Privacy

The short version

This site sets no cookies and stores nothing on your device. It has no user accounts and no comment function. The fonts are served from this domain rather than from a font network. There is no advertising, and nothing here follows you to another site.

Three things do involve your IP address, because they cannot work without it. Your request has to reach the server that holds this site, which is Vercel. The map on the bars page has to fetch its tiles, which come from OpenFreeMap. And a cookieless page view counter, also run by Vercel, derives a daily value from the request in order to tell a repeat view from a new one.

Two things ask you for something, and both are the same thing twice: a form that takes an email address and nothing else, and only after you confirm it. One is on the booklet page and sends the booklet. The other appears once that address is confirmed, and its only purpose is to tell you when the book is ready. They are separate lists, separately joined and separately left. All of it is described below. Everything else happens in your browser and goes nowhere.

Controller

The site is operated privately by a natural person as an editorial project. No data protection officer is appointed: the thresholds in Art. 37 GDPR and § 38 BDSG are not met, since there is no large-scale or systematic processing here and no employees engaged in it.

Server log data

This site is hosted by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, United States. Delivering a page necessarily discloses your IP address to the server sending it, and Vercel records request data in the course of that delivery: IP address, approximate location derived from it, the page requested, the time, the HTTP status, and the browser and system information your browser sends.

The legal basis is Art. 6(1)(f) GDPR. The legitimate interest is delivering the site at all and keeping it available and secure. There is no way to serve a web page without it, and the data is not used to build a profile, is not combined with anything else, and is not used to identify you.

Vercel acts as a processor under Art. 28 GDPR on the basis of a data processing agreement. Because Vercel is established in the United States, this involves a transfer to a third country, safeguarded by the EU standard contractual clauses and by Vercel's certification under the EU-U.S. Data Privacy Framework and its Swiss extension.

This project is on Vercel's Hobby plan, where request logs are kept for one hour and are then gone. Nothing is copied out of that window, no log is archived elsewhere, and no report is built from one. What Vercel itself retains beyond that, for its own billing and security purposes as a company, is governed by Vercel's privacy notice rather than by this site.

The page view counter

This site counts page views using Vercel Web Analytics, run by the same company that hosts it. It is cookieless: no cookie is set, and nothing is written to your device. In production the script is served from this domain, so counting a page view contacts no third party and your request does not leave the host already named above.

What is recorded for a page view is the time, the page address and the referrer, the browser and operating system and their versions, the device type, and an approximate location derived from the request. That location resolves to city level, not only to country. Telling one visitor from another is done with a value Vercel derives from the incoming request, which is valid for a single day and is discarded after 24 hours. Vercel does not publish what goes into that value, so this page does not describe it.

No custom events are collected. The plan this project runs on reports page views only, and the events the site itself cares about are written to the server log described above instead, as counts with no address attached. Vercel states that the analytics data contains no personal identifiers that track visitors across different applications or websites.

The legal basis is Art. 6(1)(f) GDPR. The legitimate interest is knowing which pages are read at all, which is the minimum needed to decide what to write next. Because nothing is stored on or read from your device, § 25 Abs. 1 TDDDG is not triggered and no consent banner is required for it. The reporting window on this plan is one month. Vercel adds that while only the reporting window is guaranteed to be stored, it may store the data for longer, which is governed by Vercel's privacy notice rather than by this site.

The map on the bars page

The bars page carries an interactive map. Its tiles and label fonts are fetched from OpenFreeMap, operated by Hyperknot Software Kft. in Hungary. Making that request discloses your IP address to them, together with the tiles you asked for, which says roughly which part of the map you were looking at.

This happens on the bars page only, and not immediately: the map is not requested until it comes close to your viewport as you scroll. It is the only third-party origin your browser contacts anywhere on this site: the page view counter and both signup forms go to this domain, not past it. If you never open the bars page, or never scroll to the map, no request to OpenFreeMap is made.

OpenFreeMap states that it does not log IP addresses by default, and that it may enable IP logging temporarily for at most 30 days if it detects a security incident, deleting those logs once the incident is resolved or the 30 days expire, whichever comes first. It states that it uses no cookies, no API keys and no user accounts, and that it may use Cloudflare as a content delivery network. Hungary is in the EU, so no third-country transfer arises from the map itself.

The legal basis is Art. 6(1)(f) GDPR. The legitimate interest is showing where the bars actually are, which is the point of the page. The map was chosen over the better-known alternatives precisely because it needs no key, sets no cookie and does not fund itself by advertising. Every bar is also listed in full as text beneath the map, so the page can be read without the map ever loading.

What is not here

No cookies are set. Nothing is written to local storage, session storage, IndexedDB or the cache API, and no service worker is registered. Because nothing is stored on or read from your device, the consent requirement in § 25 Abs. 1 TDDDG does not arise, which is why this site has no consent banner.

