Privacy Policy
1. Introduction and Identity of the Controller
Welcome to Laenethy Writers, a digital magazine for writers and publishing professionals operated by Harbinger Bros. LLC, a limited liability company incorporated under the laws of the State of Wyoming, United States, with its principal place of business at 1309 Coffeen Avenue, Sheridan, WY 82801, United States (“we,” “us,” “our,” or “the Company”).
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and equivalent legislation in the European Economic Area (“EEA”), Harbinger Bros. LLC acts as the data controller in respect of personal data collected through this website.
We can be reached by email at support@harbingerpressmedia.com. We do not maintain a dedicated Data Protection Officer at this time, as we do not engage in large-scale systematic processing of special categories of personal data; however, all data protection enquiries are handled directly by our compliance team at the address above.
2. Scope and Territorial Application
This Privacy Policy applies to all visitors and users of laenethy.com regardless of their location. We are subject to multiple privacy frameworks depending on your jurisdiction:
- European Union / EEA visitors: The GDPR applies by virtue of Article 3(2) GDPR, which extends the Regulation to controllers not established in the EU when they offer goods or services to data subjects in the EU or monitor their behaviour within the EU.
- United Kingdom visitors: The UK GDPR and the Data Protection Act 2018 apply.
- California residents: The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”), applies.
- Wyoming residents: The Wyoming Data Privacy Act applies where applicable.
- Canadian visitors: The Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation apply.
- All other visitors: We apply reasonable data protection standards consistent with the principles set out in this Policy.
3. What Personal Data We Collect
We collect and process only the minimum personal data necessary to operate our publication. We do not require user registration, maintain user accounts, run advertising networks, or deploy behavioural profiling technologies. We do use a single, cookie-less, anonymous analytics tool to measure aggregate visitor numbers — see “Anonymous Web Analytics” below.
Anonymous Web Analytics
To measure aggregate visitor numbers, we use Vercel Web Analytics, a service provided by Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA). This tool collects only aggregated, non-personal metrics such as page views, referrers, and approximate country-level location. It does not set cookies, does not permanently store IP addresses, and does not re-identify or track visitors across sessions or websites. The legal basis for this processing is our legitimate interest in understanding how our website is used (Art. 6(1)(f) GDPR). No consent is required for this processing, as no information is stored on or read from your device within the meaning of § 25 TDDDG / Art. 5(3) ePrivacy Directive. Further information: Vercel Web Analytics privacy documentation.
3.1 Data Collected Automatically by Our Infrastructure
When you access laenethy.com, certain technical data is automatically processed by our infrastructure providers as part of the delivery of our web service. This includes:
- IP address: Your Internet Protocol (IP) address is processed by Vercel Inc. (“Vercel”), our hosting provider, for the purpose of routing network requests, detecting abuse, and maintaining service security. Vercel may retain server access logs for a limited period in accordance with its own data retention policies.
- HTTP request metadata: This includes your browser type and version (User-Agent string), referring URL, requested URL path, timestamp of the request, and HTTP response codes.
- TLS/SSL connection data: Technical data required to establish a secure encrypted connection to our servers.
We do not independently store these server logs beyond the retention periods set by Vercel's standard infrastructure logging. We do not use IP addresses to identify individual users or to build profiles.
3.2 Data You Voluntarily Provide
Laenethy Writers offers a contact form at /contact. If you use it, we collect and store your name, email address, and message content in our application database in order to respond to your inquiry. This data is stored via our database provider, Supabase Inc., and is accessible only to authorised personnel who handle correspondence. Legal basis: Art. 6(1)(b) GDPR (necessary to respond to your request) or, where no contractual relationship is established, Art. 6(1)(f) GDPR (legitimate interest in handling incoming communications). We retain contact form submissions for as long as necessary to address your inquiry and for a reasonable period thereafter for documentation purposes, typically no longer than 12 months, unless a longer retention period is required by law. You may request earlier deletion of your message at any time by contacting us. We do not offer comment sections or newsletter subscriptions.
3.3 Data Stored in Your Browser (localStorage)
We store one (1) item in your browser's localStorage:
| Key | Purpose | Data stored | Duration |
|---|---|---|---|
hpm_cookie_consent | Records your cookie consent decision so we do not repeatedly prompt you | A string value indicating consent status (e.g., “accepted” or “declined”) | Persistent until manually cleared |
This localStorage entry is technically necessary for the operation of our consent management system. It does not contain any unique identifier, does not transmit data to any server, and is not used for tracking or advertising purposes.
4. Legal Bases for Processing (GDPR)
For visitors subject to the GDPR or UK GDPR, we rely on the following legal bases under Article 6 GDPR:
- Article 6(1)(f) GDPR — Legitimate Interests: The automatic processing of your IP address and HTTP request metadata by our hosting infrastructure is necessary for our legitimate interests in maintaining a secure, functional, and reliable website, and in detecting and preventing abuse.
- Article 6(1)(c) GDPR — Legal Obligation: We may process personal data where necessary to comply with applicable legal obligations, including responding to lawfully issued court orders or regulatory demands.
- Article 6(1)(a) GDPR — Consent: Where we ask for your consent (for example, in relation to optional features not yet deployed), processing will only occur upon your freely given, specific, informed, and unambiguous consent. You may withdraw any consent given at any time without detriment.
