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01
Who is responsible
Clavestra Capital Limited (Malta, company number C 113987), which runs CounterProof Research, the publisher of CounterResearch. Contact: counterresearch@nym.hush.com.
02
What we process, and why
- Server logs. When you visit, our hosting provider (GoDaddy) and the content delivery network it uses for this site (Cloudflare, a separate company) record technical data such as your IP address, browser type, the pages requested and the time. This is needed to deliver the site and keep it secure.
- A security cookie from Cloudflare. Cloudflare sets a cookie named
__cf_bmto distinguish people from automated bots. It expires after 30 minutes without activity and is not used for advertising. - Measurement scripts added by our host. GoDaddy adds two scripts to the site, loaded from img1.wsimg.com, that measure how the site performs and is used. They set cookies named
_tccl_visitor,_tccl_visitand_scc_session. - Emails you send us. If you write to us, we keep your message and address to reply and, for corrections, to keep a record of what was changed and why. Our email provider is Hushmail.
The legal basis is our legitimate interest in running a secure site and answering the people who write to us (Article 6(1)(f) GDPR). We do not sell personal data or use it for marketing.
GoDaddy and Cloudflare are US companies and may process this data outside the European Economic Area. GoDaddy states in its global privacy notice that it is certified under the EU-U.S. Data Privacy Framework. That notice covers data it handles as controller. Cloudflare’s data processing terms recognise transfers under the same framework. We have not yet confirmed which safeguards apply to transfers of this site’s personal data to the United States or other countries outside the European Economic Area. You can ask us for details.
03
How long we keep it
Server logs are kept by our hosting providers, not by us, and we do not keep copies. We have not yet confirmed the exact periods GoDaddy and Cloudflare apply. Until we confirm them, the criterion is that logs are kept for no longer than the time needed to deliver the site and keep it secure, or for any minimum period required by law. We will add the providers’ confirmed periods to this notice. We delete emails one year after our last exchange, except those that led to a correction, which we keep for as long as the corrected review is published.
04
Your rights
You can ask us for access to your personal data, for its correction or deletion, or to restrict how we use it, and you can object to how we use it, by writing to the address above. You can also complain to the Information and Data Protection Commissioner in Malta.
05
Changes
If this notice changes, the new version will be on this page with its date.