Beyond the page view counter described above, there is no analytics or statistics package of any kind, no social media plugin, no embedded video, no advertising, no A/B testing and no fingerprinting. Nothing on this site tracks you across other sites. No profiling and no automated decision-making in the sense of Art. 22 GDPR takes place.

Typefaces are self-hosted from this domain. No font network is contacted and no request leaves for one. The booklet PDF is served from this domain too, so downloading it involves no one but the host named above.

The drink finder

The drink finder runs entirely in your browser. Your answers are not transmitted anywhere, not stored, and are gone when you close the tab. The only forms on this site that send anything to a server are the two signups, described next.

The two signup forms

The booklet page carries a form that asks for an email address. That is the whole of it: no name, no company, no title. If you arrived from a campaign link, the campaign parameters in the address bar travel with the form, which records which link you followed, not who you are.

The second form appears on the page you land on after confirming, and asks the same single question for a different purpose: whether you want to hear when the book is ready. It is a separate list at the same provider, joined by its own confirmation message and left by its own unsubscribe link. Leaving one does not leave the other, and an address on one is not on the other unless it was given twice. The booklet list is used for the booklet and the occasional note; the book list is used once, when the book is ready, and for nothing else.

Submitting either form asks the mailing provider to send you one confirmation message. Your address is added to that list only if you click the link in that message, and the link expires after 30 days. If you never click it, no list entry is made. The provider records the time of the request and the time of the confirmation, which is what makes the consent demonstrable under Art. 7(1) GDPR. Each list holds its own record.

Sending that single confirmation message rests on Art. 6(1)(f) GDPR, the legitimate interest being to establish whether the address was really yours. Everything after it, the booklet, the occasional notes, and the one message about the book, rests on your consent under Art. 6(1)(a). You can withdraw it at any time under Art. 7(3), with effect for the future, using the unsubscribe link in every message or by writing to the address above. Withdrawing it for one list leaves the other standing, so if you want off both, use the link in a message from each.

The mailing provider is Sendinblue, a simplified joint-stock company registered under RCS Paris 498 019 298 and doing business as Brevo, 17 rue Salneuve, 75017 Paris, France. It acts as a processor under Art. 28 GDPR on the basis of the data processing agreement that forms an appendix to its terms of service. Brevo hosts data with OVH in France and Google Cloud in Belgium and uses Cloudflare as a content delivery network, and states that transfers outside the EU may occur, in particular to the United States and India, under the safeguards provided for in Chapter V GDPR.

Brevo embeds an image and individualized links in the messages it sends, which is how it reports whether a message was opened and which links were followed. Those reports are attributed to your address rather than counted anonymously, so the record shows that a particular address opened a particular message. Nothing is done with that record beyond seeing whether a message was worth sending. It does not follow you to this site or to any other, and loading remote images is something your mail client decides, not this site: if it blocks them, the open is never recorded.

Both forms are handled by one function on this domain rather than posting to the provider directly, so the provider's key never reaches your browser. That function holds the IP address of a submission in memory for one minute, per form, so that the same connection cannot be used to send mail to a stream of addresses. It is not written to a file, not stored, and is gone when the minute passes. No email address is written to the server log.

Contacting the operator

If you write to the email address above, your message and address are processed to answer you, on the basis of Art. 6(1)(f) GDPR. Correspondence is kept only as long as the matter requires, and longer only where a statutory retention period applies. Email is carried by the operator's mail provider and is not end-to-end encrypted unless you encrypt it yourself.

External links

This site links out to bar websites, to OpenStreetMap for individual locations, and to the sources listed on the sources page. Following a link is your action, not the site's, and what happens after that is governed by the privacy policy of whoever you land on. The operator has no control over and accepts no responsibility for their processing.

Your rights

Under the GDPR you have the right to access your data (Art. 15), to have it corrected (Art. 16) or erased (Art. 17), to restrict its processing (Art. 18), to receive it in a portable form (Art. 20), and to object to processing based on legitimate interests (Art. 21). To exercise any of them, write to the address above.

In practice there are two different cases. If you have given an email address to either list, that address is the record, and any of the rights above can be exercised against it directly. If you have not, the only data is short-lived server log data and page view counts, neither of which is linked to a name. An access request in that second case may need enough information to locate the relevant entries, and where identification is impossible Art. 11(2) GDPR applies.

You also have the right to complain to a supervisory authority, Art. 77 GDPR. The one competent for the operator is:

Visitors in Switzerland may instead contact the Federal Data Protection and Information Commissioner (FDPIC) in Bern.

Changes

This policy describes the site as it currently stands. If a future version adds anything that processes data differently, this page is updated before that version goes live, and the date below changes with it.