Privacy

Who is responsible

The controller of your personal data is Skupina Svetilnik d.o.o. (Lighthouse Group Ltd), the company Dr. Tali Režun works through. In this policy "we" and "us" mean that company; "Tali" means Dr. Tali Režun.

There is no public email address. To reach us about privacy, use the inquiry form for other requests.

The short version

• No tracking or advertising cookies, no Google Analytics, no tag managers, no cross-site identifiers. Page analytics are daily totals only. That is why there is no cookie consent banner. A short notice that you can close only points you to this policy; it asks for nothing.
• Reading the site requires nothing from you. Your browser connects to Cloudflare, which hosts the site.
• If you send an inquiry, we store what you write and use it to reply. We keep it for 12 months unless we start working together.
• Nightly backups of our database are kept for 30 days, then deleted.
• If you are invited to the members area, we store your email address, your access rights and a record of which materials you open. You can delete your account yourself.
• We never sell your data and never use it for advertising.

Visiting the site

When you open a page, your browser sends the usual technical information (IP address, browser type, requested address, referring page) to Cloudflare, which hosts and delivers the site. Cloudflare uses it to deliver the page and protect the site against attacks. Our own application logs do not record IP addresses; where an email address appears in an error log, it is masked. Cloudflare keeps operational logs for a short period under its own data processing terms.

Legal basis: our legitimate interest in running a secure website (Article 6(1)(f) GDPR).

Analytics

We want to know which pages and links are useful, not who you are. Our analytics set no cookies, use no local storage, assign no identifier, do not fingerprint your browser and never store your IP address. What we keep are daily totals, so we can count page views but cannot recognise a person or tell how many different people visited.

• Page views. When a public page opens, your browser sends us one small message with the page address (without anything after a "?"), the domain of the website that linked to it (for example google.com, never the full address), and whether your screen is phone, tablet or desktop size. We add the country Cloudflare estimates from your connection and the day. We count one more view in the daily totals for each of these: the page, the referring domain, the country and the device size. The message itself is not stored. Members and admin pages are not counted.
• Lumina, inquiries and Library search. We count, per day, when the Lumina chat is opened, that a question was sent (never what you asked), which page or website you followed from an answer, and when you choose to leave your details. We count how often each inquiry form is opened. When you search the Library, we count the search phrase you settle on (lowercased, at most 60 characters) and whether it found anything; a phrase that looks like an email address, phone number, web address or long number is dropped before it is counted. We also count which Library filters are used.
• Link clicks and downloads. When you follow a tracked link to an article or publication (addresses that start with /go/), open a PDF hosted on this site, or use a "Subscribe on Substack" button (addresses that start with /out/), we count it. We keep daily totals per publication and channel only. A separate event stream (Cloudflare Workers Analytics Engine) also records, for each click on a tracked link, the publication, the channel, the referring website's domain and your country as estimated by Cloudflare. It holds no IP address or identifier. Cloudflare keeps this stream for three months.
• Automated visitors. To keep bots out of the totals, the browser type your request sends is checked at that moment and not stored. Requests from known search and AI crawlers (for example Googlebot or GPTBot) are counted separately by crawler name and the page they fetched.
• Cloudflare Web Analytics. On public pages we also use Cloudflare Web Analytics, which counts visits and page load times without cookies, without storing IP addresses and without fingerprinting. Cloudflare acts as our processor.
• Global Privacy Control. If your browser sends the Global Privacy Control signal, it sends none of the analytics messages above and does not load Cloudflare Web Analytics. Link clicks and downloads are still counted in the totals, because they are counted on our server when the link is followed, not by your browser.

We keep these daily totals for 25 months, then delete them.

Legal basis: legitimate interest in understanding, in aggregate, how the site is used (Article 6(1)(f) GDPR).

