Privacy policy

This policy explains what information fredcornell.com collects when you read it, why, who else handles it, and what you can do about it.

1. Who we are

fredcornell.com is run by Fredrik Cornell through his company, CFC CRM Consulting Ltd, a private limited company registered in England and Wales (company number 14762661), registered office Flat 13 Knightswood House, 14 Rowe Lane, London E9 6EL. In this policy "we" means that company. We decide how your information is used, which makes us the "controller" under data protection law.

Contact for anything in this policy: [email protected].

2. The short version

• You can read every page without giving us your name or email address.
• We use Google Analytics and Cloudflare Web Analytics to count visits and see which pages and charts people use.
• If you are in the UK or Europe, they run only if you press Accept on the cookie bar. Everywhere else they run unless you switch them off, or your browser sends Global Privacy Control.
• You can change your choice at any time with "Cookie settings" at the foot of every page.
• Charts embedded on other websites do not use Google Analytics or Cloudflare Web Analytics.
• We do not sell your information.

3. What we collect and why

When you open a page

Our site is delivered by Cloudflare. To send you a page, Cloudflare receives your IP address and basic details of your request, such as your browser type and the page asked for. Cloudflare uses this to deliver the page, to protect the site against attacks and abuse, and to tell our site which country the request comes from, so that we know whether to show you the cookie bar. Cloudflare keeps its own records of requests for the periods set out in its terms. We do not store your IP address ourselves.

Google Analytics

Google Analytics tells us how many people visit, which pages and charts they use, roughly where they are, what device they use and how they found us. It works by placing cookies in your browser (listed in section 5) and sending Google information about your visit, including your IP address, which Google uses to estimate your location. We use the results to decide what to build and to fix what does not work.

We have set up Google Analytics so that:

• Google keeps the detailed data for 14 months and then deletes it;
• Google Signals is off, so your visits are not linked to your Google account;
• it is not used for advertising and is not linked to any advertising account;
• Google may not use the data for its own products, benchmarking or other purposes beyond providing the service to us.

We also keep our own copy of the Google Analytics data, and of the daily Cloudflare Web Analytics figures, in Google BigQuery in the EU, so that we can compare one year with another. We keep this copy for five years and then delete it.

Cloudflare Web Analytics

Cloudflare Web Analytics also counts page views, and shows us how fast our pages load. When it runs, a small script from Cloudflare sends Cloudflare the address of the page, the page you came from, your browser, operating system and type of device, and how long the page took to load. The request reaches Cloudflare with your IP address, as described above, and Cloudflare works out your country from it. It sets no cookies and stores nothing in your browser. Cloudflare says it does not use this data to follow you across other websites. It keeps the full records for 7 days and then a reduced sample, from which we can see reports for six months.

Your cookie choice

We remember your choice in your browser, so we do not ask again on every page. If you accept, we keep that for up to six months and then ask again. If you reject or switch analytics off, we keep that until you change it. Some browsers, including Safari, clear stored choices sooner. In the UK and Europe we then ask again; elsewhere analytics runs again until you switch it off.

We also keep a record that a choice was made: a random identifier stored in your browser, the date and time, your country, the choice and how you made it, and the versions of the cookie bar and of this policy you saw. The record holds no name, email address or IP address. Because it is linked to an identifier in your browser, we treat it as personal data. We keep it for two years to show that we asked properly, then delete it.

When you email us

If you email us, we keep your message and address to reply to you, and for up to two years afterwards unless the law requires longer.

Advertising (not yet in use)

We do not show advertising at the moment. If we start, this section will say which advertising companies we work with and what they collect, the date at the top of this policy will change, and readers in the UK and Europe will be asked again before any advertising cookies are set.

Email updates (not yet in use)

We do not run a mailing list at the moment. If we start one, we will ask for your email address only with your clear agreement at the point you sign up, send only what you signed up for, put an unsubscribe link in every email and name here the company that sends the emails for us.

Charts embedded on other websites

Our charts can be embedded on other websites. An embedded chart does not use Google Analytics or Cloudflare Web Analytics, and we set no cookies through it. Cloudflare delivers it in the same way as described above. The website showing the chart has its own privacy policy.

