Privacy Policy

Effective September 25, 2026.

1. Controller

BRANDWORKSAPP LLC d/b/a Clirium’s Magazine, a Florida Limited Liability Company, 700 Siena Palm Dr, Suite 303, Celebration, FL 34747, USA. Privacy contact: support@cliriumsmagazine.com, subject “Privacy”.

The publisher has no establishment in the EU or UK and processes data of residents of those countries only occasionally; accordingly, no representative is designated under Article 27 GDPR / UK GDPR (Art. 27(2)(a)). All requests are handled through the contacts above.

2. Data we process

Contributor applications: name, e-mail, Telegram or phone, city, application text; when preparing a publication — information the contributor shares in interview (including, at her choice, information about health, family or finances), photographs, interview recording, signed consents.

Issue-release reminders: e-mail, date and method of sign-up, consent record, unsubscribe records.

Comments: name (or pseudonym), comment text, date, technical data for spam protection.

Correspondence: e-mail and Telegram messages, rights-holder and data-subject requests.

Technical data: IP address and browser information in server logs; settings stored in your browser; with your consent — Google Analytics visit statistics.

We use no advertising trackers, build no advertising profiles, do not sell personal data and do not share it for cross-context behavioural advertising.

3. Purposes and legal bases

For each processing activity, the purpose, the basis under the GDPR / UK GDPR and the basis under Law No. 152-FZ are stated.

Reviewing a contributor application, contacting her

GDPR: Art. 6(1)(b) — steps at her request prior to an agreement; Art. 6(1)(a) — consent. 152-FZ: consent (Art. 9)

Preparing and publishing a story

GDPR: Art. 6(1)(a) and, for health data, Art. 9(2)(a) — explicit consent; Art. 85 (journalistic purposes) as provided by national law. 152-FZ: separate written consent to processing (Arts. 9, 10) and separate consent to dissemination (Art. 10.1)

Creating a cover with generative AI

GDPR: Art. 6(1)(a) — the contributor’s consent under the Model & Photo Release. 152-FZ: consent (Arts. 9, 12)

Issue-release reminders

GDPR: Art. 6(1)(a) — consent. 152-FZ: consent (Art. 9); for promotional messages — Art. 18 of Law No. 38-FZ

Publishing comments

GDPR: Art. 6(1)(a) — consent; Art. 6(1)(f) — legitimate interest in moderation. 152-FZ: consent to processing and to dissemination of name and text (Arts. 9, 10.1)

Visit analytics

GDPR: Art. 6(1)(a) — consent (cookie banner). 152-FZ: consent

Site security, server logs

GDPR: Art. 6(1)(f) — legitimate interest in protecting the Site. 152-FZ: Art. 6(1)(5) and (7)

Handling requests, DMCA, defence of claims

GDPR: Art. 6(1)(c) — legal obligation; Art. 6(1)(f) — legitimate interest. 152-FZ: Art. 6(1)(2) and (7)

4. Voluntary provision and automated decisions

Providing data is voluntary; contact details are needed to review an application and to send reminders. We make no automated decisions producing legal effects.

5. Recipients (processors)

Each processor acts on the publisher’s instructions under its data-processing terms.

Google LLC (USA) — Firebase Hosting

Site hosting and server logs

Google LLC (USA) — Google Firebase / Cloud Firestore

Storage of applications, subscriptions and comments

Google LLC (USA) — Google Analytics for Firebase

Aggregated visit statistics; only after your cookie consent

Google LLC (USA) — Google Fonts

Delivery of Site typefaces; Google receives your IP address and browser information

Tally BV (Belgium, EU) — Tally Forms

Receiving contributor applications and electronic signatures on the Featured Subject Agreement and the Model & Photo Release

OpenAI, L.L.C. (USA) — ChatGPT

Creating covers and portrait visuals from the contributor’s photographs with generative AI, only with her separate consent; model training on uploaded photographs is disabled

E-mail service provider

Sending issue-release reminders from the cliriumsmagazine.com domain

Telegram Messenger

If you contact us on Telegram; Telegram’s own policy also applies

Within the publisher

The Editor-in-Chief and authorised editorial staff, as needed for their tasks

Public authorities and courts

Only where required by law

6. Location and international transfers

The publisher is located in the United States; it collects data directly and stores it on servers in the United States. Contributor applications are received through Tally (EU) and passed to the publisher in the United States.

EU/UK residents: you provide data directly to a controller in the United States. Disclosures to our processors Google LLC and OpenAI, L.L.C. are governed by their data-processing terms, which incorporate the Standard Contractual Clauses, and by those companies’ participation in the EU-U.S. Data Privacy Framework and UK Extension; health information is processed on the basis of your explicit consent.

