Privacy Policy

Operator identified + the AI claim corrected (site-copy audit Part E; operator ruling 2026-09-12). New §0 names Robert Karsten Zaar, an individual of Melbourne, Victoria, Australia, as the entity responsible, and disclaims incorporation and any Apostoli Viae agency (APP 1.4(a)). §4 replaces the flat claim 'Data is not transmitted to any AI provider or third-party processor in the normal operation of the site' — which the feedback-lifecycle page contradicted by promising that straightforward reports 'can have a fix drafted automatically'. MEASURED, not assumed: no code in this repo calls any AI provider, but a human 'escalate' action POSTs the report title and verbatim body to a GitLab issue at git.nwpcode.org (GitLabSyncService::push/buildIssueDescription), deliberately WITHOUT reporter name/username/uid/email, and withholds the body entirely for doctrine/member-interior reports, failing closed to withheld; a human may then label that issue agent-eligible for an off-site drafting helper that may only draft. The helper itself is outside this repository (agent-loop.sh is not in this tree), so the policy states the reachable UPPER BOUND — report text may be processed by an AI service, identity is not part of it — rather than a claim about the helper that cannot be verified from here. The formation-record no-AI promise in the Art.9 consent text is restated explicitly and left unqualified. Also: §3's `SPIRITUAL_THEOLOGY_SUBGUILD_v5.md §7` internal design-document citation replaced with the member's own control at /my/formation-shares; §4 'AVC (Drupal)' and 'SS (Moodle)' renamed to Narrow Way Commons and Saint School; 'the Operator's Gmail account' described as a third-party email provider (Google); §9's 'version field at the top of this document' pointed at new §12, because LegalDocRenderer::cleanMarkdown strips the **Version:** header and the field it named was invisible to every member. Forces re-acceptance. v3: adults-first (nwp/ops#421 D4, operator ruling 2026-09-01): §8 'Children' becomes §8 'Age' — accounts are 18+, the under-16 parental-consent wording is removed; resolves legal-gate item 17. v2: privacy@nwpcode.org role address added ahead of the /contact form (Art.13(1)(a) amendment); v1 operator-drafted initial text; pre-counsel posture unchanged.

Privacy Policy

**Effective date:** 2026-09-01

**Version:** 4

**Operator:** Robert Karsten Zaar, an individual, of Melbourne, Victoria, Australia

**Contact:** privacy@nwpcode.org, or our contact form at /contact

**Status:** Operator-drafted, pre-counsel. Refined wording follows counsel engagement.

This Privacy Policy explains how personal information is handled on

this site. It is written to align with the *Privacy Act 1988* (Cth)

and the Australian Privacy Principles (APPs).

0. Who is responsible for your information

The person responsible for the personal information described here is

**Robert Karsten Zaar**, an individual, of Melbourne, Victoria,

Australia (the "Operator"). The Operator is not an incorporated body

and does not hold this information on behalf of Apostoli Viae or any

other organisation.

This policy covers both **Narrow Way Commons**, the community, and

**Saint School**, the courses. One login works on both.

You can reach the Operator about anything in this policy at

privacy@nwpcode.org, or through our contact form at /contact.

---

1. What information is collected

When you use the site, the Operator may collect:

**Account information**: name, email address, account preferences.
**Authentication identifiers**: if you sign in via OAuth2 (e.g. via

the Narrow Way Commons identity service), the OAuth `sub` claim is stored

to link sessions across associated sites.

**Content you submit**: feedback items, suggestions, comments,

reflections.

**Site usage data**: pages visited, timestamps, IP address,

browser user-agent. Used for site operation, debugging, and

rate-limiting.

**Email correspondence**: if you email the Operator, the email

content and address.

The site does **not** use third-party analytics, advertising, or

fingerprinting. It does **not** sell personal information to anyone.

2. Why information is collected

To:

Operate accounts and authenticate sessions
Display your contributions with attribution (subject to your

profile preferences)

Route feedback to the appropriate reviewer/guild Respond to your support requests Detect abuse Comply with legal obligations

3. Who can see your information

**You** — at all times, via your account profile and dashboard.
**The Operator** — for site administration.
**Guild reviewers** — when reviewing a contribution you've

submitted, they can see the contribution and your account name.

Per the federated content flow, your submission may also appear

as an issue or merge request on `git.nwpcode.org`.

