Privacy
Who is responsible
The controller of the data described here is [on request], [on request], registration number [on request].
Questions about your personal data go to [email address].
What is collected, and why
Your email address — to send the sign-in link. Without it there is no way to give you access. It is processed to perform the subscription contract (GDPR Art. 6(1)(b)).
Payment details from the processor: the payment id, amount, currency, date, the buyer’s country and the name given at checkout (for a company, the company name), together with the processor’s own notification message about the payment. If you buy as a company, the processor also collects the company’s billing address; it appears on the invoice and is kept by the processor, not on this site. Taking the payment is part of performing the contract (Art. 6(1)(b)); keeping the record is required of us by tax law (Art. 6(1)(c)).
A withdrawal statement, if you send one: the name, email address and payment id you type into the withdrawal page, and when you sent it. Keeping it is required of us as evidence that the statement was received and acted on (Art. 6(1)(c)).
Emails you send to [email address]: your address, what you write and anything you attach. To change the address on an account by hand, support asks for the date and amount of one payment and your card’s last 4 digits and expiry date, never the full card number or its security code. They are used to answer you and to act on a request about your subscription (Art. 6(1)(b)); answering any other message is our own interest (Art. 6(1)(f)).
Sessions: device, browser, the IP address you signed in from, and the time you last used it — so you can see and end your own sign-ins, and so the three-device limit works (Art. 6(1)(b)). The IP address is also what lets a flood of sign-in attempts be blocked, which is our own interest in keeping the door open for everybody else (Art. 6(1)(f)).
Server logs on the members’ site record the IP address, the browser, the page asked for and the result, for security and for finding faults (Art. 6(1)(f)).
What you have read on the members’ site — to show you what has appeared since your last visit (Art. 6(1)(b)) and, counted without your name, to see which posts and topics members read most (Art. 6(1)(f)).
How many new posts your account opens in a day, counted from that same reading history — to hold each account to a daily limit and to spot bulk or automated downloading, which protects the archive members pay for (Art. 6(1)(f)). If an account’s daily limit is lowered for that reason, the date and the note made about it are recorded too.
What you type into the members’ site search — counted per day, with no link to you or your IP address, to see what members look for (Art. 6(1)(f)).
If you dispute a payment with your bank, we may send the payment processor that account’s sign-ins (time, IP address, browser) and the posts it opened and when, as evidence that the service was provided; the processor passes them to the card network and the bank handling the dispute. This rests on our legitimate interest in answering the claim (Art. 6(1)(f)).
Payment
Payments are taken by the processor. Card details never reach this site and are not stored here — only the payment details listed above are.
Who receives data, and where
WEBZILLA B.V. hosts the members’ site in the Netherlands, inside the EEA.
Stripe (card payments, and evidence about a disputed payment), Resend (sign-in links and account notices) and Cloudflare (serving the public site, carrying traffic to the members’ site, storing its encrypted backups, and passing on email sent to support) are established in the United States and process data there. Those transfers are made under the European Commission’s adequacy decision for the EU–US Data Privacy Framework where the company receiving the data is certified under it, and otherwise under the Commission’s standard contractual clauses. Write to [email address] for a copy of the safeguards that apply.
Google receives analytics data only if you accept analytics, and only from the public site. It is received by Google Ireland Limited under the EU–US Data Privacy Framework, backed by the standard contractual clauses in Google’s own Ads Data Processing Terms, and is kept for 14 months.
How long it is kept
Payment records are kept for ten years from 31 December of the year of the payment. That is what EU record-keeping for OSS VAT returns requires.
A withdrawal statement is kept for ten years from 31 December of the year of the payment it names, alongside that payment record.
Emails to support are kept for 24 months from the last message in the conversation, then deleted. An email that withdraws from a contract is kept as a withdrawal statement, for ten years from 31 December of the year of the payment it names.
Your email address is kept for as long as your account exists. An account with no live access and no sign-in for 24 months is deleted, and the address goes with it. To apply this, we keep the time of your last sign-in for as long as the account exists.
A session ends after 60 days without use, and immediately when you sign out. Expired session records are deleted by a daily clean-up.
Server logs are kept for 30 days and then rotated away.
Search counts from the members’ site are kept for 90 days and then deleted.
Encrypted backups of the members’ site are kept for 30 days and then deleted. A deleted account stays in them until then.
Reading history is, per language, the time of your last visit, of the last time the members’ home page was shown to you and of the last post page you opened, each overwritten as you read, and one entry per post you have opened holding only the latest time; all are kept while your account exists.
A lowered limit on an account is kept, with its date and note, until it is lifted or the account is deleted.
Your rights, and deleting your account
You can ask for a copy of your data, for a correction, for deletion, for processing to be restricted, and for your data in a portable form.
Where we rely on our own legitimate interest — the IP address in sessions and in server logs, counting what you read and search, answering a payment dispute, answering a support message that is not about your subscription, and the daily reading limit — you can object to that processing. Where we rely on your consent — analytics — you can withdraw it at any time under "Cookie settings" at the foot of any page, and doing so does not undo what was done before.
Write to support from the email address you sign in with. If we cannot tell who is asking, we will ask you to confirm it before we act.
Deleting an account removes the account record, and with it your sessions, your access rights and your reading history; the email address is cleaned out of the stored payment notification. The transaction itself — processor, payment id, amount, currency and date — stays as tax evidence, because the law requires it to be kept. A withdrawal statement you sent us — your name, the address and payment id you typed, and the date and time — stays with the payment record it names, because it is evidence of a statutory act. If a payment is under dispute, the evidence for it is kept until the dispute is closed.
A request is answered within one month. If it is complicated we may need up to two months more, and we will tell you inside the first month if that happens.
If you think your data has been handled wrongly you can complain to a data protection authority.