Base Pixel d.o.o. ("we," "our," or "us") is committed to protecting your privacy, ensuring transparent data processing, and complying fully with Regulation (EU) 2016/679 (General Data Protection Regulation / GDPR) and the Croatian Act on the Implementation of the General Data Protection Regulation (Zakon o provedbi Opće uredbe o zaštiti podataka, NN 42/18).
This Privacy Policy explains how we collect, store, process, transfer, and delete your personal data when you:
Subscribe to our newsletter campaign for Minesleeper ("Minesleeper newsletter" or "newsletter campaign").
Contact us via our official business e-mail address (contact at clickeasygames dot com) or otherwise engage in direct business communication with us.
Interact with our games, store pages, and community features on the Steam platform (operated by Valve Corporation).
Interact with our official social media pages, community profiles, and public channels on BlueSky, Discord, Facebook, Instagram, Reddit, TikTok, Threads, X, and YouTube.
1. DATA CONTROLLER IDENTIFICATION
The legal entity responsible as the Data Controller under Article 4(7) GDPR is:
Base Pixel d.o.o.
Markuševečka cesta 13
10000 Zagreb, Croatia
OIB (Personal Identification Number): 80916691257
Contact e-mail: contact at clickeasygames dot com
2. THE DATA WE COLLECT
A. MINESLEEPER NEWSLETTER
We collect and process your personal data only if and when you voluntarily provide it by opting into our newsletter campaign.
Data Collected: E-mail address.
Purpose: To send updates, news, development announcements, and promotional content related to Minesleeper.
Sharing: We do not sell your e-mail address under any circumstances. We do not share your e-mail address with third parties, except with our automated newsletter platform processor, MailerLite, strictly for managing and sending newsletter campaigns.
B. BUSINESS AND DIRECT CONTACT INQUIRIES
When you reach out to us via contact at clickeasygames dot com or other direct channels, we collect the personal data you choose to provide.
Data Collected: Your e-mail address and any personal data voluntarily provided within the subject line, body, or attachments of your message (e.g., name, phone number, company affiliation).
Purpose: To respond to incoming correspondence, handle support requests, negotiate or execute contracts, manage vendor/partner relations, and maintain operational business records.
C. STEAM PLATFORM DATA
When you interact with Minesleeper on the Steam platform:
Data Collected:
Minesleeper Internal Telemetry: Features its own proprietary telemetry system that collects aggregated, non-identifiable gameplay statistics to help us balance and improve the experience.
Steam Platform Telemetry & Data: Aggregated telemetry data provided via Steamworks (player counts, crash reports, wishlist metrics) and Steam IDs where technical integration requires it.
Minesleeper Internal Telemetry Control / Opt-Out: Can always be turned off at any time directly within the Minesleeper and Minesleeper Demo settings.
Independent Controller Notice: Valve Corporation acts as an independent Data Controller for your primary Steam account details and purchasing transactions.
D. SOCIAL MEDIA & COMMUNITY PLATFORMS
When you visit, follow, comment on, react to, message, or join our official social media pages and community hubs:
Data Collected: Public profile name/handle, user ID, avatar, public comments, posts, likes, shares, reactions, direct messages, and any additional personal information you voluntarily share.
Joint Controllership Notice: For certain social media platforms, Base Pixel d.o.o. and the respective platform operators act as Joint Controllers for aggregated page insights data.
3. LAWFUL BASIS FOR PROCESSING (GDPR ART. 6)
We process your personal data strictly in accordance with Article 6(1) of the GDPR:
Consent (GDPR Art. 6(1)(a)): For newsletter distribution based on explicit, opt-in consent.
Contract Performance (GDPR Art. 6(1)(b)): When processing is necessary to take steps prior to entering into a contract.
Legitimate Interests (GDPR Art. 6(1)(f)): For business inquiries, social media interactions, and community management.
Legal Obligation (GDPR Art. 6(1)(c)): Where retaining records is required by applicable Croatian or EU legal obligations.
4. HOW WE STORE & SHARE YOUR DATA
We implement appropriate technical and organizational security measures (GDPR Art. 32) to safeguard your personal data:
Newsletter Platform (Processor): Managed via MailerLite with strict DPAs.
E-mail & Direct Messages: Accessed strictly by authorized personnel for routine business communication.
Social Media Operators: Processed on servers of Bluesky, Discord, Google/YouTube, Meta, Reddit, TikTok, and X.
Data Transfer Outside the EEA: Safeguarded using EU Standard Contractual Clauses (SCCs) or EU Adequacy Decisions.
5. E-MAIL TRACKING TECHNOLOGIES
Our newsletter campaigns utilize built-in tracking tools provided by MailerLite:
Web Beacons / Tracking Pixels: Tiny 1x1 pixel graphics embedded directly within the HTML source code of our newsletter messages. When you open or view the email in your client, this image asset is automatically requested from our server, securely notifying us that the transmission was successfully delivered and opened by the recipient
Tracked Links: Links route through MailerLite to track click-through rates.
You can opt out of open tracking at any time by disabling automatic image loading in your e-mail client software.
6. DATA RETENTION POLICY
Newsletter Subscribers: Retained as long as you remain subscribed; erased within 30 days of unsubscribing.
Business Correspondence: Retained for business operations or statutory accounting periods (typically 11 years under Croatian law).
Steam, Telemetry & Social Media Data: Aggregated analytics retained indefinitely; platform posts remain until removed by you.
7. UNSUBSCRIBING AND DELETION POLICY (NEWSLETTER)
You may opt out of our newsletter at any time using the "Unsubscribe" link included at the footer of every e-mail, triggering immediate suppression and deletion within 30 days.
8. DELETION POLICY FOR DIRECT E-MAILS & SOCIAL MEDIA
We retain communications until an explicit request is submitted to contact at clickeasygames dot com, subject to legal accounting retention exceptions under Croatian law.
9. YOUR RIGHTS UNDER GDPR & CROATIAN LAW
As a data subject, you hold rights under Articles 15–22 GDPR (Access, Rectification, Erasure, Restriction, Portability, and Objection). Contact us at contact at clickeasygames dot com to exercise these rights.
10. RIGHT TO LODGE A COMPLAINT
Agencija za zaštitu osobnih podataka (AZOP)
Selska cesta 136, 10000 Zagreb, Croatia
E-mail: azop@azop.hr | Website: www.azop.hr
11. CONTACT INFORMATION
E-mail address: contact at clickeasygames dot com
Company Name: Base Pixel d.o.o.
Address: Markuševečka cesta 13, 10000 Zagreb, Croatia Last Updated: September 28, 2026