4. Where you are changes what we ask

The UK, the European Economic Area (the EU countries plus Iceland, Liechtenstein and Norway), Switzerland, Jersey, Guernsey, the Isle of Man and Gibraltar. Nothing other than what is strictly needed to run the site loads until you choose. The cookie bar has Accept and Reject buttons of equal size. If you do not choose, nothing optional runs.

Everywhere else. Google Analytics and Cloudflare Web Analytics run when you open a page. You can switch them off at any time with "Cookie settings".

Global Privacy Control, wherever you are. If your browser sends this signal, we treat it as a choice to switch off Google Analytics, Cloudflare Web Analytics and any advertising, and we do not load them. You can still switch analytics on yourself in "Cookie settings" if you want to.

We work out your country from your request, through Cloudflare. If we cannot tell where you are, we treat you as being in the UK or Europe and show the cookie bar.

5. Cookies and similar storage

Cloudflare Web Analytics is a similar technology: it uses no cookies and no browser storage, but it does send Cloudflare details of your visit (section 3), so it needs your agreement in the UK and Europe in the same way.

If you choose Reject or switch analytics off later, we stop Google Analytics and Cloudflare Web Analytics and delete Google's cookies from your browser.

6. Our commitment

We do not use the pages you read on this site to build a profile of your political views, and we will not use them to target advertising at you if we carry advertising later.

7. The legal basis (UK and European readers)

Under the UK GDPR, the EU GDPR and the equivalent laws of Switzerland and the Crown Dependencies:

• Google Analytics, Cloudflare Web Analytics and any future advertising: your consent, which you can withdraw at any time. In the UK the law allows cookies used only for statistics without consent, provided you can opt out. We choose to ask first anyway, so that the same rule applies across the UK and Europe. In the EU, the national laws based on the ePrivacy Directive require consent.
• Delivering and protecting the site through Cloudflare, and keeping the record of your cookie choice: our legitimate interest in running a working, secure site and showing we asked properly.
• Replying to your emails: our legitimate interest in answering you.
• A future mailing list: your consent.

8. Who handles your information for us

Each handles your information for us under a data processing agreement. Each may also use some of it for its own purposes set out in its terms, such as security and meeting legal duties.

9. Information sent outside the UK and Europe

Cloudflare and Google may handle information in the United States. Where they do, the transfer relies on the EU-US Data Privacy Framework and its UK Extension, or on the standard contractual clauses approved by the European Commission and the UK addendum to them.

10. Your rights

Everyone. You can ask us what information we hold about you, and ask us to correct or delete it. Email us at [email protected]. We reply within one month. If a request is complex we may need up to two months more, and if so we tell you within the first month.

We do not collect names for ordinary reading, so we usually cannot link analytics data to you by name. "Cookie settings" shows your analytics reference (the identifier Google Analytics gives your browser). If you send it to us, we can ask Google to delete the data linked to it, and we delete it from our own copy too.

UK and European readers also have the right to object to our use of your information, to restrict it, to receive a copy in a portable form, and to withdraw consent at any time without affecting what happened before. You can complain to the Information Commissioner's Office (ico.org.uk) in the UK, or to the data protection authority where you live, such as Integritetsskyddsmyndigheten (IMY) in Sweden. We would like the chance to put things right first, so please contact us.

US readers. Depending on your state, you may have the right to know what we collect, to delete it, to correct it, and to opt out of its sale, its sharing for cross-context behavioural advertising, and targeted advertising. We do not sell your information or share it for advertising. "Cookie settings" and Global Privacy Control both switch off Google Analytics and Cloudflare Web Analytics. Older "Do Not Track" browser settings have no agreed standard, so we do not respond to them; we respond to Global Privacy Control instead. If we turn down a request, reply to our answer and we will look at it again.

11. Children

fredcornell.com is a news and data site for adults. It is not aimed at children and we do not knowingly collect information about anyone under 16.

12. Changes to this policy

When we change this policy we change the date and version at the top. If a change affects what we ask UK and European readers to agree to, we ask again.