ProcessingData and purposeLegal basisStorage and recipientsRetention
01Project inquiry
Name and email (required); phone number, company, preferred collaboration type, project types, stage, budget, timing and project summary; language/source; fixed interface values; and a derived private price range, complexity and budget-fit assessment. Used to review and answer a request, prepare a possible engagement and open a project space.
Steps requested before a possible contract (GDPR Art. 6(1)(b)). Where the message is not pre-contractual, the legitimate interest in answering a professional inquiry (Art. 6(1)(f)).
Saved in the site’s Cloudflare D1 database. A second copy, including the derived assessment, is sent server-to-server to the private Studio inquiry service when that integration is configured. Accessible to Fadel Santiago and the infrastructure providers needed to run those services.
For a prospect who does not become a client: 3 years from collection or the prospect’s last active contact. If the inquiry becomes a client relationship, correspondence needed as evidence of the commercial relationship: 5 years after the relationship ends. The inspected site and Studio source contain no automatic deletion job; these limits require a documented periodic manual review and deletion process.
02Private project portal
A 64-character access token, initially present in the invitation URL, and an inquiry identifier authenticate the browser. The portal retrieves the client name, company, project details, status and timestamps, and stores messages of up to 4,000 characters. Used to secure and operate the invited client conversation.
Steps before a contract or performance of the requested service (Art. 6(1)(b)); legitimate interest in access security and service continuity (Art. 6(1)(f)).
The site relays requests to the private Studio service using a server-side service credential. Portal cookies are HTTP-only and are not available to client-side JavaScript. The access URL, including its token, is necessarily received by the delivery infrastructure for the initial request. Fadel Santiago and the relevant infrastructure providers can receive the records needed to operate the portal.
The access cookies last no more than 90 days and can be erased with “Forget this device”. The Studio access session also stops authorizing access after 90 days. Cookie or session expiry does not delete the inquiry or messages; those records follow the 3-year prospect or 5-year client-correspondence rule above. No automatic server deletion is implemented.
03Optional first-party interaction measurement
After consent only, a random browser identifier is created. The current interface records opening the brief and viewing a named service or use case, with the page language. The event table stores the identifier, event name, limited context and creation time. It does not store the inquiry form fields, and the application does not write IP address or user-agent into that table.
Consent (Art. 6(1)(a)). Refusal has no effect on normal navigation. Consent can be withdrawn through Privacy settings.
Saved only in the site’s first-party Cloudflare D1 database and available to Fadel Santiago and the infrastructure providers needed to operate it. This first-party path does not send data to Google Analytics or an advertising platform.
The browser identifier is removed when consent is rejected or withdrawn and when an expired choice is processed. Server-side events are limited to 25 months from the event date. The inspected source contains no automatic deletion job, so this limit requires periodic manual review and deletion; an earlier deletion can be requested at any time.
04Optional Google Analytics 4 portfolio measurement
Only after a current explicit analytics choice, the site can send a manual page_view containing the page path without its query string or hash, a sanitized referrer, the page title and routine device and browser data collected by the Google tag. It can also send github_click when a public repository link is selected and contact_click when a public project-inquiry, business email or telephone link is selected. Those manual interactions contain only an allow-listed project_id when relevant, link_type and language; they never contain an email address, telephone number or full external URL. No CV download is currently published, so no cv_download event is emitted. Google may also create its standard session events, including first_visit, session_start and user_engagement; they receive the same sanitized page context. Private portal paths are reduced to /portal before sending, and external referrers are reduced to their origin. Names, email addresses, inquiry contents, portal identifiers and the first-party browser identifier are not sent. Enhanced Measurement and Google-tag automatic detection for history changes, scrolls, outbound clicks, form interactions, videos and downloads are disabled. Google Signals and ad-personalization signals are disabled; advertising storage, advertising user data and advertising personalization remain denied. With analytics consent, once the server confirms that a project inquiry was successfully saved, GA4 may also receive a generate_lead event containing only the page language. It does not contain the submitted name, email address, project description, message contents, inquiry identifier or portal URL. Operational processing of the submitted inquiry is separate from optional analytics: the inquiry is saved whether analytics consent is accepted, rejected or later withdrawn.
Consent (GDPR Art. 6(1)(a)). Refusal has no effect on normal navigation. Consent can be withdrawn through Privacy settings, which immediately disables further collection in the loaded tag and removes accessible Google Analytics cookies.
Google Ireland Limited provides Google Analytics to users in the EEA and may use affiliates and subprocessors under its applicable terms. No Google Tag Manager, Google Ads or advertising service is added. Google states that EU, Swiss and UK IP addresses are used to derive coarse location before being discarded and are not logged or stored.
The Google Analytics property was verified on 21 October 2026: event data retention is set to 2 months and user data retention to 14 months, with user retention reset on new activity. These property settings are distinct from browser storage. Separately, the site code caps Google Analytics cookies at 180 days from the first consented visit and does not refresh that expiry.
05Security and delivery
Normal web requests necessarily expose request-level technical data such as IP address, browser headers, requested URL and time to the services delivering and protecting the site. Cloudflare may set its essential bot-management cookie. RELAINE pages currently request two screenshots from GitHub’s raw-content domain, so GitHub receives the normal request data for those images.
Legitimate interest in secure, reliable delivery and presenting the portfolio (Art. 6(1)(f)). The Cloudflare security cookie is essential rather than optional analytics.
The site is published through OpenAI ChatGPT Sites and uses Cloudflare application, security and D1 infrastructure. GitHub receives a request only when a page loads externally hosted RELAINE imagery or when a visitor follows a GitHub link.
OpenAI and its subprocessors retain service, security and operational records under the agreement and policies applicable to ChatGPT Sites. Their exact log periods and this Site’s deployment region are not exposed in the project configuration, so no specific country or log duration is claimed here.
