts that require them to protect your data. These include:

  • Marketing and communications agencies. We work with Immutable Pty Ltd (ACN 626 193 351), based in Sydney, Australia, who help us with marketing campaigns, community outreach, and communications. Where they handle personal data (such as mailing lists or campaign analytics) they do so on our instructions as a data processor under a data processing agreement.
  • Email and newsletter providers. Our email and mailing list messages are sent via Hostinger, our email and hosting provider, from harvey@proxima.studio.
  • Website hosting and infrastructure providers. Our website is hosted by Hostinger.
  • Analytics providers. We use Google Analytics to understand how our website is used. Google may process this data on servers outside the UK, including in the United States (see section 5).
  • Game distribution platforms. If you buy or play our games through platforms such as Steam, the Epic Games Store, or console storefronts, those platforms collect and process your data as separate controllers under their own privacy policies. We may receive limited, aggregated sales and player data from them.
  • Professional advisers and authorities. Accountants, lawyers, insurers, and public authorities where we are legally required to share data.

5. International transfers

Where possible we use providers that store data in the UK or the European Economic Area. Some of our service providers are based outside the UK. In particular, our marketing agency, Immutable Pty Ltd, is based in Australia, and some infrastructure providers may be based in the United States. Where personal data is transferred outside the UK, we make sure appropriate safeguards are in place, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or an adequacy decision such as the UK Extension to the EU-US Data Privacy Framework.

6. How long we keep your data

We keep personal data only as long as we need it:

  • Newsletter data: until you unsubscribe, after which we retain a minimal suppression record so we do not email you again
  • Enquiries: typically up to 24 months after our last exchange
  • Website analytics: up to 14 months, as configured in Google Analytics
  • Accounting and business records: at least 6 years, as required by UK law

7. Cookies and analytics

Our website uses essential cookies, which are needed for the site to work, and analytics cookies set by Google Analytics, which help us understand how visitors use the site.

Analytics cookies are only set with your consent, which you can give or withdraw at any time via the cookie banner on our site. Refusing analytics cookies does not affect your use of the website.

8. Children

Our website and communications are intended for a general audience and are not directed at children. We do not knowingly collect personal data from children under 13. If you believe a child has provided us with personal data, please contact us and we will delete it.

9. Your rights

Under UK data protection law you have the right to:

  • Access the personal data we hold about you
  • Rectify data that is inaccurate or incomplete
  • Erase your data in certain circumstances
  • Restrict or object to our processing, including objecting to direct marketing at any time
  • Data portability, receiving your data in a machine-readable format where applicable
  • Withdraw consent at any time where consent is our lawful basis

To exercise any of these rights, email us at harvey@proxima.studio. We will respond within one month.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk or by calling 0303 123 1113. We would appreciate the chance to resolve any concern with you first.

10. Security

We use appropriate technical and organisational measures to protect your data, including encrypted connections (HTTPS), access controls, and reputable service providers. No system is completely secure, but we take reasonable steps to protect the data we hold.

11. Changes to this policy

We may update this policy from time to time. The latest version will always be available on our website, with the date of the last update shown at the top. If we make significant changes, we will let newsletter subscribers know by email.

If you have any questions about this policy or how we handle your data, contact us at harvey@proxima.studio.*