Effective date: 4 July 2025
1 . Who we are
Boxroom66 Ltd.
Riverside One, Sir John Rogerson’s Quay, Dublin 2, Ireland
Email: privacy@boxroom66.com
We follow the EU General Data Protection Regulation (GDPR), the UK GDPR and, where relevant, the California Consumer Privacy Act (CCPA).
We collect no personal data while you browse; the only details we ever receive are those you send us through a form.
We do not have a Cookie Banner to request consent because, under EU privacy laws, we are not doing anything that requires consent.
2 . What we collect & why
· Site analytics
Data
Ephemeral IP (truncated) · browser & OS
Why / legal basis
Improve site performance — legitimate interest §6 (1)(f) GDPR
Processor / location
Fathom Analytics — EU + US
Retention
Raw IP ≤ 48 h → deleted
Aggregated stats kept indefinitely
· Email forms
Data
Name (optional) · email · consent timestamp · requested download
Why / legal basis
Deliver the requested resource — consent §6 (1)(a)
Processor / location
ConvertKit Inc. — USA (SCCs · Data-Privacy Framework)
Retention
Until you unsubscribe or request erasure
· Server operation & security
Data
IP · URL · timestamp · user-agent
Why / legal basis
Security & abuse prevention — legitimate interest
Processor / location
Framer Sites on AWS — EU/US
Retention
30 days → anonymised logs
3 . Cookies & tracking technologies
This site sets no cookies, pixels or browser fingerprinting.
Fathom works without cookies and guarantees no persistent user identifiers.
Therefore a cookie banner is not required under the ePrivacy Directive.
4 . International transfers
ConvertKit and Framer store data in the United States. Both providers rely on Standard Contractual Clauses (SCCs) approved by the European Commission and participate in the EU-U.S. Data Privacy Framework where applicable.
5 . Your rights (GDPR & UK GDPR)
Access – know what data we hold.
Rectification – correct inaccurate data.
Erasure – “right to be forgotten.”
Restriction / Objection – limit or stop certain processing.
Portability – receive your data in a machine-readable format.
Email privacy@boxroom66.com with your request. We respond within 30 days.
6 . Data security
All traffic is forced over HTTPS. Data at rest is encrypted (AES-256) on AWS. We restrict access to authorized personnel and routinely review sub-processor security certifications.
7 . Children
Boxroom66 is not directed at children under 16. We do not knowingly collect personal data from minors.
8 . Changes to this policy
We will update this page before any material change in our data-handling practices. “Effective date” reflects the latest revision.
9 . Contact & complaints
Questions or complaints? Email privacy@boxroom66.com.
EU residents may also lodge a complaint with the Irish Data Protection Commission.
Last reviewed: 4 July 2025