Privacy Policy

This policy explains which personal data we process on www.akelani33.com, why, and how you can exercise your rights, including withdrawing a tribute from the Ocean of Memories. It follows Regulation (EU) 2016/679 (GDPR) and the Spanish Organic Law 3/2018 (LOPDGDD).

Last updated: October 18, 2026

1. Data controller

Owner
(to be completed)
Tax ID
(to be completed)
Address
(to be completed)
Contact email
(to be completed)
Website
www.akelani33.com

2. What data we process and why

We only process the data that is strictly necessary, depending on what you do on the site:

  • Ocean of Memories. Your name (or how you wish to appear), the name of the person being honoured, the note you write, whether you allow it to be published, the date and time of the tribute, your sharing code and the version of this policy you accepted. Of the withdrawal code we only keep an irreversible hash. Purpose: to record the tribute, link it to the honoured person’s circle of memories and, if you allow it, display your note.
  • Song votes. One counter per song and language. We do not store who votes; to prevent abuse, the voting frequency is limited per IP address, which is not kept longer than needed for that limit.
  • Security and abuse prevention. The tribute service uses a salted cryptographic hash of your IP address that expires after one hour. We do not store your IP address in clear.
  • Preferences on your device. The light/dark theme and the circles you have opened are kept in your browser’s local storage and are not sent to any server. We use no advertising or analytics cookies.
  • Email (only if you ask for the email). If you use “Send by email”, your address is sent to Brevo to deliver the codes to you. We do not store it in our system; only an irreversible salted hash that expires after 24 hours is counted to limit abuse. The message contains the name of the honoured person and the codes, never your note or your name.

3. Legal basis

  • Performance of your request (Art. 6(1)(b) GDPR): recording the tribute you ask for and, if you request it, emailing you the codes.
  • Consent (Art. 6(1)(a) GDPR): you accept this policy when you record a tribute and, if you tick the relevant box, that your note is shown in the circle of memories. You may withdraw consent at any time by withdrawing the tribute (section 8), without affecting prior processing.
  • Legitimate interest (Art. 6(1)(f) GDPR): keeping the service secure and preventing abuse.

4. Deceased persons and third parties

The GDPR does not apply to the data of deceased persons, but Spanish law (LOPDGDD, Art. 3) allows their heirs or persons closely linked to them to request access, rectification or erasure.

By recording a tribute you declare that you have a relationship with the honoured person and are entitled to remember them. Please do not include health data or other specially protected data, or data of living people other than yourself, in your notes. We may remove content that breaches these rules or infringes the honour of third parties.

5. Recipients and international transfers

Only the following is shown publicly in a circle of memories: the honoured person’s name, your abbreviated name (e.g. “María P. L.”), the date and your note only if you ticked the publication box. Private notes are never sent to any visitor; only the controller can see them. We do not sell or share your data.

To provide the service we use processors: Vercel Inc. (hosting and application runtime), Upstash (database) and Brevo (Sendinblue SAS, France; delivery of the email with your codes when you ask for it, without creating contacts or lists). They may process data outside the European Economic Area under appropriate safeguards (standard contractual clauses and/or the EU–US Data Privacy Framework).

6. How long we keep data

  • Tributes are kept while the service is active or until they are withdrawn.
  • When the last tribute of a circle is withdrawn, the circle is deleted.
  • The IP hash used to limit abuse expires after one hour.
  • Technical logs of the hosting provider are kept according to its own retention periods.
  • The email you enter to receive the codes is not stored in our system; Brevo keeps the technical record of the delivery according to its own retention periods.

7. Your rights

You may exercise your rights of access, rectification, erasure, objection, restriction and portability, and withdraw your consent, by writing to (to be completed) (or by withdrawing the tribute yourself, as explained below). We will reply within one month at most (Art. 12(3) GDPR) and may ask you for information to verify your identity.

If you believe we are not handling your data properly, you may complain to the Spanish Data Protection Agency (www.aepd.es) or to your local supervisory authority.

8. How to withdraw a tribute

You can withdraw your tribute whenever you want, immediately and free of charge:

  • With your withdrawal code. When you record a tribute, a withdrawal code (format XXXX-XXXX-XXXX-XXXX) is shown only once: keep it. On the Ocean of Memories page click “Withdraw a tribute”, enter the code and confirm.
  • What is deleted. Your note, your name, your sharing code (the link you sent stops working) and its link to the circle are erased. If it was the last tribute in the circle, the circle disappears. The honoured person’s name stays as long as other tributes remain in the circle.
  • If you lost the code. Write to (to be completed) stating the honoured person’s name, your name, the approximate date and, if you have them, your sharing code or the circle code. We will verify that you are the author before deleting (so that no one else’s tribute is removed) and will do so within one month at most.
  • Relatives of the honoured person. You may ask by email for the removal of a specific tribute or of the whole circle, proving your link with the deceased (Art. 3 LOPDGDD).

Withdrawal cannot undo copies that other people made on their own of content that was public.

9. Minors

The service is intended for people over 14. If you are younger, you need the authorisation of a parent or guardian to record a tribute.

10. Security

We apply proportionate technical and organisational measures: encrypted connection (HTTPS), validation of all incoming data, long random codes, per-IP usage limits, origin checks on requests, storing the hash (not the code) of the withdrawal code, and always displaying notes as plain text. No system is infallible, though: do not write in the notes anything you would not want someone to be able to read.

11. Changes to this policy

If we change this policy, we will publish the new version and its date here. The version accepted by each person is stored with their tribute.