What I hold, and why

Who is responsible

Yin Rhythms is run by me, Anna Teresa Kopacz, from Chêne-Bougeries in the canton of Geneva, Switzerland. I work as an independent - there is no company behind Yin Rhythms and no team. I am the person responsible for the data described here, and the person you reach if you want it changed or removed: hello@yinrhythms.com.

This covers www.yinrhythms.com, the participant portal on the same domain, and the letters I send.

Which law applies

I am in Switzerland, so the Swiss Federal Act on Data Protection (the revised FADP, in force since 1 September 2023) governs what I do. Many of the women I work with live in the European Union, so the GDPR applies too, to them.

They are close cousins and mostly ask the same things of me, but they are not the same law and I am not going to pretend one covers the other. Where they differ, I have tried to meet the stricter of the two. If you are in the EU, the rights and the complaint route below are yours under the GDPR; if you are in Switzerland, under the FADP. If you are somewhere else, ask me anyway - I answer these the same way for everyone.

I have not appointed a data protection officer or an EU representative. I am one person working alone at a small scale, and my reading is that neither is required of me. This is one of the things a Swiss advocate should confirm rather than take my word for.

What I collect, and only when you offer it

When you give your email at a door

Your email address, and your first name if the form asks for one. It goes to MailerLite, the service that holds my lists and sends my letters, along with which list you joined - the field notes, the free practice, a gathering, the waiting list for a particular offer. Which door you came through is part of what I keep, because it is how I know what you actually asked for.

You can leave at any time using the unsubscribe link at the bottom of any letter, and I will not ask why.

When you register for a free gathering

Your name and your email. They go to Zoom, so it can send you your own way into the room and so I know who to expect, and to that gathering's list in MailerLite together with the field notes, so I can send you the joining note and afterwards the recording.

When you join a paid container

Your name and email, and the fact that you have paid. I never see your card. Payment happens on Stripe's own pages. Stripe tells my site only that a payment succeeded, which address it belongs to, and what was bought, and my site then puts you in the group that opens the room you paid for. If a payment is refunded or disputed, that same path takes the access back and tells me, so I can come and talk to you.

When a session is recorded

Live sessions are recorded so that the women who could not be there still receive them. If your camera or your microphone is on, your image and your voice are part of that recording, and so is anything you say. You can keep both off, and you can tell me at any point that you would rather not be recorded.

A recording is shared only with the women who were in that container, and with no one else. That is not only a promise - it is how the thing is built. The recordings sit in a private store with no public address; the page you watch them on holds an id rather than a file; and the only way to reach one is a link my site signs at the moment you ask, which stops working shortly after and is only signed at all if you are signed in and own that container. There is no address I could hand to someone else even if I wanted to. More on this in the terms.

When you enter the participant portal

Nothing new about you. You type your address at the door, a link arrives in your inbox, and opening it leaves a small signed cookie in your browser so you are not asked again on every page. The details are in the cookie table below.

I do keep a record on my side of that we tried to send you a door link - the address, when, and whether the sender accepted it. Never the link itself, never a token, never the contents of anything. It exists because when a woman writes "I got nothing", a typo and a silent failure look identical from outside, and I would rather be able to look than guess.

When you write to me through the form on the home page

Your name, your email address and whatever you wrote. The form emails it to me and my site keeps no copy of it. Not in a database, not in a log, not in the measurement. There is no retention period for what you write to me here because there is nothing being retained - the note becomes an email and the site forgets it in the same breath.

I would rather say that plainly than quote you a number of months, because it is the stronger thing and it is now literally true: this form used to be delivered by a third party in the United States who held every message a woman sent, and it does not any more. That door is mine now, and it is the only kind of promise about your words I am willing to make - one the code enforces rather than one I merely intend.

Two honest edges on it. Your note travels through my mail sender to reach me, like any email. And once it arrives it sits in my inbox, where I keep it as long as our exchange is alive, the way anyone keeps a letter. What is gone is the third party in the middle, and any copy held by the site itself.

When you simply visit

My host, Vercel, keeps the ordinary records any web server keeps - the request, the time, the IP address it came from - and I use a count of requests per address, held only in memory for a few minutes, to stop a robot flooding my signup forms. I do not use those records to work out who you are, and I do not build a profile from them.

What the site measures

I do want to know whether what I make is landing - how many women were shown an invitation, gave an email, opened a practice, read an offer, clicked through to pay. So the site counts those steps.

Three things about how that is done, because they are the whole point:

• No names and no email addresses are ever sent into the measurement. Anything that looks like an address, or a field named like one, is stripped out before the record is written - on the browser's side and again on the server's. The counts are counts, not people.
• If your browser says "do not track me", the site does not. Nothing is recorded at all.
• There is no advertising anything. No Google Analytics, no Meta pixel, no advertising cookie, nothing that follows you to another site.

What a measurement row does carry: which step it was, the page path, the campaign and the door name, any utm_ tags your link carried, the host you arrived from (never the full address of the page you came from), a random id that lives only for that one visit, the time, and the country your request appeared to come from, which my host works out and I never see as an address. Those rows land in a spreadsheet I own. Vercel also counts page views without identifying anyone.

Cookies, and the small things stored in your browser

There is no cookie banner on this site because there is nothing to consent to: no advertising or tracking cookies are set, by me or by anyone else.

The first three never leave your browser - they are notes it keeps for itself. The link that lets you into the portal in the first place is a signed token in a URL that is good for fifteen minutes and one trip.

