Privacy notice
Beta. These pages have not been reviewed by counsel yet. No data protection officer is appointed for the free beta; write to privacy@lotusmind.one.
1. Who is responsible
Controller: Lotus Mind Limited, a private company limited by shares, company no. 826314, registered office 10 Aderrig Manor, Adamstown, Lucan, Dublin K78 A4T8, Ireland. Privacy contact: privacy@lotusmind.one. No data protection officer is appointed for the free beta (Art. 13(1)(b)); all data protection questions go to the privacy contact above. This notice covers pray.lotusmind.one only; lotusmind.one publishes its own notice.
2. Summary
Religion is a special category of personal data (GDPR Art. 9). The page is built so that a request never names a tradition: sacred texts are addressed by an opaque hash and the free-session start call carries only your 18+ confirmation. The site also publishes an index (/c/v1/index.json) that maps each hash to its tradition, so a recorded request path can be resolved back to a tradition by anyone who has the index. The protection is that this host writes no request log, not that the hash is a secret. The sky is computed in your browser. The page makes no requests to third parties: no analytics, no fonts, no CDN, no advertising.
3. What we process, why, and on what legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Giving you an open session | Your 18+ confirmation; a signed cookie counting open sessions used; a salted hash of your network address kept in memory | Art. 6(1)(b) — steps taken at your request before a contract. The 18+ confirmation also serves our legal duty to keep the service for adults |
| Limiting abuse of the open-session counter | The same salted hash, per hour | Art. 6(1)(f) — our legitimate interest in keeping the free tier available to everyone. The interest is named here; you may object |
| Gloop explanations (verified members who ask) | Your question, the tradition, the text reference, your interface language | Art. 9(2)(a) — your explicit consent, asked in the box beside every question and withdrawable by not ticking it. Art. 6(1)(a) |
| Remembering your language, your chosen place, that you saw the opening | localStorage in your browser only | ePrivacy Reg. 5(3) (S.I. 336/2011) — storage strictly necessary to provide a service you asked for |
| Keeping you signed in after Lotus Mind login | A signed session cookie | Art. 6(1)(b) — the account service you requested |
4. Recipients and transfers outside the EEA
Hosting: Hetzner (Germany, EEA) — data centre to be confirmed. Lotus Mind Hub (lotusmind.one) handles login only and issues a short-lived signed assertion; this site holds no Hub password or database. Gloop: if you consent, your question, the tradition, the reference and your language go only to a model run by Lotus Mind (GLM-5.3-Flash), reached over our private network; its hosting location is confirmed before launch and will be stated here. No other company's AI service receives them, and this site's server refuses to start if a third-party model is configured. This site does not store or log your question or the answer; it holds them in memory only while the answer is produced (see AI use). No other recipients. We do not sell data and we run no analytics.
5. Retention
| Record | Kept for |
|---|---|
| Open-session cookie (__Host-lp_free) | 90 days, then your browser drops it |
| Member session cookie (__Host-lp_s) | 12 hours |
| Rate-limit hash (memory only) | Counted per hour. The hash stays in memory until the server restarts (at most 100,000 entries), but it can be linked to a network address only until the salt is replaced, which happens on the first request after 00:00 UTC each day; never written to disk or a log |
| Request logs for the session endpoints | None — request logging is off on this host |
| Server-side sign-in record (your Hub member id, verification status and membership tier) | In memory only, for 12 hours; deleted when it expires or the server restarts; never written to disk and never logged |
| Application log lines (session outcome, which model leg answered, timing) | Written to the host's system journal under the host's journal policy; no tradition, question, member id or network address is written |
| Server database or files | None — the service keeps no database and no files; it holds only the short-lived sign-in record above, in memory |
| Night Folio pages | In your browser until you delete them; never uploaded |
6. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent at any time (withdrawing does not affect processing already done). Because this site keeps no account database (only the short-lived sign-in record in section 5), most rights are exercised through your browser: clearing site data deletes the cookies and the Night Folio. Write to privacy@lotusmind.one for anything else.
7. Complaints
You may lodge a complaint with the Irish supervisory authority: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland — dataprotection.ie, 01 765 0100 / 1800 437 737. You may also complain to the authority in your own country.
8. Automated decisions
There is no automated decision-making that produces legal or similarly significant effects (Art. 22). AI answers are explanations, clearly labelled, and are not decisions about you.
9. Location and your device
This page never calls the geolocation API. To preselect a city we read your browser's own time-zone name on your device; it is never sent to us. Otherwise you choose a city or type a latitude and longitude, and that choice stays in your browser.
10. Logs, login, children, status
Requests to the session endpoints are not logged with path or network address. Gloop logs which model leg answered and never your text. Logging in takes you to Lotus Mind and returns a short-lived code; this site never sees your password. Not for people under 18; no children's data is knowingly processed. Beta, not reviewed by counsel, DPIA not signed — see the Data protection page.
Controller: Lotus Mind Limited, company no. 826314, 10 Aderrig Manor, Adamstown, Lucan, Dublin K78 A4T8, Ireland · privacy@lotusmind.one · Complaints: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland — dataprotection.ie, 01 765 0100 / 1800 437 737.
Version lm-pray-dpia-20261111-v1 (beta). Translations of these pages were drafted by AI and checked only by AI reviewers, on the owner's decision; they are not legal advice and were not reviewed by counsel or a native speaker.