Cookies and local storage

This site sets no tracking, advertising or analytics cookies, and reading the public pages sets no cookies of our own. What the site does use:

• Sign-in session cookie. Only if you sign in to the members area (or the admin area). It keeps you signed in for up to 30 days, is HTTP-only and is sent only to this site. If Google sign-in is offered and you use it, a short-lived technical cookie also protects the sign-in step (Google sign-in is not offered at the moment). Signing out removes the session.
• Signed-in hint cookie. After you sign in, a second small cookie, "tr_acct", holding only the value 1, tells the site's pages that you may be signed in, so the header can show your account link. It contains nothing about you, lasts up to 30 days and is removed when you sign out, or the next time the site finds that you are no longer signed in.
• Cloudflare security cookies. Cloudflare may set strictly necessary cookies to tell people from bots and to block attacks.
• Theme preference. If you choose light or dark mode in the footer, your choice is saved in your browser's local storage under "tr-theme". It never leaves your device.
• Privacy notice. A short notice points visitors to this policy. It is information only, not a consent request: closing it switches nothing on or off. When you close it, your browser's local storage remembers that under "tr-notice", so the notice does not come back. It never leaves your device.
• Session storage for the chat and the inquiry form. If you use the Lumina chat, the conversation shown on screen is kept in your browser's session storage ("tr-lumina:v1", plus "tr-lumina:pulse", which only marks the section of a page to highlight after you follow a link from an answer), so it stays visible as you move between pages. The Lumina chat program also keeps its conversation reference there. If you send an inquiry, the email address you entered is kept there ("tr-inquiry-email") so the next page can show where the confirmation link went. Session storage stays on your device and is cleared when you close the tab or browser.
• Back office. In the admin area, used only by administrators, the browser also keeps interface settings (such as the last tab used) and one-off status messages. They hold no visitor data.

These are strictly necessary for a service you request, so no consent is required (Article 5(3) of the ePrivacy Directive, as implemented in Slovenian law). You can delete cookies and local storage in your browser settings at any time.

Inquiries

When you use the inquiry form, we store the details you enter: your name, your email address, your company if you give it, the type of inquiry and your answers (for example role, budget range, timeline and your message). We also store technical bookkeeping such as when the inquiry was created and confirmed.

Email confirmation. We send you a link to confirm your address. Until you confirm, the inquiry is not processed or sent to Tali; it is only stored, marked as waiting for confirmation. Unconfirmed inquiries are deleted after 30 days.

Bot protection. The form is protected by Cloudflare Turnstile and by rate limits. Rate limits use one-way hashes of your IP address and email address, which are deleted within about a day.

AI-assisted triage (only when switched on). AI triage is not switched on at the moment, so no inquiry is sent to an AI provider. When it is switched on, after you confirm, the inquiry is sent to an AI model, by default Anthropic's Claude, which suggests a category, a fit score, a short summary and a draft reply for Tali. We may instead use Google's Gemini models for the same task. The provider acts as our processor and receives only the inquiry. The AI output is a suggestion: Tali reads every confirmed inquiry and decides himself whether and how to answer. Simple automatic checks (for example, a free email address on a company inquiry) also add notes for Tali about possible spam; they decide nothing. No decision with legal or similarly significant effect is made automatically.

Delivery. The inquiry, with the AI suggestion when there is one, is emailed to Tali's business mailbox, either at once or in a daily summary. You receive a short note that it arrived. Any reply comes from Tali personally.

Inquiries from Lumina. If you ask the Lumina assistant on this site to pass on your details, Lumina collects your name, email address and request inside the conversation, and the Lumina service emails them to Tali. Today these details do not enter this site's inquiry system. If a direct connection from Lumina to this site is switched on later, Lumina will send us the same details and the inquiry will be handled as above.

Retention. We delete inquiries 12 months after they were created, unless they led to a working relationship. In that case we keep them as long as the relationship and our legal obligations (for example accounting rules) require. Email correspondence with Tali is business correspondence and is kept on the same principle. Tali may delete an inquiry earlier, for example one that is spam or needs no answer.

Legal basis: steps taken at your request before entering into a contract, and our legitimate interest in answering inquiries (Article 6(1)(b) and (f) GDPR).

Members area

The members area holds materials for programs, cohorts and individual shares. Access is by invitation: the organiser of a program gives us the email addresses of participants.

What we store.

• Your email address. If Google sign-in is offered and you use it (it is not offered at the moment), also the name and profile picture address that Google shares with us, plus the technical tokens Google issues for the sign-in.
• Your access rights: which program, cohort or item you may open, who granted it and when it expires.
• Your sessions: when you signed in, the IP address and browser of the session, and when it expires.
• An access record: which members materials you viewed or downloaded, and when. We do not record activity anywhere else on the site.
• When an administrator changes access rights, that change is recorded in an internal audit log, together with your email address.

Emails to members. We use your email address to send you sign-in links and, when the organiser or Tali sends them through the site, invitations, program announcements and session details.

