Lightford brand logoNightink InteractiveLightford Production Hub

GDPR Art. 13 / 14

Privacy Policy

This notice explains how personal data is processed in the Lightford Production Hub at kev2block.win, the internal production tool of Nightink Interactive. The public game website at welcometolightford.com has its own separate notice.

The street address and telephone number below are still placeholders. They will be replaced with the real operator details used in the Impressum.

1. At a glance

The Hub is a closed workspace for a small studio team. It has no public visitors, no registration, no advertising, no analytics and no marketing trackers. Access requires a Discord account on the studio's allowlist.

Three groups of people can appear in the data: team members who sign in and work in the Hub; people mentioned in workspace content such as issues or attachments; and people who commented publicly on the studio's own social media posts, whose comments the Hub mirrors into a reading inbox. The third group is covered by Art. 14 GDPR, since that data does not come from the person directly — see section 9.

2. Controller

The controller for data processing on this website is:

  • Nightink Interactive GbR
  • Street and house number, Postcode City, Germany
  • Telephone: telephone number
  • Email: [email protected]

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

3. Hosting and delivery

Hetzner

The origin server is provided by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. Details are in Hetzner's privacy policy. Use of Hetzner is based on Art. 6 (1)(f) GDPR — we have a legitimate interest in reliable operation. A data processing agreement (AVV) is in place.

The application, its PostgreSQL database, uploaded attachments and backups all live on this one server. No external database, object storage or analytics service is used.

Cloudflare

Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, sits in front of the server as reverse proxy, DNS and TLS layer. Every request is routed through Cloudflare, which may process your IP address, request time, requested resource, response status and browser information in order to deliver, encrypt and protect the site. Cloudflare is not used here for analytics, advertising, audience measurement or a captcha.

Legal basis: Art. 6 (1)(f) GDPR (secure, available delivery). Cloudflare acts as a processor; see Cloudflare's privacy policy. This may involve transfer of personal data to the United States and other third countries, covered by the EU–US Data Privacy Framework and/or standard contractual clauses.

4. Server log files

The server automatically records information that your browser transmits: browser type and version, operating system, referrer URL, host name of the accessing computer, time of the request and IP address. This data is not merged with other data sources. Legal basis: Art. 6 (1)(f) GDPR — legitimate interest in technically error-free operation. Hetzner and Cloudflare may each keep such logs as part of hosting and reverse-proxy operation.

5. Signing in with Discord

The only way into the Hub is Discord OAuth with the identify scope. When you start sign-in, Discord Inc. (USA) processes your IP address and Discord account identifiers, and returns your Discord user id, username and avatar reference to the Hub.

The Hub stores, for each member:

  • Discord user id, Discord username and avatar reference;
  • a display name, role (admin or member) and an active/inactive flag;
  • your notification preferences.

It does not store your Discord email address, your friends, your servers or your message history. Sign-in attempts are rate-limited per IP address to prevent scripted guessing of allowlisted ids. Discord accounts that are not on the allowlist are refused and no account is created.

Legal bases: Art. 6 (1)(b) GDPR for members whose access is part of their working relationship with the studio, and Art. 6 (1)(f) GDPR for secure operation and access control. Transfer to a third country (USA) is involved; see Discord's privacy policy.

6. Cookies

This website uses no advertising, analytics, profiling or marketing cookies, and there is no consent banner because there is nothing optional to accept or reject.

The only cookie set is the session cookie issued by the authentication library after you successfully sign in with Discord (name authjs.session-token, served with the __Secure- prefix over HTTPS). It is HTTP-only, SameSite, and holds a signed token identifying your session. Someone who never signs in never receives a cookie from this site — including on these legal pages.

Legal basis: § 25 (2) no. 2 TDDDG, since the cookie is strictly necessary to provide the login you requested, together with Art. 6 (1)(f) GDPR for the underlying processing. You can configure your browser to refuse or delete cookies; the Hub cannot keep you signed in if you do.

7. Workspace content

Working in the Hub creates records: issues, comments, sprints, tags, categories, board positions, calendar entries, activity history and file attachments. These are tied to the member who created them and timestamped. Attachments are stored on the same server, not with a third-party file host, and are only served to signed-in members.

Content you write may itself contain personal data — a colleague's name in an issue, a person visible in a screenshot. Please only enter such material where there is a proper basis for it. Legal basis: Art. 6 (1)(b) and (f) GDPR — performing the studio's work and the legitimate interest in an organised production record.

8. Discord notifications

The Hub can notify members about workspace events through a Discord bot — either as a direct message to the member, or to a studio channel through a webhook. To do this it sends the relevant event text and your Discord user id to Discord. Notifications can be turned off per member and per event type in Settings. If your Discord privacy settings block direct messages from the bot, the Hub stops trying.

Legal basis: Art. 6 (1)(f) GDPR — keeping the team informed about its own work.

9. Connected social media channels

An authorised member can connect the studio's own channels on YouTube, TikTok, Instagram, Facebook, X, Reddit and Bluesky. Connecting always runs through the platform's own login and consent screen; the Hub never sees your platform password. The Hub requests read-only access and never posts, comments, deletes, follows or advertises.

