Privacy Policy

Data controller

The controller of your data is Eryk Panter, who publishes the game as 5lamp. For anything about your personal data, write to contact@holyholyholy.pl.

Purpose and legal basis

We process the e-mail address from the sign-up form to send a newsletter about the game’s launch and new materials (including the printable file you request on the blog) — on the basis of your consent (GDPR Art. 6(1)(a)), given by clicking the confirmation link in the e-mail (double opt-in). Without that click the address never reaches the list. We process the message and e-mail address from the contact form to answer your question — on the basis of the controller’s legitimate interest (GDPR Art. 6(1)(f)) in handling correspondence.

Data you give when ordering (full name, e-mail, phone, locker code, billing address) is processed to perform the sales contract and deliver the parcel (art. 6(1)(b) GDPR), and sales records are kept because tax and accounting law requires it (art. 6(1)(c) GDPR).

Recipients of data

We share data with these service providers — Resend and Railway process it on our behalf as processors, Stripe and InPost as recipients needed for payment and delivery:

Resend — sending e-mail

Resend, Inc. is based in the United States and participates in the EU–US Data Privacy Framework (DPF), which is the legal basis for transferring data outside the European Economic Area. Resend sends the sign-up confirmation e-mail and delivers messages from the contact form.

Railway — hosting

Railway runs the server this site is served from, and keeps the technical logs (IP address, timestamp) needed to operate and secure the service.

Stripe — payments

Stripe Payments Europe Ltd. (Ireland) handles BLIK, Przelewy24 and card payments and the order page. We never see card or account details — only Stripe does, acting as a separate controller for payments under its own privacy policy.

InPost — delivery

InPost sp. z o.o. receives your name, phone, e-mail and locker code in order to deliver the parcel.

Analytics

We measure site traffic with Umami — it works without cookies and collects no data that could identify an individual, so no consent banner is needed. The HOLY! HOLY! HOLY! game (Circle of Saints) carries no analytics at all — nothing is measured on children.

Conversation assistant (ElevenLabs)

On the home page, the presale page and "About us" you can talk to an assistant — by voice or in writing. The chat panel may open by itself, but nothing from ElevenLabs loads until you send a message or click "Talk". From then on your voice (if you turn on the microphone — the browser always asks first) and the content of the conversation go to ElevenLabs, Inc. (USA), which processes them on our behalf: it turns speech into text, prepares the answer and reads it aloud.

The legal basis is our legitimate interest in answering questions about the game and orders (Art. 6(1)(f) GDPR); you start the conversation yourself and can end it at any time. Data is transferred to the USA under the standard contractual clauses in our data processing agreement with ElevenLabs. We create no identifier that links your visits and do not use conversations for marketing. Conversation records are deleted after 30 days. Please do not share sensitive data or data about children in the conversation.

Retention period

We keep the e-mail address from the sign-up list until you unsubscribe (link in every e-mail’s footer) or until the launch campaign ends. We keep a contact-form message as long as we need it to handle the matter it concerns.

Order data is kept for 5 years from the end of the year of sale (tax law) and, in case of a complaint or dispute, until it is resolved.

Your rights

You have the right to access your data, to have it rectified or erased, to restrict its processing, to data portability, and to object to processing. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (uodo.gov.pl). You can exercise any of these rights by writing to the address below.

Contact

For anything concerning personal data, write to contact@holyholyholy.pl.