Privacy Policy

Last updated: [DATE]. This page explains which personal data this website processes, on what legal basis under the GDPR (EU 2016/679), and which rights you have.

1. Controller

Responsible for data processing on this website:

[CONTROLLER LEGAL NAME]
[STREET AND NUMBER]
[POSTCODE, CITY, COUNTRY]
Contact:

2. Hosting and server logs

This site is served by Cloudflare Pages (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA). When you visit a page, Cloudflare processes technical connection data (IP address, date and time, requested URL, browser user agent) to deliver the site and to protect it against attacks. The legal basis is our legitimate interest in operating a secure and fast website (Art. 6(1)(f) GDPR). Cloudflare acts as our processor under Art. 28 GDPR; transfers to the USA are covered by the EU-U.S. Data Privacy Framework and standard contractual clauses. We do not combine these logs with any other data. [SERVER MODE ONLY, DELETE IN SCRIPT MODE: On this site's own domain, Cloudflare also passes the data described in section 3 to our analytics tool.]

3. Cookies and analytics

This website is ad-free and sets no cookies. Your visit leaves no advertising or cross-site tracking identifiers with us.

To understand how the site is used, we run Plausible Analytics, a web analytics tool [CHOOSE ONE: self-hosted on our own server (first confirm that no web server, proxy or CDN log keeps IP addresses, or say so here) / operated for us as our processor (Art. 28 GDPR) by Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estonia (EU)]. [SCRIPT MODE ONLY, DELETE IN SERVER MODE: Its script sets no cookies and writes nothing to your device. It checks one setting in your browser, which lets you exclude your own visits, and whether the browser is automated; neither is sent to the measurement server. When you open a page, it sends the address of that page and the page or site you came from to the measurement server, together with the technical data your browser sends with every request (browser, operating system, device type, IP address). When you leave the page or switch to another tab or window, it also sends how far you scrolled and how long the page was visible and in focus.] [SERVER MODE ONLY, DELETE IN SCRIPT MODE: No analytics code runs in your browser, and nothing is stored on or read from your device for it. When you open a page, the server that delivers this site (Cloudflare, see section 2) passes the address of that page and the page or site you came from, if your browser sends it, to the measurement server, together with the technical data your browser sends with every request (browser, operating system, device type, IP address).] [DELETE UNLESS OUTBOUND LINKS IS TICKED IN PLAUSIBLE: It counts clicks on links to other websites and sends and stores the address of the link you clicked.] [DELETE UNLESS FILE DOWNLOADS IS TICKED IN PLAUSIBLE: It counts clicks on links to files, such as PDFs, and sends and stores the address of the file.] [DELETE UNLESS FORM SUBMISSIONS IS TICKED IN PLAUSIBLE: It counts submissions of forms on the site, but not what you enter.] [SCRIPT MODE ONLY, DELETE IN SERVER MODE: It also counts each click on an email address on this site, and on a button that opens your email program, together with the page it was on and the page or site you came from. Neither the email address nor anything you typed is sent.] [SERVER MODE ONLY, DELETE IN SCRIPT MODE: A click on an email address on this site passes through our server, which counts it together with the page it was on and then opens your email program. The email address is not sent to the measurement server.] The tool derives your approximate location from the IP address and does not keep the IP address in its own records. From your IP address, your browser data and this website's domain, plus a value that is replaced every 24 hours, it forms an identifier. While that value lasts, and as long as those inputs stay the same, the tool therefore recognises the same browser and counts it as one visitor. Once the value is replaced, it can no longer recognise that browser; only a visit that is still going at that moment (one with activity in about the last 30 minutes) continues as the same visit. Nor can the tool recognise that browser on another website. The individual events (for example each page view[SCRIPT MODE ONLY, DELETE IN SERVER MODE: , and the scroll depth and engaged time sent when you leave a page or switch away from it]) and the session records are stored with this identifier, the page address, the referrer, the location and the device data, and are shown as aggregated counts, for example page views, referrers and countries.

The legal basis is our legitimate interest in understanding how the website is used and in improving it (Art. 6(1)(f) GDPR). [STATE THE STORAGE PERIOD, for example: We keep these records for 24 months and then delete them.] [SCRIPT MODE ONLY, DELETE IN SERVER MODE: You can prevent the measurement by blocking the analytics script in your browser.] [SERVER MODE ONLY, DELETE IN SCRIPT MODE: The measurement happens on the server, so blocking scripts in your browser does not prevent it. You can object to it (see section 5).]

4. Contact by email

If you contact us, we process the data you provide (name, email address, and the content of your message) to handle the request and possible follow-up questions. The legal basis is Art. 6(1)(b) GDPR where the request relates to a contract, otherwise our legitimate interest in answering enquiries (Art. 6(1)(f) GDPR). We keep the correspondence only as long as needed for this purpose and for any statutory retention duties.

5. Your rights

Under the GDPR you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection to processing based on legitimate interest (Art. 21). To exercise any of these rights, contact us via the address in section 1; we will verify your identity before acting on a request. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).

6. Changes to this page

We will update this page whenever the data processing on this site changes, and adjust the date at the top accordingly.