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Table of Contents

Privacy Policy

Introduction

Before we get stuck in with this policy, we just wanted to say:

Your data is private and keeping it that way is important to us. So, we promise we never sell your data: never have, never will.

In this policy, consistent with our obligations and your rights under English law, we lay out:

  • What data we collect and why
  • How your data is handled
  • Your rights to your data.

Your acceptance of our privacy policy is required to access our site and is deemed to occur when you first accessed our site. If you do not agree with our privacy policy, you must stop using our site immediately.

Definitions

Let's kick with some key definitions so we're all on the same page:

  • Account means your electronic identity that is required to access and/or use certain areas and features of our site. This applies if you chose to sign up to our site.
  • Personal Data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. Here, it covers the personal data (e.g. your name and your email address) that you give to us via our site.
  • We / Us / Our / Service / Services means Requira Consulting who operates this site.

Scope

Our privacy policy applies only to the use of our site.

Our site may contain links to other websites and we have no control over how your data is collected, stored, or used by other websites. Accordingly, we always advise you to check the privacy policies of any such websites before providing any data to them.

About Us

We are Requira Consulting Limited, trading as Requira.

  • Our registered office is at The Knoll Business Centre, Unit W8A, 325-327 Old Shoreham Road, Hove. BN3 7GS, United Kingdom.
  • We are registered in England and Wales under company number 8128682.
  • We can be contacted here.

Lawful basis for processing personal data

We are a Data Controller of your information.

Our legal basis for collecting and using the personal information described in this Privacy Policy falls under the following lawful bases:

  • Consent: You have given us permission to do so.
    • For example: Signing up to our site gives us consent to use your email to send you our newsletter (until you decide to unsubscribe).
  • Contract: Processing is necessary for a contract we have with you or because you have asked us to take specific steps before entering into a contract.
    • For example: If we decide to offer paid memberships and you decide to accept.
  • Legal Obligation: To comply with a legal obligation we are subject to.
    • For example: If we are subject to a court order to pass personal data to the designated party.
  • Legitimate Interests: Processing is necessary for our legitimate interests to provide the core functionality and services of our site.
    • For example: Using your IP address to reduce spam and malicious comments.

What Data Do We Collect & Why?

As a privacy-first company, our guiding principle is to collect only what we need and to only process this information so that we can provide the core functionality and services of our site.

Browsing our site

When you access our site, your browser automatically shares specific information such as the operating system and browser version you're using.

Whilst we do track the usage of our site, we respect your privacy by specifically doing this without collecting any personal data or personally identifiable information and without cookies.

We use a third-party service, Plausible, to do site measurement absolutely anonymously and all data is in aggregate only.

Cookies

A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more.

  • You can adjust cookie retention settings in your own browser.
  • To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit the UK Information Commissioner's Office.

The following cookies are used on our site in these scenarios.

  • If you're not logged into this site and not logged into comments:
    • No cookies are used.
    • You cannot see or post comments unless you are logged into this site.
  • If you're logged into this site:
    • Necessary cookies are used to identify your log-in and that you're logged in.

Creating an account

If you choose to sign up to our site, you will need to provide us with:

  • Your name.
  • Your email address.

We use these details to:

  • Allow you to log-in and log out.
  • Customise our site and newsletter to make your experience more personalised and engaging.
  • Grant you access to view and post comments (as per our Comment Policy).
  • Send you our newsletter (until you choose to unsubscribe by clicking the link at the bottom of the newsletter).
  • Send you essential information.

We will never sell your personal info to 3rd parties. Nor we will use your personal info in marketing statements without your permission either.

We use a third-party service, Ghost, to host this site and provide core functionality.

Subscribing to our newsletter

If you choose to subscribe to our newsletter, you will need to provide us with:

  • Your email address.

We use these details to:

  • Create your account on Substack which is a third-party service we use as our newsletter platform.
  • Send you issues by email until you opt out.
  • Communicate with you via additional Substack features such as Chat.

Usage by third-parties

Some third-party services will collect and store other information that is not listed here for the functional provision of those services, such as your IP address and what browser you're using.

However, where possible, we have chosen to use third party services which:

  • Are privacy-focused and compliant with GDPR. CCPA and PECR.
  • Keep data within the European Union.

Voluntary correspondence

When you contact or email us directly:

  • We will use your name and email in order to respond back to you and not for any other reason.
  • We will keep that correspondence, including your name and your email address, so that we have a history of past correspondences to reference if you reach out in the future.

