Privacy Policy 隐私政策
中文摘要：我们只收集本堂运作所需的资料，不出售个人资料，也不使用广告追踪工具；我们只以不使用 Cookie、不识别个人身份的 Vercel Web Analytics 统计浏览次数。纪念页、留言及供品上的姓名与关系会公开显示。“未寄出的信”从不发送给我们，也不会被保存。付款由 Stripe 处理，我们不会看到或保存您的银行卡或电子钱包资料。如需查阅、更正或删除您的资料，请联络我们的资料保护主任：norestforme@nirvanahall.com。
本政策以英文版本为准。
1. Who we are
This policy explains how the Nirvana Hall of Remembrance 涅槃追思堂 (the Hall) collects, uses and protects personal data, in line with Singapore's Personal Data Protection Act 2012 (PDPA).
The Hall is operated by Nirvana Hall (UEN 53532867B), a business registered in Singapore (we, us).
Data Protection Officer: norestforme@nirvanahall.com. Contact our Data Protection Officer with any question or request about your personal data.
2. What we collect and why
We collect only what the Hall needs to work. By submitting information, you consent to its use for the purposes below.
| Data | When it is collected | Why |
|---|---|---|
| Memorial details: the deceased's name, gender, dates of birth and passing, dialect group, resting place, description | When you create a memorial | To show the memorial, and to write the seal on offerings |
| Portrait photo | When you upload one with a memorial | To show on the memorial and in link previews |
| Message author's name, relationship and message | When you leave a message of remembrance | To show the message on the memorial page |
| Giver's name, relationship to the deceased, and the occasion | When you make an offering | To write the seal, and to show your offering with your name on the memorial page |
| Offering records: the offerings chosen, the memorial, the date and the transaction ID | When you make an offering | To burn it, and to show it in the public burn register |
| Payment details: your card, wallet (Apple Pay, Google Pay, WeChat Pay, GrabPay) or PayNow details, email address and country | At checkout, on Stripe's payment page | Collected and handled by Stripe to process your payment. We receive only confirmation that you have paid, the amount and Stripe's payment reference, which we keep with the offering record |
| Visitor fingerprint: a one-way scrambled code made from your internet address and browser type | When you submit a memorial, message, offering or report | To limit spam and abuse; it cannot be turned back into your address |
| Your country, worked out from your internet address | When you open the Hall | To show approximate prices in your currency; it is not stored |
| Your email and what you write to us | When you email us | To reply and deal with your request |
| Administrator email address | When an administrator signs in | To control access to moderation |
We do not ask for, and ask you not to include, NRIC numbers, contact details or other sensitive information in memorials, messages or names.
3. What we never collect, and what becomes public
Never collected:
- Unsent Letters. Letters written with an offering stay in your browser and are released with the offering. Their words are never sent to us or stored.
- Card and bank details. These go directly to Stripe, our payment provider, and are never sent to us.
- Tracking and advertising data. The Hall uses no advertising trackers. It counts page visits with Vercel Web Analytics, which uses no cookies, does not identify you and does not follow you to other sites.
Public on the Hall:
- Memorials and messages are visible to anyone, may be shared by visitors, and show in link previews on messaging apps.
- Offerings are shown on the memorial page with the giver's name and relationship, the occasion and the items offered. A name our filter flags, or that is reported, is shown as "A family member" until we review it.
- The burn register shows each offering's date, name, memorial and transaction ID.
Permanent on the blockchain. Each burn is recorded on the public Ethereum blockchain with an offering reference code and amount. The blockchain record contains no names, but it cannot be edited or deleted by us or anyone else. If a memorial is removed, its offerings stay on the blockchain, but the Hall no longer links them to a name.
4. Who we share data with
We do not sell personal data or share it for marketing. We use these service providers to run the Hall:
| Provider | What it does | Where data is held |
|---|---|---|
| Supabase | Stores memorials, messages, offering records and photos | Singapore |
| Vercel | Hosts the website, processes requests and counts page visits | United States and other regions |
| Resend | Sends our administrators emails about content that needs review, which may include the content concerned | United States |
| Zoho | Our email service, for emails you send us and our replies | According to Zoho's data centres |
| Google Fonts | Supplies the site's typefaces; your browser requests them from Google | United States and other regions |
| Ethereum network | Records burns publicly | Worldwide, public |
| Stripe | Processes payments for offerings, by card, Apple Pay, Google Pay, WeChat Pay, GrabPay and PayNow, under its own privacy policy | Singapore, the United States and other regions |
Because the Hall serves families around the world, your data may be stored and processed outside the country where you live, mainly in Singapore and the United States. Wherever it is transferred, we take reasonable steps to ensure it is protected to a standard comparable to the PDPA, including through the providers' data processing terms. We may also disclose data where required by law.
