Privacy Policy

v1 - released on 31/10/2020

To provide our services to you, it is sometimes necessary for us to collect or process information about you, in one or more of the following forms:

1. Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
2. Information that is automatically sent to us by your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
3. Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.

This privacy policy sets out the detail of what information we collect, as well as how that data is used and protected.

Our commitment to data privacy

We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.

This website is designed with privacy in mind, and we operate a ‘data minimisation’ principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary. We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’).

Should you have any questions or concerns about the data we hold about you, I can be contacted using the information below:

marco@zanzo.me

Marco Zanzotera, PLDO
Perleberger Str 42C, 10559 Berlin

Definition of ‘personal data’

When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.

Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, we will cover the use of such data here also.

We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. This website belongs to an individual and the information contained within it is not affiliated to any company or organisation. Same applies to the information that you will share when engaging with or navigating through the website.

Some important details:

• Security: We use a plugin provided by Defiant Inc, which is called Wordfence™ – this is a security software that protects our website. Only limited, technical data (such as device IP address, browser type/version, language etc) may be transmitted.
• Analytics: We use Matomo analytics to obtain non-personally identifiable information (browser, country of visit, date/tame, anonymised IP, etc) on how our visitors use the website; such plugin is installed locally and its data is stored together with the website’s.
• Our web hosting supplier (currently Namecheap) hosts the physical infrastructure in their datacenters, which may be located outside the EU; to ensure no personally identifiable data of our visitors is saved on their server, whenever you get in contact with us through the website, your request is processed immediately, and is not saved onto their server
• The processing of such request is handled by Mailgun, which in the context of GDPR is considered a processor and therefore only uses information sent to them to process it and removes it afterwards (in particular, message bodies are retained for 7 days and can only be accessed under particular circumstances)
• Embedded content from other websites: some pages or articles on this site may include embedded content (e.g. videos, images, buttons, etc.) which typicall behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How your data is protected

We take the security of all personal data very seriously, and that data is protected in a number of ways:

• Access control: access is controlled by individual user accounts, for which we enforce strong passwords policy
• Dedicated security software: as mentioned above, we leverage security scanning and access control software on our website. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
• Data encryption: this website is secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.
• Minimisation of third-party services: we use a very limited number of third party service providers, however some are essential for the provision of physical hosting environments. One of the core criterias in the selection of providers we engage with is their ability to provide secure systems and processes, and/or their application of high privacy standards when processing requests on our behalf.

Access to your personal data

In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:

• you have the right to obtain from us confirmation about whether any such data is being held;
• you have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
• Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
• you have the right to require us to rectify any incomplete or incorrect information held about you;
• you have the right to require us to erase the data held about you (the ‘right to be forgotten’);

In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies), you have the right to object by simply opting out through the “cookie consent” and/or by disabling the use of cookies and other technologies such as javascript within the options of your browser.

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.

When you complete a contact form on our website, we may ask you for a number of pieces of personal information, such as your name, email address and other contact details. This is obviously required for us to respond to your request.

If you do not use or submit an online form on the website, no data will be collected in that regard.

Legal Basis:

Consent (GDPR Art 6(1)(a)): Generally, we will ask for your explicit permission to process this data before you are able to submit the contact form. We will also give you a link to our Privacy Policy (this document) that you may review before submitting your details.

Intent to contract (GDPR Art 6(1)(b)): Additionally, the information that you provide to us here is necessary for us to fulfil your request prior to entering into a contract.

Types of processing

• We will process the data you submit through our email provider
• We will store the information you provide to us in a secure, encrypted email inbox. Such storage allows us to safely access your data and respond to your requests;
• We will only use this information to contact you to respond to your request;
• We will NOT use this data for any further purpose without your express further consent;
• We will NEVER sell your information to any 3rd party.

Data minimisation:

We will only ask you for the minimum amount of information required to appropriately fulfil your request. This will usually be your name, one or more contact details, and any specific information about your request.

Retention

We will retain this data for a maximum of 12 months.

This website does not allow registration of users besides administrators, therefore no data will be collected or requested from you in this regard.

Technical data (such as ‘IP address’)

When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.

Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).

IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.

Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.

Legal Basis

In the event that such anonymous data is considered to fall within the scope of the applicable data protection regulations, the legal basis for processing such data is:

Our Legitimate interest (GDPR Art 6(1)(f)): The integrity, security and performance of our systems and infrastructure is a vital part of the services that we offer. We consider that it is in our legitimate interest to maintain and protect our systems to this end.

Types of processing

• We will store the information you provide to us in our website server logs
• For the purpose of maintaining the integrity of our systems, we may also store this data in infrastructure backups
• We will NOT use this data to attempt to identify an individual person

Retention

Server logs and backups are retained for a maximum of 12 months following the closure of the relevant log file.

Cookies & ‘similar technologies’

We have included cookies and similar technologies into one section because they all perform similar functions even if, from a technical perspective, they work slightly differently.

All of these technologies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.

These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.

Cookies

These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

• Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
• Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
• First-party cookies are set by the site you are visiting.
• Third-party cookies are set by a third party site separate from the site you are visiting.

There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.

They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.

Additionally, we have incorporated specific cookie functionality on our website that allows you to easily indicate when you first visit the site whether or not you are happy for cookies to be set on your device.

