Version: 1.2 · Effective from: 2026-06-10

This policy explains how Imagination Studio handles personal information. It is written to be honest and minimal, because we deliberately collect very little. A central point: our merchant-of-record (currently Lemon Squeezy) handles the checkout and collects buyer payment and contact data as the seller — much of the data handling sits with them, not us.

1. Who is responsible

Lucid Websites (Pty) Ltd (trading as Imagination Studio), Cape Town, South Africa, is the responsible party / data controller for the limited personal information described below. Jon Pullen, in his capacity at Lucid Websites (Pty) Ltd, is the Information Officer under section 55 of the South African Protection of Personal Information Act (POPIA). Contact for any privacy matter: lucidwebsites@gmail.com.

2. What we collect, and what the merchant-of-record collects

What the merchant-of-record collects (as seller): when you buy a Drop, the merchant-of-record collects and processes your name, email, billing details, and payment information to complete the sale, deliver the download, handle tax, and provide receipts. This is governed by the merchant-of-record's own privacy policy, not this one. We receive from them only limited order information (e.g. that a sale occurred, the buyer's email for delivery and support, the product purchased).

What we collect directly:

If you email us, your email address and the content of your message, to respond and provide support.
Studio notes (mailing list). If you subscribe, your email address, so we can send occasional product announcements (a short note when a new drop ships). This marketing list is kept separate from buyer data and from analytics. We use MailerLite to store the list and send the emails; MailerLite acts as our processor. You join only by confirming a double opt-in email, and you can unsubscribe from any message.
Site analytics. We use Google Analytics 4 to understand how the Site is used and which drops resonate. Google acts as our processor. It sets first-party cookies and gives us aggregate usage such as pages viewed, approximate location derived from IP (we do not retain the IP), and device and browser type. We have disabled advertising features and ad personalisation, and we do not build profiles or use this for marketing. You can opt out with a browser-level control or Google's opt-out add-on, as described in our Cookie Policy.

We do not run advertising trackers, sell personal information, or build buyer profiles.

3. Why we use it (lawful basis)

To deliver the product you purchased and provide support (performance of a contract / legitimate interest).
To respond to enquiries you send us (legitimate interest / your request).
To send you studio notes, if you have subscribed (consent, which you give by confirming the double opt-in email and can withdraw at any time by unsubscribing).
To understand how the Site is used and improve it (analytics, on the basis of our legitimate interest); you can opt out as described in our Cookie Policy.
To meet legal and tax-record obligations where they apply.

4. Who we share it with

The merchant-of-record as seller and payment handler (their privacy policy applies).
Service providers strictly needed to run the business (e.g. email, hosting).
Google (Google Analytics) as our analytics processor. Google processes the data on our behalf under its data processing terms.
MailerLite as our newsletter processor, if you subscribe to studio notes. MailerLite stores your email and sends our notes on our behalf, under its own data processing terms.
Authorities where required by law.

We do not otherwise share or sell your information.

5. International transfers

Because we use international services (the merchant-of-record, our analytics provider, our newsletter provider MailerLite, and hosting/CDN providers are outside South Africa), your information may be processed in other countries. Those providers operate under their own data-protection commitments, including standard contractual protections where applicable, and transfers are conducted under safeguards intended to satisfy POPIA section 72 and (where relevant) GDPR Chapter V requirements.

6. How long we keep it

Support correspondence kept for up to 2 years after the last interaction, then deleted, unless we are required by law to keep it longer.
Mailing-list data kept until you unsubscribe or ask us to delete it, after which your address is removed from the active list.
Order records kept for the periods required by South African tax law (typically 5 years) and then deleted.
Other personal information kept only as long as needed for the purpose it was collected.

7. Your rights

Depending on where you live (e.g. under POPIA in South Africa, or GDPR in the EU), you may have rights to access, correct, delete, or object to the processing of your personal information, and to lodge a complaint with a regulator (the SA Information Regulator at inforegulator.org.za, or your EU national supervisory authority). To exercise any right regarding data we hold, email lucidwebsites@gmail.com. For data the merchant-of-record holds as seller, contact the merchant-of-record directly.

EU residents. Imagination Studio does not currently meet the criteria requiring an EU representative under GDPR Article 27 (processing is occasional, involves no large-scale special-category data, and is low-risk). If this changes, we will appoint a representative and update this policy.

8. Children

The Site and products are not directed at children, and we do not knowingly collect children's data.

9. Changes

We may update this policy; the version on the Site applies, and the "Last updated" date reflects changes.

10. Contact

lucidwebsites@gmail.com.