What is stored

  • Channel identity: the platform's account id, handle, display name, avatar URL and profile URL.
  • Access credentials: the access token and, where the platform issues one, a refresh token. These are encrypted at rest with AES-256-GCM under a key held only in the server configuration, and are used exclusively to refresh the statistics shown in the Hub.
  • Daily statistics: one snapshot per channel per day of follower count, views, likes, comments and shares, so the dashboard can draw growth over time.
  • Recent posts: title or caption, permalink, thumbnail URL, publication date and the per-post counters.
  • Comments on those posts — see the next paragraph.

Comments by third parties (Art. 14 GDPR)

For YouTube, Instagram, Facebook, Reddit and Bluesky, the Hub mirrors comments left on the studio's own posts into a read-only inbox, so the team can see and answer them in one place. For each comment it stores the commenter's display name, their handle where the platform provides one, their avatar URL, the comment text, its like count, its permalink and its publication time. TikTok and X are not included, because their APIs do not expose comment text.

This data is not collected from the commenter directly but from the platform, which is where the person chose to publish it publicly. Source categories are therefore the public APIs of the platforms named above. Legal basis: Art. 6 (1)(f) GDPR — the studio's legitimate interest in reading and responding to public feedback on its own channels. The data is not used for profiling, advertising or any purpose beyond that. The Hub replies to nobody automatically; answering a comment happens on the platform itself.

If you commented on one of the studio's posts and want that copy removed from the Hub, write to the address in section 2 and it will be deleted. Deleting the comment on the platform also removes it from the Hub at the next synchronisation.

Recipients and third countries

Synchronisation means the server calls the platform APIs roughly every 30 minutes. The recipients are therefore Google Ireland/LLC (YouTube), TikTok Technology Limited / ByteDance, Meta Platforms Ireland (Instagram, Facebook), X Corp., Reddit Inc. and Bluesky Social PBC, each under its own privacy policy. Several are established outside the EU, so transfers to third countries — chiefly the USA — take place.

Ending a connection

Disconnecting a channel in Settings deletes its stored credentials, statistics, posts and mirrored comments from the Hub. You can additionally revoke the Hub's access from the platform's own account security settings, which stops all further synchronisation.

10. Code review and AI processing

The Hub reads the studio's source repository from a self-hosted Gitea instance on the same server, using a dedicated service token. No third party is involved in that step.

The optional AI code review is different: when a member deliberately starts a review, the selected code and the review prompt are sent to the configured AI provider — Anthropic and/or OpenAI, depending on the model chosen — and the result is stored with the issue. Anything contained in the reviewed code, including any personal data in it, is transmitted to that provider, which is a transfer to the USA. The feature does nothing unless configured and explicitly run. Legal basis: Art. 6 (1)(f) GDPR — legitimate interest in code quality.

11. Calendar feed

The Hub can publish an iCal feed so members can subscribe to studio dates from their own calendar app. The feed is reachable without signing in and is protected only by a secret token in its URL. Your calendar application will fetch that URL periodically, which appears in the server logs described in section 4. Anyone who obtains the URL can read the feed, so it should be regenerated if it is ever exposed.

12. Requests your browser makes to third parties

  • Discord CDN: member avatars are loaded directly from cdn.discordapp.com, so your browser contacts Discord when the Hub displays them.
  • Platform CDNs: on the social dashboard, channel avatars and post thumbnails are loaded from the respective platform's image servers.
  • Fonts: the interface fonts are bundled into the application at build time and served from this server. Your browser makes no request to Google Fonts or any other font CDN.
  • No trackers: no advertising, analytics, tag manager, session recorder, captcha or embedded third-party video player is loaded anywhere in the Hub.

13. Backups

The workspace database and uploaded files are backed up automatically to the same server so the studio can recover from mistakes and failures. Backups contain the personal data described above and are retained on a rolling basis. Because a backup is a point-in-time copy, data erased from the live workspace may persist in backups until those are rotated out. Legal basis: Art. 6 (1)(f) GDPR — data security and continuity.

14. Storage periods

Unless stated otherwise above, personal data remains until the purpose for processing ceases to apply. In practice:

  • Member accounts remain while the person works with the studio; deactivation ends access, and the record can be deleted on request.
  • Workspace content remains as part of the production record until deleted by the team.
  • Social credentials, statistics, posts and mirrored comments are deleted when the channel is disconnected.
  • Server logs are kept only as long as needed for security and troubleshooting.

Statutory retention obligations — in particular tax and commercial law periods — remain unaffected, and deletion then takes place after those periods end.

15. Your rights

You have the right to free information about your stored personal data, its origin, recipients and the purpose of processing, and a right to rectification or erasure. You have the right to request restriction of processing, and the right to data portability for data processed on the basis of consent or a contract, in a common machine-readable format where technically feasible.

Right to object (Art. 21 GDPR): where processing is based on Art. 6 (1)(e) or (f) GDPR, you may object at any time on grounds relating to your particular situation. We will then stop processing the affected data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. No direct marketing and no profiling of visitors takes place in the Hub.

Where processing rests on consent, you may revoke it at any time with effect for the future; the lawfulness of processing carried out until revocation is unaffected.

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. To exercise any of these rights, contact the address in section 2.

16. TLS encryption

This site uses TLS encryption for security and to protect the transmission of confidential content. You can recognise an encrypted connection by https:// in the address bar and the lock symbol in your browser.

17. Changes

This notice is updated when the Hub changes. The date below is the current version.

Last updated: August 2026