Privacy policy

The controller of the personal data described here is [legal entity name], registered at [registered address] (trading as Kiberry). If you have a question about this policy or about your data, write to askhat@gmail.com.

We have not appointed a Data Protection Officer, as we are not required to under Article 37 of the GDPR.

We collect personal data in one situation only: when you fill in a form on this site. We do not buy contact data, and we do not build profiles of visitors.

When you submit a form — the contact form, the diagnostics request, or a programme registration — we receive the fields you filled in. Depending on the form, that is your name, work email, company, job title, the phone number or Telegram username you chose as a contact method, and the message you wrote. Everything in the message field is up to you: please do not send us data you would not want in an email.

Along with the submission we process two technical signals to keep the forms from being abused: your IP address, held in the memory of the server process for ten minutes to limit how many submissions can come from one source, and a hidden timestamp showing how long the form was open. The IP address is never written to a database and is gone when the ten minutes pass.

Measurement. We use a privacy-preserving analytics tool that counts page views without cookies and without building a profile of you. It does not identify you and we cannot connect those counts to a person. That is why this site has no cookie banner: there is nothing to consent to.

For form submissions, our legal basis is your consent — Article 6(1)(a) of the GDPR. You give it with the checkbox next to the submit button, and you can withdraw it at any time (see clause 07). Withdrawing consent does not affect the lawfulness of what we did before you withdrew it.

For the anti-abuse signals in clause 02, our legal basis is our legitimate interest in keeping the site working and free of automated submissions — Article 6(1)(f). We have weighed that interest against your rights and kept the processing to the minimum we could: an IP address, in memory, for ten minutes.

We read your message and reply to it. If the conversation continues, the thread lives in our mailbox like any other piece of correspondence. We do not use what you send us for advertising, we do not sell it, and we do not pass it to anyone except the processors named in clause 05.

Two suppliers touch your data on our behalf, both under data processing agreements:

• Resend — delivers the email that carries your form submission to our mailbox.
• Vercel — hosts this site and runs the code that receives your submission.

Both are established outside the EEA. Transfers to them rely on the European Commission’s Standard Contractual Clauses, together with the technical measures described in this policy. You can ask us for the details of those safeguards at the address in clause 01.

[Where the mailbox that receives form submissions is operated, and the safeguard relied on for that transfer]. We are in the middle of changing this arrangement and will update this clause when it is settled.

Correspondence that came through a form is kept for [retention period] from our last exchange with you, after which it is deleted. The technical anti-abuse signals in clause 02 are kept for ten minutes. If you ask us to delete your data sooner, we do — see clause 07.

Under the GDPR you can ask us to:

• tell you what data about you we hold, and give you a copy;
• correct anything that is wrong;
• delete it;
• restrict what we do with it;
• hand it to you, or to someone else, in a machine-readable form;
• stop processing it where we rely on a legitimate interest.

You can also withdraw your consent at any time. One email to askhat@gmail.com is enough for any of this — there is no form to fill in and no reason you need to give. We answer within one month, as Article 12(3) requires.

If you think we have handled your data badly, you can complain to a supervisory authority — in the EU country where you live or work, or to [our lead supervisory authority]. We would rather you told us first, but it is your right either way.

This site sets no advertising or tracking cookies. The analytics described in clause 02 work without cookies, and nothing on the site follows you to other sites.

When what we do with data changes, this page changes with it, and the date at the top moves. If a change materially affects people who have already written to us, we will say so by email rather than quietly editing the page.

Email askhat@gmail.com, or message us on Telegram. For anything else about working with us, the contact page is the place to start.