5. International Data Transfers
As a US-based company using US and international cloud infrastructure, some processing of personal data occurs outside your home jurisdiction.
5.1 Transfers to the United States
Our primary hosting provider, Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA), processes server-side request data in the United States. Vercel participates in the EU-US Data Privacy Framework as established by Commission Implementing Decision (EU) 2023/1795 of 10 July 2023, which provides an adequacy decision for transfers to certified US organisations. We also rely on Standard Contractual Clauses pursuant to Article 46(2)(c) GDPR as a supplementary transfer mechanism.
5.2 Database Services
We use Supabase Inc. as our database provider. Supabase processes data under a Data Processing Agreement compliant with GDPR requirements. Data is stored in geographically distributed data centres and protected by industry-standard encryption at rest and in transit.
5.3 Image Delivery (Unsplash)
Article images may be hosted on and served directly from Unsplash (Unsplash Inc., Montreal, QC, Canada). When your browser loads an image from Unsplash servers, Unsplash may receive your IP address and standard browser request headers as part of the HTTP connection. We have no control over Unsplash’s data processing. Unsplash’s privacy policy: unsplash.com/privacy
6. Your Rights Under GDPR and UK GDPR
If you are located in the European Economic Area or the United Kingdom, you have the following rights regarding your personal data:
- Right of access (Art. 15 GDPR): You have the right to obtain confirmation of whether we process your personal data and, if so, to receive a copy of that data and information about how it is used.
- Right to rectification (Art. 16 GDPR): You have the right to have inaccurate personal data corrected without undue delay.
- Right to erasure (Art. 17 GDPR): You have the right to request the deletion of your personal data where one of the grounds set out in Article 17 applies.
- Right to restriction of processing (Art. 18 GDPR): You have the right to request that we restrict the processing of your personal data in certain circumstances.
- Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
- Right to object (Art. 21 GDPR): You have the right to object to processing based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds which override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defence of legal claims.
- Right not to be subject to automated decision-making (Art. 22 GDPR): We do not engage in automated decision-making or profiling that produces legal or similarly significant effects.
- Right to lodge a complaint: You have the right to lodge a complaint with your national data protection supervisory authority. In the EU, a list of supervisory authorities is available at edpb.europa.eu. In the UK, the relevant authority is the Information Commissioner's Office (ICO) at ico.org.uk.
To exercise any of these rights, please contact us at support@harbingerpressmedia.com. We will respond to your request within 30 days.
7. Rights of California Residents (CCPA/CPRA)
California residents have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
- Right to Know: The right to know what personal information we collect, use, disclose, and sell.
- Right to Delete: The right to request deletion of personal information we have collected, subject to certain exceptions.
- Right to Correct: The right to request correction of inaccurate personal information.
- Right to Opt-Out: The right to opt out of the sale or sharing of personal information. We do not sell or share personal information as defined by the CCPA/CPRA.
- Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined by the CCPA/CPRA.
- Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
To submit a California privacy request, contact us at support@harbingerpressmedia.com with the subject line “California Privacy Request.”
8. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Server-side infrastructure logs maintained by Vercel are subject to Vercel's own retention policies (typically 30 days for standard logs). LocalStorage data remains in your browser until you manually clear your browser data or site data.
9. Security
We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. All data transmitted between your browser and our servers is encrypted using industry-standard TLS encryption. Our database is protected by row-level security policies and access controls.
10. Children's Privacy
Our Website is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected such data, please contact us immediately at support@harbingerpressmedia.com.
11. Additional Jurisdictions (Australia, India, South Korea)
Australia
If you are located in Australia, the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) apply to our processing of your personal information. You have the right to access and seek correction of your personal information, and to lodge a complaint about a potential breach of the APPs. Complaints may be directed to us at support@harbingerpressmedia.com and, if unresolved, to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
India
If you are located in India, the Digital Personal Data Protection Act, 2023 (“DPDP Act”) applies to our processing of your personal data. As a Data Principal, you have the right to obtain a summary of the personal data we process about you, the right to correction and erasure of your personal data, and the right to grievance redressal. To exercise these rights or raise a grievance, contact support@harbingerpressmedia.com. Unresolved grievances may be escalated to the Data Protection Board of India.
South Korea
If you are located in South Korea, the Personal Information Protection Act (“PIPA”) applies to our processing of your personal information. You have the right to access, correct, delete, and suspend the processing of your personal information. To exercise these rights, contact support@harbingerpressmedia.com. Complaints may also be directed to the Personal Information Protection Commission (PIPC) of the Republic of Korea.
12. Notification of Personal Data Breaches (Art. 33–34 GDPR)
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it (Art. 33 GDPR). Where a breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay (Art. 34 GDPR), describing the nature of the breach and the measures taken or proposed.
13. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The date of the most recent revision appears at the top of this page. We encourage you to review this Policy periodically. Where changes are material, we will take reasonable steps to notify you.
14. Contact
For any questions, concerns, or requests relating to this Privacy Policy or our data practices:
Harbinger Bros. LLC
1309 Coffeen Avenue
Sheridan, WY 82801
United States
Email: support@harbingerpressmedia.com