1. Data controller
HALOKROS is currently operated by an individual:
Gediminas Tamošaitis
Aido g. 9-27, LT-78292 Šiauliai, Lithuania
Email: halo@halokros.com
This policy applies to the website at halokros.com and its Lithuanian and English versions.
Your information
Privacy Policy
How HALOKROS handles personal data and listener reflections.
2. Data we process
| Activity | Data | Purpose and legal basis | Retention |
|---|---|---|---|
| Visiting the website | IP address, request time, requested URL, response status and browser or device information in Hostinger security logs. | Operating and securing the website, preventing abuse and diagnosing errors. Legitimate interests. | Normally 7-30 days, subject to Hostinger's technical configuration and legal obligations. |
| Optional website analytics | Page URL and title, referring page, session and interaction statistics, approximate location, browser, device, operating system, language and pseudonymous client or session identifiers. | Understanding how the website is used and improving its content and performance. Consent. | Google Analytics cookies: up to 12 months. User and event data: up to 14 months, according to the Analytics property settings. Anonymous aggregated reports may be kept longer. |
| Contacting HALOKROS | Name, email address, selected topic, message and the page from which the form was sent. | Replying to requests, discussing cooperation and taking steps requested by you. Legitimate interests and, where applicable, steps before entering into an agreement. | Up to 12 months after the last communication, unless a longer period is required for an agreement or legal claim. |
| Listener reflections | Song, language, reflection text, submission time, consent version, notification-batch status and a hashed deletion code. A short-lived pseudonymous rate-limit key is processed separately. | Collecting reflections in groups of five and preparing anonymous, aggregated listener insights. Consent. If a reflection contains sensitive information, explicit consent is relied upon. | Raw reflections: up to 90 days. Rate-limit records: up to 48 hours. |
| Privacy requests | Request details and information needed to verify and complete the request. | Complying with data protection obligations and demonstrating compliance. | Up to 3 years where necessary to document the response. |
Writing or copying a reflection in the text field does not send it to HALOKROS. It is transmitted only when you deliberately use the sharing function and confirm the required notice.
3. Listener reflections
Listener reflections may contain personal or sensitive experiences. Do not include names, contact details or information that could identify you or another person.
- Individual reflections are not published by default.
- HALOKROS groups five new reflections for the same song and sends the batch to its administrative inbox for human review.
- HALOKROS may prepare and publish only combined, anonymised insights for a song. An individual reflection is not published.
- Consent can be withdrawn immediately after submission or later by entering the deletion code in the form below.
HALOKROS may correct spelling and grammar or remove identifying details without changing the intended meaning. A submission may be rejected or deleted if it contains personal data about others, unlawful content, threats, abuse, advertising or irrelevant material.
4. Remove a submitted reflection
Enter the deletion code shown after submission. A matching reflection will be removed from active website storage, and HALOKROS will receive an administrative deletion notice containing the withdrawn text and its record details. This allows HALOKROS to identify and remove the same text from a review email or working notes. An insight that has already been irreversibly anonymised and can no longer be linked to a submission may remain.
5. Recipients and service providers
Personal data is accessible only where necessary to HALOKROS and service providers acting on its instructions. The website hosting and domain-email provider is Hostinger. Completed batches of five reflections and related deletion notices are sent to the HALOKROS domain inbox. Hostinger may process technical data and, where applicable, the contents and metadata of administrative emails.
The website loads the Inter font from Google Fonts. This creates a technical connection to Google and may disclose an IP address and browser information. With your consent, HALOKROS also uses Google Analytics 4 (measurement ID G-RFECHPRFRD). The Analytics script is not loaded before consent. Google may receive the analytics data listed above and act as a service provider under its applicable data-processing terms. Google Signals and advertising personalisation features are disabled.
Data may also be disclosed where required by law or necessary to establish, exercise or defend legal claims. Where a provider processes data outside the European Economic Area, HALOKROS will rely on an applicable adequacy decision or appropriate safeguards.
6. Cookies and similar technologies
HALOKROS stores the strictly necessary analytics-consent choice for six months. Google Analytics cookies are set only after you accept analytics and are configured to expire after no more than 12 months. Advertising and personalisation storage remains disabled. You can change or withdraw your choice through “Cookie settings” in the footer. Details are provided in the Cookie Policy.
7. Automated tools and AI
No reflection is automatically sent to an AI service. HALOKROS first reviews each five-reflection batch and removes details that could identify a person. A manually reviewed and de-identified batch may then be used with an external generative-AI service to draft a combined insight. A person remains responsible for reviewing and deciding what is published.
HALOKROS will assess the selected AI provider, its data-processing terms and any international transfers before using it with listener material. AI is not used to make legal or similarly significant decisions about individuals.
8. Your rights
Subject to the GDPR and applicable law, you may request access, correction, deletion, restriction, portability or object to processing. Where processing is based on consent, you may withdraw it at any time without affecting earlier lawful processing.
Send requests to halo@halokros.com. You may also lodge a complaint with the Lithuanian State Data Protection Inspectorate at vdai.lrv.lt.
9. Security, children and changes
HALOKROS applies access controls, data minimisation, validation, backups and other reasonable safeguards. No online service can guarantee absolute security.
The listener reflection feature is intended for people aged 16 or older. People under 16 should not submit a reflection or personal data through that feature.
This policy may be updated when the website, providers or processing purposes change. The current version and update date will always be published on this page.