Russian residents: cross-border transfer to the United States is based on your separate consent (Section 9), given in the knowledge that the United States is not among the countries recognised as ensuring adequate protection of data subjects’ rights.

7. Retention

Applications not accepted for publication

12 months from last contact, then deleted

Published contributors’ materials

For the life of the publication and archive

Contributor consents, interview recordings and notes, approved final texts

For the life of the publication and at least 7 years after removal from the archive (Editorial Charter, Art. 11.2); recordings for unpublished stories — 12 months after the decision not to publish

Subscriptions

Until you unsubscribe or withdraw consent; after unsubscribing, your e-mail is kept on a suppression list solely to ensure we do not contact you again

Comments

While posted; rejected comments — 90 days

Server logs

Up to 30 days

Google Analytics data

14 months

Cookie-consent records

For the duration of consent and 3 years thereafter

DMCA notices and legal claims

3 years from receipt

Data-subject requests and responses

24 months

8. Your rights

You may: obtain information about processing and a copy of your data; correct inaccurate data; erase data; restrict processing; object to processing based on legitimate interest; receive your data in a portable format; and withdraw consent at any time (without affecting the lawfulness of prior processing). EU/UK residents may lodge a complaint with their supervisory authority. Russian residents may apply to Roskomnadzor or a court.

The publisher voluntarily extends the rights to access, correct and delete personal information to residents of every U.S. state, does not sell personal information and does not “share” it for targeted advertising.

How to submit a request: support@cliriumsmagazine.com, subject “Privacy Request”, or by post to the publisher’s address. We verify your identity in a manner proportionate to the request.

Response time: no later than 45 days after receipt; for EU/UK residents — no later than one month (extendable by two months with notice of the reasons where the request is complex); for Russian residents — 10 business days (extendable by 5 business days with a reasoned notice). Withdrawal of consent is given effect within the time required by applicable law and, for consent to dissemination under Art. 10.1 of Law No. 152-FZ, within 3 business days.

9. Russian Federation (152-FZ)

9.1. The publisher is a Florida entity with no branch, representative office or servers in the Russian Federation; the magazine is free and sells no goods or services to consumers in Russia. The publisher’s activities are not directed at the territory of the Russian Federation within the meaning of Article 18(5) of Law No. 152-FZ, and the Site database is located in the United States. Should these circumstances change, the publisher will ensure that data of Russian citizens is initially recorded in a database located in the Russian Federation.

9.2. Consent is given separately and is not a condition of accepting the Terms of Use. Readers located in Russia give it by a separate, unticked checkbox in the form; contributors — by signing Annex A to the Featured Subject Agreement (consent to processing, including cross-border transfer to the USA, to dissemination, and to processing of health information). If you do not wish your data to be transferred to the USA, write to support@cliriumsmagazine.com instead of submitting a form.

9.3. Operations: collection, recording, organisation, accumulation, storage, updating, retrieval, use, transfer (provision, access), cross-border transfer, depersonalisation, blocking, deletion, destruction; mixed processing, with the use of automation.

9.4. Withdrawal of consent: by e-mail to support@cliriumsmagazine.com or by post to the publisher’s address.

10. Minors

The Site is intended for persons aged 18 or older. We do not knowingly collect data from persons under 18 and delete it if discovered.

11. Security

We apply reasonable organisational and technical safeguards: encrypted connections (HTTPS), role-based access with two-factor authentication, database security rules and data minimisation. Identity documents and health information are stored with restricted access.

12. Breach notification

Florida (Fla. Stat. § 501.171): in the event of a breach of security of personal information we notify affected Florida residents no later than 30 days after determining that a breach occurred or having reason to believe that one occurred and, where 500 or more Florida residents are affected, the Florida Department of Legal Affairs within the same period. Residents of other U.S. states are notified within the periods set by their state laws.

EU and UK (GDPR Arts. 33–34): we notify the competent supervisory authority within 72 hours where the breach poses a risk to individuals, and the individuals without undue delay where the risk is high.

Russian Federation (Art. 21(3.1) of Law No. 152-FZ): we notify Roskomnadzor within 24 hours and of the results of the investigation within 72 hours.

13. Changes

The new version is published on this page with its effective date; subscribers are notified of material changes by e-mail.

Documents: Imprint · Masthead · Editorial Policy · Code of Ethics · Corrections & Right of Reply · AI Use Policy · Terms of Use · Privacy Policy · Cookie Policy · Comment Policy · Featured Subject Agreement · Model & Photo Release · Contributor Consents · Advertising Disclosure · Copyright & DMCA · Disclaimer · Accessibility & Age · Newsletter Terms · Consent to Advertising Use