Perhaps ironically (no, seriously), for our site to remember your preference for whether to allow cookies or not, it is necessary for us to set cookies for this specific purpose.

When you first visit our site, a Cookie Control box will be displayed allowing you to choose whether to allow cookies or not. Only Essential cookies will be set when you first visit our site.

If you click on the ‘Accept’ button in the Cookie Control box, we will enable our Analytics and Marketing cookies. Alternatively, you can click the ‘Settings’ button, where you will see further information and have the ability to accept or reject our different types of cookies individually.

If you do not positively agree to the use of cookies in one of the ways described above, we will not set any non-essential cookies.

you can change your choice at any time by clicking on the persistent cookie icon at the bottom of the screen.

Our uses of such technologies fall into the following general categories:

1. Essential. We may use cookies or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; 
2. Performance Related. We may use cookies or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
3. Functionality Related. We may use cookies or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools;
4. Marketing Related.  We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites.  This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.

The cookies currently in use on this site are as follows:

Cookie	Purpose
CookieControl	Essential – required for our Cookie Control mechanism to work
_pk_ses, _pk_id	Performance Related – Analytics cookies set by Matomo
wfwaf-authcookie-(hash)	Essential – these are set by our security software, Wordfence, enabling that system to distinguish visits from different users and user types, and helps us to identify and prevent fraud and attempted unauthorised access to our systems.

We use Matomo to better understand what people look at on our website.

When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) is sent in an anonymous form to Matomo (which is hosted on our own servers).

The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.

We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.

As analytics information is not personal data, we do not specifically ask for your prior consent.

In addition to Matomo, we use a number of industry-standard Google services to provide particular pieces of website content. These include:

• Google Fonts: We may use one or more of Google’s web fonts to ensure that our website content is displayed in a clear and consistent fashion across all of the different types of devices and browsers.
• Google Recaptcha: We may use Google’s Recaptcha service (which provides the ‘I Am Not A Robot’ functionality) on our web contact forms. This is a security measure to prevent the abuse of our contact forms by automated programs.

Each of these services involve our website making a connection to one or more Google servers, and may result in Google placing cookies on your device.

Google Fonts

By using Google Fonts, we make a connection to the Google Fonts API and, unless your browser has already stored a copy of the font in use (by virtue of visiting another website that uses it), your browser will download a copy of that font. This all happens in near real time, and means that our website content will be displayed on your device in the way we had intended it, regardless of whether the particular font is installed on your device.

The Google Fonts API connection is unauthenticated, meaning that it will work regardless of whether you are logged into Google. It does not rely on cookies being sent to Google. Google may capture your device’s IP address as part of this process, and uses this data only in aggregate form to understand the popularity of individual fonts. More detail can be found on the Google Fonts FAQ page.

Lawful Basis

• Under the Google Terms of Service we ask for your consent to process your personal data in this way (GDPR Article6(1)(a)) as part of this privacy policy. However, please note that this is not the only lawful basis on which we process this data
• We consider that it is in our Legitimate Interest to process data in this way under GDPR Article 6(1)(f). The use of Google Fonts is a means of ensuring a clear and consistent display of our web content, in a way that improves user experience. The data collected by Google is extremely limited and we consider that it has negligible impact on individuals’ data privacy.

Google Recaptcha

We use the Google Recaptcha (‘I Am Not A Robot’) functionality to prevent automated programs (or ‘bots’) abusing our contact forms with spam messages or other malicious activity.

Before submitting a contact form to us, you may be asked to check the ‘I Am Not A Robot’ checkbox. In the background, Google will perform a number of checks that are aimed at understanding the likelihood of your being a ‘real’ person, as opposed to an automated system. If it is in any doubt, it will ask you to perform one or more activities (such as identifying particular items within an image) that only a ‘real’ person can do.

The exact mechanism for this is a closely guarded Google secret, but it does involve Google checking your activity on our (and other) websites and the presence/absence of any Google cookies in place on your device.

Lawful Basis

• Under the Google Terms of Service we ask for your consent to process your personal data in this way (GDPR Article6(1)(a)) as part of this privacy policy. However, please note that this is not the only lawful basis on which we process this data
• We consider that it is in our Legitimate Interest to use Recaptcha in this way under GDPR Article 6(1)(f). It enables us to maintain the security and integrity of our systems by minimising spam, and to provide an efficient service to ‘real’ users. On balance, we consider that it has a negligible impact on individuals’ privacy.

One last thing around privacy

You can always use your browser’s ‘private’ or ‘incognito’ mode to browse websites anonymously. Further, you can employ the use of tools such as VPNs to disguise your real position or encrypt your traffic further.

As a strong advocate of personal privacy, I endorse the use of such tools and I set up this website in a way where the information collected is limited to either:

• Useful for us to understand the effectiveness of our initiatives (e.g. sharing content, writing stories, podcasts, etc.) – in which case it happens in an anonymous, unidentifiable fashion
• Necessary for our user to get in touch and get their request answered – in which case we ask for minimum information and won’t use it for any purpose other than that (no, not even marketing)

I feel this is in line with the goal of this website and with my principles as an individual. I hope users who are privacy-conscious will appreciate and share my views on such choices.