This Privacy Policy explains how the Church of the Eternal Cluster ("we", "us", "our") collects, uses, and protects personal data when you visit ha-llelujah.dev and its subdomains. We are based in Slovenia and this policy is governed by the General Data Protection Regulation (GDPR) and applicable Slovenian law.
1. Who We Are
The data controller for this website is the operator of ha-llelujah.dev, based in Slovenia, European Union. For data protection enquiries, contact us at: [email protected]
2. What Data We Collect and Why
2.1 Newsletter subscription
When you complete the Rite of Reconciliation and confirm your subscription, we collect:
- Email address — required to send you newsletters
- First name — optional, used to personalise emails
- Date and time of confirmation — to record your consent
- IP address at the time of confirmation — recorded by Brevo as proof of double opt-in consent
Legal basis: Consent (GDPR Article 6(1)(a)). You may withdraw consent at any time by clicking the unsubscribe link in any email or by contacting us.
2.2 Website analytics
With your consent, we use Google Analytics (Google LLC) to collect anonymised data about how visitors use this website, including pages visited, time spent, and approximate geographic region. Google Analytics sets cookies on your device. No data is collected until you accept analytics cookies.
Legal basis: Consent (GDPR Article 6(1)(a)). You may withdraw consent at any time via the cookie settings link in the footer.
2.3 Certificate of Reconciliation
The certificate generated after you confirm your subscription is created and displayed entirely within your browser. We do not store the certificate, your chosen name, or your Member ID on our servers.
2.4 Server logs
Our hosting provider (Cloudflare) automatically records standard server log data including IP addresses, browser type, and pages requested. These logs are retained for up to 30 days for security purposes.
Legal basis: Legitimate interests (GDPR Article 6(1)(f)) — maintaining the security and availability of the website.
3. Who We Share Data With
| Recipient | Purpose | Location | Safeguards |
|---|---|---|---|
| Brevo (Sendinblue SAS) | Newsletter delivery and subscriber management | EU (France) | GDPR-compliant processor; Brevo Privacy Policy |
| Google LLC | Website analytics (Google Analytics) | USA | Standard Contractual Clauses; data anonymised before transfer; Google Privacy Policy |
| Cloudflare Inc. | Website hosting, CDN, DDoS protection | USA / EU | Standard Contractual Clauses; Cloudflare Privacy Policy |
We do not sell your data. We do not share your data with advertisers.
4. How Long We Keep Your Data
- Newsletter subscribers — until you unsubscribe or request deletion
- Analytics data — retained by Google Analytics for 14 months (configured as the shortest available retention period)
- Server logs — up to 30 days
- Consent records — for the duration of your subscription plus 3 years (legal requirement to demonstrate consent)
5. Your Rights Under GDPR
As a data subject within the EU, you have the following rights:
- Right of access — request a copy of the personal data we hold about you
- Right to rectification — correct inaccurate data
- Right to erasure — request deletion of your data ("right to be forgotten")
- Right to restriction — limit how we process your data
- Right to data portability — receive your data in a machine-readable format
- Right to object — object to processing based on legitimate interests
- Right to withdraw consent — at any time, without affecting the lawfulness of prior processing
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
You also have the right to lodge a complaint with the Slovenian supervisory authority: Informacijski pooblaščenec, www.ip-rs.si.
6. Cookies
We use cookies for analytics (with your consent) and for the operation of the website. For full details, see our Cookie Policy.
7. Children
This website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has submitted personal data to us, please contact us and we will delete it.
8. Changes to This Policy
We may update this policy from time to time. The "Last updated" date at the top of this page will reflect any changes. We will notify newsletter subscribers of material changes.
9. Contact
For any privacy-related questions: [email protected]