Privacy Policy

1. Who is responsible for your data

The data controller for personal data processed through this website is:

• Foolhardy Horizons F.M.B.A
• Forening med begrænset ansvar (F.M.B.A.), registered in Denmark on 15 January 2025
• Registration number (CVR): 45344088 · EU VAT: DK45344088
• Borups Allé 138, 1. tv, 2000 Frederiksberg, Denmark
• E-mail: info@foolhardyhorizons.net · Telephone: +45 28 35 97 80

We have not appointed a Data Protection Officer, because our processing does not meet the criteria in Article 37 of the GDPR. Data protection questions go to the address above and are answered by the director.

2. The short version

We collect what you type into one of our two forms, and the technical information a web server records in order to serve a page. There is no analytics on this site, no advertising pixel, no tag manager, no social media widget and no third-party script of any kind. We do not sell or rent personal data, we do not profile you, and we do not make automated decisions with legal effects about you.

3. What we collect

3.1 Information you send us in a form

The general enquiry form asks for your name, e-mail address, an optional company name, a subject and your message. The pitch form asks for your studio name, your name, your e-mail address, the working title of your game and its genre, stage and target platforms, optional links to a build and a press kit, whether you would like an NDA, and your description of the project. We also record the date and time of the submission, which version of this notice was on screen, and a reference number.

3.2 Server logs

Our web server records each request in the ordinary way: IP address, date and time, the page requested, the HTTP status, and the browser's user-agent string. This is how a hosting provider keeps a service running and how misuse is investigated.

3.3 Abuse-prevention records

To stop the forms being used to send bulk mail, we count submissions per visitor per hour. Your IP address is not stored for this: it is combined with a secret value held on the server and turned into an irreversible hash, and only that hash and the timestamps are written to disk. Those records are deleted automatically after one hour.

3.4 Correspondence

If you write to us by e-mail or call us, we keep the correspondence so that we can deal with the matter and refer back to it.

We do not ask for and do not want special-category data (Article 9), and we ask you not to include it in a form.

4. Why we process it, and on what legal basis

• To answer a general enquiry. Legal basis: our legitimate interest in responding to people who contact us (Article 6(1)(f)). Our assessment is that you expect a reply, and that answering you does not override your rights.
• To evaluate a pitch and reply to it. Legal basis: steps taken at your request prior to entering into a contract (Article 6(1)(b)), and our legitimate interest in assessing business proposals (Article 6(1)(f)).
• To keep the site available and secure, including the abuse-prevention counting described above. Legal basis: our legitimate interest in the security and integrity of our systems (Article 6(1)(f)).
• To comply with the law, for example accounting and bookkeeping obligations once a business relationship exists. Legal basis: legal obligation (Article 6(1)(c)).

We do not use your data for marketing. There is no newsletter on this site and no marketing tick-box, because we do not send marketing e-mail.

5. Cookies and local storage

This website sets one cookie, and only on the contact page, at the moment the page with the forms is loaded. It is strictly necessary and therefore does not require consent under section 9 of the Danish Executive Order on Cookies or Article 5(3) of the ePrivacy Directive.

Name	fh_session
Purpose	Holds the anti-forgery token that proves a form submission came from our own page, and the timestamp used to detect automated submissions.
Type	First-party, strictly necessary, session cookie
Expires	When you close the browser
Flags	HttpOnly, SameSite=Lax, Secure over HTTPS

We also store one value in your browser's local storage, called fh-cookie-notice-seen, to remember that you dismissed the cookie notice. It never leaves your device and is not sent to our server. You can clear it through your browser's site-data settings.

There are no analytics, advertising, profiling, A/B testing or social media cookies on this site. If that ever changes, this section and the notice on screen will be updated before the cookie is set, and consent will be asked for where the law requires it.

6. Who else sees it

Inside the cooperative, only the people who need it: whoever answers enquiries, and — for a pitch — the members who evaluate it.

Outside it, our hosting provider and our e-mail provider process data on our behalf as processors under Article 28, under written agreements that restrict them to our instructions. We will name our current processors on request — write to info@foolhardyhorizons.net.

We may disclose data where we are legally obliged to, for example to a public authority acting under a valid legal basis. We do not sell, rent or trade personal data, and we do not share it with advertising networks.

7. Transfers outside the EU/EEA

Where a processor we use stores or accesses data outside the European Economic Area, that transfer takes place under an adequacy decision of the European Commission or under the EU Standard Contractual Clauses, together with any additional measures the transfer requires. You can ask us which safeguard applies to a given processor.

8. How long we keep it

• General enquiries: 24 months from the last message in the exchange, then deleted.
• Pitch submissions and our notes on them: 24 months, then deleted, unless a contract results — in which case the contract's own retention terms apply.
• Abuse-prevention records: one hour.
• Server logs: kept for as long as our hosting provider's standard log rotation, and not used for any purpose other than operating and securing the service.
• Accounting records relating to an actual business relationship: five years from the end of the financial year they concern, as required by the Danish Bookkeeping Act.

9. Your rights

Under the GDPR you have the right to:

• ask what personal data we hold about you, and get a copy (Article 15);
• have inaccurate data corrected (Article 16);
• have data deleted where one of the grounds in Article 17 applies;
• have processing restricted in the cases in Article 18;
• receive data you gave us in a portable format, where Article 20 applies;
• object to processing based on legitimate interest, on grounds relating to your particular situation (Article 21).

Write to info@foolhardyhorizons.net. We answer within one month. There is no charge, unless a request is manifestly unfounded or excessive.

If you are not satisfied with how we handle it, you may complain to the Danish Data Protection Agency, Datatilsynet, Carl Jacobsens Vej 35, 2500 Valby, Denmark — datatilsynet.dk.

10. Security

The site is served over HTTPS with HTTP Strict Transport Security. It sends a strict Content-Security-Policy that permits no third-party scripts, no framing and no inline script other than our own structured data. Form submissions are protected against cross-site request forgery and rate-limited. Access to submissions is limited to the people who need it. No system is perfectly secure, and we will notify you and Datatilsynet where a breach requires it under Articles 33 and 34.

11. Children

This website is aimed at studios, press and business contacts. It is not directed at children, and we do not knowingly collect personal data from children through it. Age ratings and content notices for individual games are shown on the relevant store pages and on our games page.

12. Changes to this policy

If we change how we handle personal data, we update this page and the version number at the top of it before the change takes effect. The version recorded against your submission is the wording that was on screen when you sent it.

Foolhardy Horizons F.M.B.A · CVR 45344088 · VAT DK45344088 · Borups Allé 138, 1. tv, 2000 Frederiksberg, Denmark · info@foolhardyhorizons.net