Lisheenaleen is published by Oisín Sedgwick, in Ireland. For the purposes of the General Data Protection Regulation and the Data Protection Act 2018, he is the data controller for this site. Anything on this page can be asked about at hello@lisheenaleen.com.
This is a short policy because the site does very little. It has no accounts, no comments and no shop. The one thing here to sign up to is the newsletter, and the section on it below says exactly what that involves.
No cookies and no analytics
This site sets no cookies. It runs no analytics, no tracking pixels and no advertising scripts, so there is no consent banner, because there is nothing to consent to. Typefaces are served from this site rather than from Google, so loading a page here does not tell Google you were here.
If that ever changes, this page changes first, and anything that needs your consent will ask for it before it runs rather than after.
Server logs
The site is hosted by Vercel. Like any web host, Vercel records requests as they arrive: the IP address they came from, the page asked for, the time, and the browser and operating system reported by the request. That happens at the server and is how a website is delivered and kept up at all.
The lawful basis is legitimate interests, under Article 6(1)(f): serving the site, keeping it available, and dealing with abuse or attack. Those logs are held by Vercel under its own retention schedule, for a short period, and are not used to build any profile of you. Vercel is a US company, certified under the EU-US Data Privacy Framework, and it relies on the EU Standard Contractual Clauses for transfers out of the EEA. Its terms are at vercel.com/legal/privacy-policy.
The newsletter
If you subscribe, your email address goes to Buttondown, the service that sends the newsletter for us. Buttondown also records the IP address and the page you subscribed from, which is how it guards against someone signing up an address that is not theirs. Nothing is added to the list until you click the link in the confirmation email it sends you.
The lawful basis is your consent, under Article 6(1)(a). We use the address to send you the newsletter and for nothing else. It is not shared, sold or used for advertising, and the newsletter does not track whether you open it or which links you click. Every email has an unsubscribe link that works at once, or write to us and we will take you off ourselves.
Buttondown is a US company. It holds the list on our behalf under a data processing agreement that incorporates the EU Standard Contractual Clauses for transfers out of the EEA. Its terms are at buttondown.com/legal/privacy.
If you email us
Your address and whatever you write sits in our mailbox, held by our email provider, and is used to answer you and to keep a record of the exchange. If you are a subject of a piece, the correspondence is kept as part of the record for that piece, which is how a correction or a disputed fact can be traced back later. The lawful basis is again legitimate interests: replying to someone who wrote to us, and being able to stand over what was agreed.
Writing to us does not put you on the newsletter; only subscribing does. Ask us to delete the correspondence and we will, unless it is tied to something published, in which case we will say so and explain why.
Photographs and people in pieces
A piece about a person contains information about that person, which is personal data, and the lawful basis for publishing it is legitimate interests in journalism. The Data Protection Act 2018 sets journalism apart for this reason, and it does not put us beyond reach: a person in a piece can write to us, and the editorial policy sets out how corrections are handled and what gets disclosed.
We photograph people with their agreement, and every usable frame goes to them unwatermarked before we ask them for anything.
Your rights
You can ask for a copy of any personal data we hold about you, ask us to correct it, ask us to erase it, ask us to restrict what we do with it, object to us holding it, or ask for it in a portable form. Write to hello@lisheenaleen.com and we will answer inside one month. There is no charge.
If you are not happy with how we handle it, you can complain to the Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963, or through dataprotection.ie. You can do that without going through us first.
Changes
When this policy changes the date at the top changes with it. If the change is material, such as analytics arriving, it will be said on the page rather than slipped in.