5. How long we keep it, and how we protect it
Retention. We keep data only as long as it serves its purpose:
- Memorials, photos, messages and offerings shown on them: for as long as the memorial remains on the Hall. When a memorial is deleted, its details, photo, messages and givers' names are deleted with it.
- Declined memorials and messages: deleted within 30 days of the decision.
- Visitor fingerprints: kept for up to 30 days, then deleted automatically.
- Offering and payment records: kept for 5 years, to meet accounting and tax requirements.
- Emails with us: kept for as long as needed to deal with your request, and no longer than 2 years.
Protection. Data is stored with access controls enforced by the database itself: visitors can see only published content, givers' names are only ever shown in their masked form, and only administrators can see anything awaiting review. Uploaded photos are kept in private storage and served only for published memorials. Connections to the Hall are encrypted. No system is perfectly secure, but we will notify affected people and the Personal Data Protection Commission of any data breach where the PDPA requires it.
6. Your rights
You may ask our Data Protection Officer to:
- access the personal data we hold about you, and learn how it has been used in the past year;
- correct personal data that is inaccurate or incomplete;
- withdraw consent, for example by asking us to remove a message you left, your name on an offering, or a memorial you created. Removing content does not affect the public blockchain record (section 3).
We will respond within 30 days. We may need to confirm your identity first. We may charge a reasonable fee for access requests, and will tell you the fee in advance.
Wherever you live. The Hall is used by Chinese families around the world. We give the rights in this section to everyone, wherever they live, and where the law of the place you live gives you further rights, we will honour them.
If you are in the European Union, the European Economic Area or the United Kingdom. The General Data Protection Regulation (or the UK GDPR) applies. We use your personal data with your consent (when you submit a memorial, message or offering), where it is needed to provide what you ask for, and in our legitimate interest in keeping the Hall safe from spam and abuse. As well as the rights above, you may ask us to erase your data, to restrict or object to its use, or to give you a copy in a portable format. Where your data is transferred outside your country, we rely on safeguards such as the standard contractual clauses in our providers' terms. We will respond within one month. You may also complain to the data protection authority in the country where you live or work.
If you are in Hong Kong. The Personal Data (Privacy) Ordinance (Cap. 486) gives you the right to ask for a copy of the personal data we hold about you and to ask for it to be corrected. We will respond to such requests within 40 days. We do not use personal data for direct marketing. If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong.
If you are in Malaysia. The Personal Data Protection Act 2010 gives you the right to ask for a copy of the personal data we hold about you and to ask for it to be corrected, and to withdraw consent. We will respond to access and correction requests within 21 days. If you are not satisfied with our response, you may complain to the Personal Data Protection Commissioner of Malaysia.
If you are in Taiwan. The Personal Data Protection Act gives you the right to ask to review or receive a copy of your personal data, to have it supplemented or corrected, to ask us to stop collecting, processing or using it, and to ask for it to be deleted. We will respond to review and copy requests within 15 days, and to other requests within 30 days, telling you in writing if we need longer. If you are not satisfied with our response, you may contact Taiwan's personal data protection authority.
People who have passed away. Memorials hold personal data about people who have died. We treat it with care, and will consider requests from family members to correct or remove a memorial, even where they did not create it.
7. Browser storage, changes and contact
Browser storage. Your browser remembers your language choice and whether the ceremony bell is on. The language choice is also kept in a small cookie, so that Stripe's payment page opens in the same language; nothing else is sent to us. While you pay through Stripe, your browser also briefly keeps your offering's seal and items, so the ceremony can be shown when you return; this is cleared once the offering is complete. Administrators' browsers keep a sign-in session so they stay logged in. The Hall sets no advertising or tracking cookies; Stripe's payment page uses its own cookies, as described in Stripe's privacy policy.
Changes. We may update this policy. The date at the top shows the latest version, and significant changes will be announced on the site.
Contact. Questions, requests or complaints: our Data Protection Officer at norestforme@nirvanahall.com. If you are not satisfied with our response, you may contact the Personal Data Protection Commission of Singapore, or the data protection authority where you live (see section 6).