Legal
Privacy policy.
This policy explains how personal data is handled when you visit the Portico Play website at porticoplay.com or contact the studio. It is written to meet the EU General Data Protection Regulation (GDPR). It does not cover the Portico console or the campaign pages, which have their own notices.
1. Who is responsible
Portico Play is a product and trading name of Luminbrane AB (org. no. 559523-4245, VAT SE559523424501), Stockholm, Sweden. Luminbrane AB is the data controller for personal data processed through this website. You can reach us at [email protected].
2. What this policy covers
The public website: its pages, the contact link and, if you agree to it, website analytics. The Portico console at console.porticoplay.com and the campaign pages at play.porticoplay.com process customer and participant data under separate agreements. Anyone who has taken part in a campaign should read the notice shown on that campaign; the business running it decides the offer, eligibility and fulfilment.
3. What we process, why, and on what basis
Delivering and protecting the website
The site is static HTML served by Cloudflare. Cloudflare processes technical request data, such as your IP address, browser type and the page requested, to deliver pages and defend against abuse. We do not receive or keep logs of individual visitors. Legal basis: our legitimate interest in operating a secure website, Article 6(1)(f) GDPR.
Website analytics, only with your consent
If you accept analytics in the cookie banner, we use Google Analytics 4 to understand which pages are read and how visitors arrive. It records pages viewed, the referring site, browser and device type, approximate location derived from your IP address (the address itself is not stored) and a pseudonymous identifier kept in the _ga cookies. We do not use advertising features or Google Signals, and we do not combine analytics with any information that identifies you. Analytics is delivered through Google Tag Manager, a container that loads measurement scripts and sets no cookies of its own. Until you accept, no Google script is loaded and no analytics cookie is set. Legal basis: your consent, Article 6(1)(a) GDPR, which you can withdraw at any time through Cookie settings in the footer. Retention: analytics event data is kept for no longer than 14 months.
Enquiries
The contact form sends your message by email to the studio mailbox through Resend, our email delivery provider; this website keeps no copy of it. Form enquiries are also passed to Portico’s own sales system so the studio can follow up, and are kept there no longer than needed. You can also email us directly. Either way we process what you send: typically your name, email address, company and the content of your message. We use it to answer you and to prepare any proposal or agreement you ask for. Legal basis: steps taken at your request prior to a contract, Article 6(1)(b) GDPR, and our legitimate interest in responding to business enquiries, Article 6(1)(f). We keep enquiry correspondence for as long as the conversation and any business relationship that follows require, and review it at least every two years. Please do not include customer records, identity documents or other sensitive information in an initial enquiry.
4. Who receives data
We do not sell personal data. It is shared only with service providers who process it on our instructions:
- Cloudflare, Inc. — hosting and content delivery for porticoplay.com.
- Google Ireland Limited — Google Analytics 4 and Google Tag Manager, only after you have consented.
- Resend, Inc. — delivers contact form messages to the studio mailbox as email.
- Our email provider — for correspondence you send to the studio mailbox.
Data may also be disclosed where the law requires it or to protect our rights.
5. Transfers outside the EU/EEA
Cloudflare, Resend and Google may process data in the United States and other countries. Where that happens, transfers rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework and on Standard Contractual Clauses, with additional safeguards where needed.
6. Cookies and local storage
The cookie policy lists every cookie and storage item the site may use, how long each lasts and how to change your choice.
7. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict processing;
- receive your data in a portable format;
- object to processing based on legitimate interest, including any direct marketing;
- withdraw consent at any time, without affecting processing that happened before you withdrew it.
To exercise any of these rights, email us at [email protected]. We answer within one month. You also have the right to lodge a complaint with a supervisory authority. In Sweden that is the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (IMY), imy.se; you may instead contact the authority where you live or work.
8. Children
This is a business-to-business website. It is not directed at children and we do not knowingly collect data from anyone under 18.
9. Security
The site is served over HTTPS only, has no user accounts and stores no visitor data of its own; the contact form relays your message and keeps nothing. Our providers apply industry standard technical and organisational measures.
10. Changes to this policy
When we change how the website processes personal data we update this page and the date at the top. Material changes, such as adding a new processor, are announced here before they take effect.