One more signed thing worth naming: the unsubscribe link at the bottom of my letters carries your address inside it, signed, so that one click can take you off the list without you having to sign in or prove anything. That link does not expire - a letter from a year ago must still be able to unsubscribe you.

Where it is actually held

Most of what I hold about you is in MailerLite. The rest sits in a private storage bucket at Cloudflare R2, which is where the platform I have built keeps its own records. Named honestly, because "storage" is where privacy pages usually go vague:

• A contact register - name, email, which of my groups you belong to, how you got there, and a short trail of the events that changed it. This is the same information as the MailerLite list, kept where my own site can read it without asking a third party every time.
• The letters and their schedule - drafts, templates, who a letter is addressed to, when it goes.
• An admin record - a line for each change I make from my tools: when, which of my own addresses was signed in, what was done, and to what. That last part can name a subscriber's address. It never holds the contents of a change, a letter, or anything you wrote.
• A send record - the address a door link was sent to, when, and whether it left. Never the link.
• The recordings, audio and PDFs - the material of the containers, in a private bucket with no public address. Nothing about you.

Nothing in that bucket is reachable from the web. Every file in it is fetched through a link my site signs at the moment you ask for it, which stops working shortly afterwards, and only if you are signed in and own the thing you are asking for.

Who else touches it

I use a small number of services to do things I cannot do alone. Each one only receives what it needs. None of them is allowed to use it for anything of their own.

Nothing is sold. Nothing is given to anyone for advertising. If a court or an authority ever obliged me to hand something over, I would comply with the law and, where I am allowed to, tell you.

Sending it abroad

Most of those companies are based in the United States, so your data goes there. Under Swiss and EU law that needs a legal footing, and the footing I rely on is the one each of them publishes: their standard contractual clauses, and where they hold it, their certification under the Swiss-US and EU-US Data Privacy Frameworks. I have not personally audited each company's paperwork. I am telling you that rather than implying a diligence I have not done.

How long it is kept

Some of these are decisions; some are simply what the systems do. I have marked which is which rather than invent a tidy number.

• If you are on a list: until you unsubscribe or ask me to remove you. There is no automatic expiry. If you unsubscribe, MailerLite keeps the record that you did, so you are not accidentally added back - that record is what protects you.
• If you came to one free gathering: your registration stays with that gathering's record in Zoom and in its list. Ask, and it goes.
• If you were in a paid container: your place in it stays on record while the room exists, because that is what gives you access to it.
• Accounting records - what you paid, when, and for what: ten years. Swiss law requires business books, the vouchers behind them and the reports drawn from them to be kept that long, and it does not make an exception for a small practice. This is the one thing I cannot delete on request, and if you ask me to erase everything, this is what stays and why.
• Your participation itself - the container you were in, your place in it, the material: that is a separate question from the books, and it is mine to decide rather than the law's. I keep it while the room is open and while it is still useful to you, and I remove it when you ask.
• The admin record and the send record: these are capped by size rather than by time - roughly the last two thousand admin lines and the last five hundred send lines, with older ones falling off the end. In practice that is months, not years, but I am not going to dress a size limit up as a retention policy.
• The contact register and the letters: kept for as long as I am working, with no automatic deletion built in. If you ask to be removed, I remove you from it.
• Measurement counts: kept, because they contain nothing that identifies anyone.
• What you write in the contact form: nothing, by the site. There is no store to expire and no log line to age out. Your note lives in my inbox and nowhere else of mine.
• Server logs at Vercel: set by them, not by me. I have not been able to determine that period from my own side, and I would rather say so.

The lawful basis, in plain words

• Because you asked: the letters, the free practice, the gathering you registered for. Consent, which you can withdraw whenever you like, and withdrawing it costs you nothing.
• Because we have an agreement: everything needed to give you what you paid for - your place, your access, your materials.
• Because the law requires it: keeping the books.
• Because it is reasonable and does not cost you anything: counting steps with no names in them, keeping a record of what I changed in my own tools, and keeping the site standing up against abuse. Under the GDPR this is a legitimate interest; under the FADP it is processing that is proportionate to running the thing you came for. If you disagree in your own case, say so and I will stop.

No decisions made about you by a machine

Nothing here decides anything about you automatically, and nothing here profiles you. There is no scoring, no prediction, no algorithm sorting women into kinds.

What does happen, and I would rather name it than let it hide behind that sentence: I group people by what they asked for - the field notes, a particular offer, a container - and a letter goes to a group rather than to everyone. That is a mailing list working as a mailing list, and it is why a woman who just took the free practice does not get ten emails in a fortnight. It is not a judgement about you and it has no legal or similar effect on you.

What you can ask of me

Whether you are in Switzerland, the EU or elsewhere, you can ask me to:

• tell you what I hold about you,
• correct it,
• delete it,
• give you a copy in a form you can take elsewhere,
• stop using it for something, or object to a particular use,
• or withdraw a consent you gave, at any time, without any consequence for you.

Write to hello@yinrhythms.com. I answer these myself, and I will do it within a month. There is no form and no process - a sentence is enough. I will ask you enough to be sure it is really you, and nothing more.

If something goes wrong

If data I hold is lost or exposed in a way that is likely to put you at risk, I will tell the Swiss Commissioner as the law requires, and I will tell you - in words, not in a notice designed to be skimmed.

Children

This work is for adult women. I do not knowingly collect anything from anyone under 16.

If this page changes

The date at the top changes with it. If a change matters to you - a new service holding your data, a new purpose - I will say so in a letter rather than quietly editing a page and hoping you re-read it.

with warmth,
Anna Teresa