Privacy policy

1. Who is responsible

lowbrowse media UG (haftungsbeschränkt)
c/o Paul Green
Burgherrenstraße 3
12101 Berlin
Germany

Email: contact@lowbrowse.org

We have not appointed a data protection officer. More details are in the legal notice.

2. Visiting the website (hosting)

The website is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. Vercel's network delivers the pages, and our server functions (sign-up, confirmation, unsubscribe) run in Vercel's Frankfurt region.

When you open a page, your browser sends technical data that Vercel needs to deliver it and may record in server logs: your IP address, the date and time, the address of the page (URL), your browser's identification (user agent) and the page you came from (referrer).

Unsubscribe links in some older emails contain your email address in the page address. If you use one, your email address can appear in these logs. Newer links carry it only in encrypted form.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a website that works and is secure.

3. Language cookie

On every page we set one cookie of our own, NEXT_LOCALE. It stores the language of the page you last opened (en, de or tr), so that the website can open in that language next time. It lasts one year and is sent only to lowbrowse.org.

Legal basis: § 25(2) no. 2 TDDDG, and Art. 6(1)(f) GDPR. Our legitimate interest is showing you the website in your language.

4. Consent manager

The consent window comes from consentmanager AB, Håltegelvägen 1b, 72348 Västerås, Sweden. It loads on every page, before you make a choice, so your browser connects to consentmanager's servers, which receive your IP address and browser data. To remember your choice, it stores a cookie (__cmpcccu…) and entries in your browser's storage whose names begin with cmp or __cmpcccu. It tells the website whether analytics may run. You can change or withdraw your choice at any time under Cookie settings at the bottom of every page.

Legal basis: storing your choice is necessary for the consent window to work (§ 25(2) no. 2 TDDDG). We process your choice because we have to be able to show your consent (Art. 6(1)(c) with Art. 7(1) GDPR).

5. Analytics (PostHog)

Only if you agree, we use PostHog, a product of PostHog Inc., 2261 Market Street #4008, San Francisco, CA 94114, USA. The data goes to PostHog's EU servers, which PostHog states are in Frankfurt.

PostHog records which pages you view, your clicks on the page (never in the consent window), errors in the page, page-speed measurements, and named steps such as opening the sign-up form or clicking a footer link. Technical details about your browser and device and the page you came from are sent with them, and PostHog receives your IP address with each request. A random identifier is stored in a cookie (ph_<key>_posthog) and in your browser's storage, so that your visits can be told apart from other people's. We don't use session recording, heatmaps, surveys or feature flags.

If you withdraw your consent, analytics stops at once in the open page, and the PostHog cookie and storage are deleted from your browser.

Legal basis: your consent (§ 25(1) TDDDG, Art. 6(1)(a) GDPR).

6. Signing up

You can sign up for the beta or for news about the launch. We ask only for your email address. No name.

After you send the form, we email you a confirmation link. We store nothing ourselves at this point: your sign-up travels inside the link, encrypted, and the link works for 7 days. Brevo, which sends the email, keeps a log of it with your address. We use that log so that one address gets at most one confirmation email every 10 minutes.

Only when you click the link does Brevo store you as a contact, with:

• your email address
• your language
• whether you signed up for the beta or for launch news
• whether you also agreed to marketing emails
• when you signed up, which wording you agreed to and how (double opt-in)
• when you confirmed

Without the tick for marketing emails, you are on the launch list only.

Legal basis: your consent (Art. 6(1)(a) GDPR), which you confirm by clicking the link. We keep the record of your consent because we have to be able to show it (Art. 6(1)(c) with Art. 7(1) GDPR).

Giving your email address is voluntary. Without it, you can't sign up.

7. Emails and unsubscribing

Our emails are sent through Brevo, a service of Brevo SAS, 17 rue Salneuve, 75017 Paris, France, from hello@lowbrowse.org.

The welcome email has an unsubscribe link. You can also write to contact@lowbrowse.org. When you unsubscribe, Brevo keeps your address but blocks it, so that no further email is sent to it. Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is respecting your unsubscribe. If you want your address erased completely, write to contact@lowbrowse.org.

8. Who receives your data

The providers named above process your data for us: Vercel (hosting), consentmanager (consent window), PostHog (analytics, only with your consent) and Brevo (emails). We don't sell your data, we show no advertising, and we pass your data to no one else.

Fonts and images come from our own website. The LinkedIn link at the bottom of the page is a plain link: LinkedIn receives nothing until you click it.

9. Transfers outside the EU

Vercel Inc. and PostHog Inc. are US companies. Both state that they take part in the EU-US Data Privacy Framework, for which the European Commission has decided that the level of data protection is adequate (Art. 45 GDPR). Brevo states that some of its service providers are outside the EU and work under the EU-US Data Privacy Framework or the EU's standard contractual clauses.

10. How long we keep data

• Language cookie: one year, renewed each time you open a page.
• Sign-up before confirmation: nothing is stored by us. The confirmation link expires after 7 days.
• Vercel's request logs, Brevo's send log, PostHog's event data and your stored consent choice: kept only as long as the provider's own log or data retention for our account keeps them, and deleted when they are no longer needed for the purpose stated above. The exact durations of these logs are set by the providers.
• Brevo contact: stays on our contact list until you unsubscribe or ask us to erase it. After you unsubscribe, your address stays on Brevo's blocklist only so that your unsubscribe is honoured.
• PostHog cookie and storage: deleted from your browser when you withdraw your consent.

11. Your rights

You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16), erased (Art. 17) or its processing restricted (Art. 18), and to receive it in a portable format (Art. 20). You can withdraw a consent at any time, with effect for the future (Art. 7(3)).

Right to object (Art. 21 GDPR): where we process your data on the basis of Art. 6(1)(f) GDPR, you can object at any time on grounds relating to your particular situation.

To use any of these rights, write to contact@lowbrowse.org. We reply within one month (Art. 12(3) GDPR).

You can also complain to a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is the Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, Germany.

12. No automated decisions

We make no automated decisions about you and do no profiling (Art. 22 GDPR).

13. Changes

We update this policy when the website changes. The date at the top shows the current version.