We use these third-party services:

Both platforms are compliant with the General Data Protection Regulation.

Web beacons

A web beacon (also known as a tracking pixel) is a technique used on web pages and emails to check if and when a user has accessed the content.

  • On accessing our website, please see the Browsing Our Site section above on how we use a third-party service, Plausible, to do this in a way that respects your privacy.
  • On newsletters that we send out, we have enabled open-rate analytics on Ghost (our third-party service that we use to send out newsletters). This is limited to showing how many people the email was delivered to and the percentage open rate. We only use this information to improve our newsletter for our readers.
  • On emails that we send, we have specifically used ProtonMail (our third-party service that we use for emails) which doesn't permit such capability.

What we do not collect

We do not collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities.

You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when contacting us.

We also do not collect any biometric data.

Children

This website is not targeted at children and we do not knowingly collect any personally identifiable information from children.

  • If you are under the age to provide consent for the sharing of your personal data (e.g. your email for the newsletter) then you must first seek consent from your parent or guardian.
  • If you are a parent who believes your child has provided their personal details and wish to have these details removed then please contact us.

How Your Data Is Handled

Data location & security

Our site and its functionality is provided by a limited number of third-party services - all of which are privacy conscious and are compliant with the General Data Protection Regulation.

Data is hosted as specified below and is secured as described in each of their privacy policies:

Note that each of these third-party services may store your data in other locations for the function of those services. Please check their dedicated privacy policies linked above.

Data retention

We will retain your information as long as your account is active, as necessary to provide you with the services or as otherwise set forth in this policy.

We will also retain and use this information as necessary for the purposes set out in this policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights.

You can choose to:

  • Delete the email on your account on our site by contacting us from the email on your account.
    • Background: If you unsubscribe we will update your account so that "Subscribed To Newsletter" is marked as inactive. However, your email will be retained so we know which email not to email in the future. This option allows you to have your email deleted.
  • Delete your contact form submission by contacting us from the email provided on that submission.
  • Delete your account on our site by contacting us from the email on your account.
  • Delete your comment by going to it and deleting it.

Disclosure

  • We do not (and will not) monetize this website by selling your data. Your activity on the web is yours only.
  • Your personal data will not be disclosed to anyone unrelated to the functional requirements of this website and the services it provides.
  • Your personal data may be disclosed to someone other than the above is if there is an unavoidable legal obligation and request to do so.

Third Party Services

We use third party services to provide the core functionality of this website. However, where possible, we have chosen to use third party services which:

  • Are privacy-focused.
  • Are based in the European Union and host their data within the European Union.
  • Are compliant with GDPR with some additionally compliant with CCPA and PECR.

Here's what we use and why:

Other third-party services may be used on an ad-hoc basis to provide features such as embedded media for blog posts.

Your Rights

Under data protection regulation, you have the following rights:

  • The right to be informed about the collection and use of your personal data.
    • As described in this Privacy Policy.
  • The right to access the personal data we hold about you
    • Please contact us (as below).
  • The right to correct inaccurate personal data.
    • Please contact us (as below).
  • The right to have your personal data deleted.
  • The right to request restriction or suppression of your personal data.
    • Please contact us (as below).
  • The right to make use of your personal data for your own purposes across different services.
    • Please contact us (as below).
  • The right to object to us processing your personal data in some circumstances.
    • For newsletters, you can always unsubscribe via the link at the bottom of the email.
    • Otherwise, please contact us (as below).
  • The rights relating to decisions being made about you without human involvement.
    • Please contact us (as below).

For further information about your rights, please go to the Information Commissioner's Office.

To exercise your rights, please contact us.

To make a complaint, please  contact us first. If you are not satifisfed, you can also complain to the UK's supervisory authority - the Information Commissioner's Office:

Privacy Policy Changes

  • We may alter our Privacy Policy at any time - especially when a material change occurs. This includes changes in law,  in the way personal data is used, in the functionality of the website changes, or if third-party services are added or removed from the website.
  • Any changes will be posted on our site and emailed to account users.
  • You will be deemed to have accepted our Privacy Policy on your first use of our site following the alterations.
  • Unless expressly stated otherwise, the current version of our Privacy Policy is in effect and prevails over previous versions.

Change Log

  • 21 December 2022: Updated as this site has migrated to using Substack for "The Forcing Function" newsletter.
  • 11 November 2022: Updated as this site has migrated from using Hyvor Talk for commenting to Ghost's native commenting functionality.
  • 18 June 2022: Initial version published.
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