**Other site members** — see only what your own sharing settings

expose. The defaults are private-leaning: your practices and your

written reflections are private to you and are shown to another

member, such as a mentor, only where you have chosen to share them.

You set and change those choices yourself, at any time, at

/my/formation-shares. Your progress through the community is

visible in the ordinary course of taking part, which is what the

formation-consent text you accept at /legal/formation-consent

describes.

The Operator does not share personal information with third parties

except where required by law or where you have explicitly consented.

4. Where data is stored, and what leaves this site

The Narrow Way Commons (Drupal) database, on a Linode VPS in the

United States (region: us-iad) under the Operator's Linode account

The Saint School (Moodle) database, on the same Linode

infrastructure

Backup snapshots stored privately and rotated per the Operator's

backup policy

Email correspondence, held in the Operator's mailbox with a

third-party email provider (Google)

Browsing the site, holding an account, and taking courses send

nothing to any AI service. The site uses no third-party analytics,

advertising, or tracking, and no part of your formation record — the

practices you take up and the reflections you write — is ever sent to

an AI service or used to train one. That is the promise in the

formation-consent text at /legal/formation-consent, and it is not

qualified by anything below.

**One thing does leave this site, and you should know exactly what.**

If you send in a feedback report or a problem report, a member of

staff may decide to escalate it. Escalation is a person's decision,

never automatic. When it happens:

The **title and text of your report** are copied to an issue on the

Operator's own issue tracker at git.nwpcode.org.

**Your name, username, and email address are not copied with it.**

The issue identifies you only by a reference number that staff can

look up back on this site.

If your report touches belief, teaching, or anything personal to you

— the examen, confession, spiritual direction, conscience, or your

own formation record — **the text is not copied at all.** Only a

classification and a link back to this site are sent, and a report

that cannot be classified is treated as though it were personal.

A member of staff may then mark that issue as eligible for an

automated helper, which proposes a draft change for a person to

review. The helper may only draft: it cannot approve, merge, or

publish anything.

That helper is an AI assistant, and it runs outside this site. So the

text of an escalated report — but not your identity, and not anything

withheld under the rule above — may be processed by an AI service. If

you would rather that never happen to something you want to tell the

Operator, use privacy@nwpcode.org or our contact form at /contact

instead of the feedback form; correspondence sent that way is not

escalated to the issue tracker.

5. How long data is retained

Account data: retained while your account is active and for up to

12 months after account termination, then deleted.

Submitted contributions: retained indefinitely as part of the

site's content history; you may request your name be removed

from attribution per §6 below.

Server logs: retained for up to 90 days for debugging and

security purposes, then rotated out.

Email correspondence: retained at the Operator's discretion.

6. Your rights

Under the *Privacy Act 1988* you have the right to:

**Access** the personal information held about you
**Correct** information that is inaccurate or out of date
**Request deletion** of your account data (subject to §5 retention

of submitted contributions for content-history purposes)

**Be removed from attribution** on contributions you have

previously made

**Complain** to the Operator, and if unresolved, to the Office of

the Australian Information Commissioner (OAIC)

**Withdraw consent** to optional processing at any time

Email privacy@nwpcode.org, or use our contact form at /contact, to exercise

any of these rights. Reasonable requests will be honoured within 30 days.

7. Cookies and similar technologies

The site uses session cookies necessary for authentication. No

third-party tracking, advertising, or analytics cookies are set.

8. Age

This site is offered to adults. You must be at least 18 years of age

to hold an account; it is not directed at children, and accounts are

not offered to anyone under 18.

9. Changes to this policy

When this policy is updated, you will be required to re-accept the

new version on next login. The version number is at the foot of this

document, in §12, and it changes when the policy is materially

updated.

10. Contact + complaints

For privacy questions or to exercise any right above, email

privacy@nwpcode.org or use our contact form at /contact. If you believe a privacy breach has occurred and

the Operator's response is not satisfactory, you may also lodge a

complaint with the OAIC at oaic.gov.au.

11. Governing law

This policy is governed by the laws in force in Victoria,

Australia.

12. Version of this document

This is **version 4** of the Privacy Policy. The version number is

recorded here, at the foot of the document, and in the record of your

acceptance. When it changes you will be asked to re-accept this

policy on your next login.

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