Signing in. You sign in with a one-time link sent to your email (valid for 15 minutes, used once, stored only as a hash). Google sign-in is not offered at the moment; if it is switched on, you will be able to use it instead. There are no passwords. The sign-in form is protected by Cloudflare Turnstile and by rate limits based on hashed identifiers.

Retention. We keep your account until your access expires plus 12 months, and access records for up to 24 months. Access records are: the record of which materials you opened (24 months from each view or download), your access rights once they have ended, by expiry or withdrawal (24 months from the day access ended), and the internal audit log of access changes (24 months from each change). Access rights that are still valid are kept while they are valid. Accounts that never had any access are deleted once they have not been used for 12 months.

Deleting your account. You can delete your account at any time at /members/account. This removes your account, your sessions, any linked Google sign-in, your access history and your access rights, including invitations you have not used yet, so your access to programs ends; to come back, ask the organiser to invite you again. In the internal audit log of access changes, your email address is replaced by a neutral marker ("deleted-member"); the entries themselves are deleted when they are 24 months old. When we delete an account automatically under the retention rules above, exactly the same happens. Copies in our nightly backups disappear within 30 days (see Service providers).

Legal basis: performance of a contract (providing the materials you or your organiser signed up for) and our legitimate interest in protecting licensed materials (Article 6(1)(b) and (f) GDPR).

Lumina chat

The chat assistant on every public page is Lumina, built by Tali and operated by Lighthouse Group's Lumina service with EU data residency. The chat program is loaded from Lumina's servers only when you first move to or click into the chat, so reading a page makes no request to Lumina. What you type into the chat is processed by Lumina to answer you. What your browser keeps during the conversation is described under Cookies and local storage. Lumina has its own terms and privacy information at luminawidget.xyz. Please do not enter sensitive personal data into the chat.

Video, links and third-party sites

• Videos. Embedded YouTube videos load only when you click play, from youtube-nocookie.com. Until then, nothing is requested from YouTube. Once you play a video, Google's privacy policy applies.
• Links. The site links to other services, such as Substack, Medium, YouTube, LinkedIn and GitHub, and to projects run by related companies. When you follow a link you leave this site, and the other site's privacy policy applies.

Service providers

We use these providers to run the site. They process data on our behalf under data processing terms.

• Cloudflare (hosting, content delivery, database, file storage, bot protection with Turnstile, analytics). The database is located in Western Europe and file storage is held in the EU jurisdiction.
• Resend (transactional email: sign-in links, inquiry confirmations and notifications, member invitations and program announcements).
• Anthropic (AI-assisted inquiry triage, by default) and Google (Gemini models as an alternative for the same task, and Google sign-in if it is offered and you choose to use it). Neither is switched on at the moment, so today neither receives your data.
• Lumina (the chat assistant on public pages), operated by Lighthouse Group.

We also use AI services to help prepare Library entries from Tali's own publications. No visitor data is involved in that work.

Backups. Every night we save a copy of the database, plus a list of the stored files (names and sizes, not their contents), in the same EU file storage at Cloudflare. Each copy is kept for 30 days and then deleted, so data deleted from the site is gone from the backups within 30 days. Live sign-in sessions, pending sign-in links and rate-limit counters are left out of the backups, and Google sign-in tokens are blanked. An administrator can download a backup, for example to restore the site after a failure.

International transfers

We keep data in the EU where the service allows it. Resend may process data outside the European Economic Area, in particular in the United States; so may Anthropic and Google once AI triage or Google sign-in is switched on. Where that happens, transfers rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses or the provider's certification under the EU-U.S. Data Privacy Framework. Cloudflare's global network may also process technical data outside the EU to deliver pages and stop attacks, under the same kind of safeguards.

Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you and get a copy;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to processing based on our legitimate interests;
• receive data you gave us in a portable format;
• withdraw any consent you gave, without affecting earlier processing.

How to exercise them. Use the inquiry form for other requests and say what you would like us to do. Members can delete their account directly at /members/account. We may need to confirm that a request comes from you, usually by replying to the email address concerned. We answer within one month.

Complaints. You can complain to a supervisory authority. In Slovenia that is the Information Commissioner (Informacijski pooblaščenec), ip-rs.si. You can also complain in the EU country where you live or work.

Children

This site is not directed at children under 16, and we do not knowingly collect their data.

Changes to this policy

We update this policy when the site changes. The version number and date at the top show the current version. If a change affects how we use data you have already given us, we will tell members by email before it applies.