Privacy policy

1. Who is responsible

The controller for the processing described here is:

2. What this website does not collect

It is worth stating the shape of this first, because it is short. This website publishes articles. It does not operate user accounts, it has no login, it runs no contact form, and it does not ask for a name, address, date of birth, National Insurance number, bank details or any financial information at any point.

The only personal data a visitor actively provides is an email address, and only if they choose to subscribe to the newsletter.

3. Server log data

When a page is requested, the hosting server records technical data needed to deliver it and to keep the service secure and stable:

• the IP address of the requesting device,
• the date and time of the request,
• the page or file requested and the HTTP status returned,
• the amount of data transferred,
• the referring page, where the browser sends one,
• the browser type, version and operating system.

Legal basis: Article 6(1)(f) GDPR. Our legitimate interest is the technically secure and reliable operation of the website. Retention: log entries are kept for a short period for security and troubleshooting purposes and are then deleted or anonymised. They are not used to build profiles of individual visitors.

4. Cookies and local storage

This website sets no cookies for its own purposes. One entry is written to your browser's local storage when you answer the cookie notice, so that the notice is not shown again on every page.

Full detail, including any third-party entries, is on the cookie notice page.

5. Measurement of advertising campaigns

This website is funded by advertising, and visitors may arrive from a paid placement on the Outbrain content recommendation network. To measure whether those placements work, article pages, the homepage, section pages and the newsletter page load the Outbrain Amplify measurement pixel (Outbrain Inc. and its affiliated companies, including Outbrain UK Ltd). The pixel loads a script from amplify.outbrain.com and records a page view.

We want to be plain about one point rather than describe an ideal that the page does not match: this pixel loads together with the page, before you answer the cookie notice. In that moment it can process your IP address, the page URL, the referring information and technical browser data, and it may set its own identifiers. Declining in the cookie notice stops further measurement from that point but does not undo the initial request.

The pixel is not loaded on the imprint, privacy, cookie, terms, contact or newsletter confirmation pages, so those pages can be read without it.

Legal basis: Article 6(1)(f) GDPR, our legitimate interest in measuring the effectiveness of advertising we pay for, together with Article 6(1)(a) GDPR consent where you accept in the notice. If you would prefer this not to happen at all, Outbrain publishes its own privacy information and an opt-out at outbrain.com/privacy, and browser-level tracking protection or an ad blocker will also prevent it.

Transfers: Outbrain operates internationally and data may be processed outside the European Economic Area and the United Kingdom, under the safeguards described in its own privacy information.

6. Fonts and other assets

All typefaces, icons, images, stylesheets and scripts used by this website are served from our own domain. No font CDN, no analytics library and no social media widget is loaded, so no request is made to a third-party server merely by opening a page, apart from the measurement pixel described in section 5.

7. The newsletter

If you subscribe to The Sunday Plain English, we process the email address you enter, and the technical data associated with the subscription (time of request, IP address and confirmation time) as evidence that the subscription was genuine.

We use a double opt-in procedure. After you submit the form, a confirmation email is sent to the address given. Nothing further is sent until you click the link in it. If it is not confirmed, the address is deleted after a short period.

We also record, where present, the campaign parameters in the link you arrived through, so that we can tell which placement a subscription came from. These are campaign identifiers, not identity data.

Legal basis: Article 6(1)(a) GDPR, your consent. Withdrawal: every issue contains an unsubscribe link, and you may also withdraw by writing to [email protected]. Withdrawal does not affect the lawfulness of processing before it. Retention: until you unsubscribe, plus the period needed to evidence consent.

We do not sell, rent or pass email addresses to advertisers or to any other third party for their own marketing purposes.

8. Enquiries by email or telephone

If you contact us, the content of your message and your contact details are processed in order to answer it. Legal basis: Article 6(1)(f) GDPR, or Article 6(1)(b) where the enquiry concerns a pre-contractual matter. Correspondence is deleted once it is no longer needed and no retention obligation applies.

9. Processors

We use service providers who process data on our behalf under Article 28 GDPR: a hosting provider for the server infrastructure and log data, and an email service provider for sending the newsletter. Each is bound by a data processing agreement and may process the data only on our instructions.

10. Automated decision-making

We do not carry out automated decision-making or profiling within the meaning of Article 22 GDPR that produces legal effects for you or similarly significantly affects you. Nothing on this website assesses your eligibility for anything.

11. Your rights

You have the right to:

• obtain confirmation of whether we process your data and request a copy of it (Article 15),
• have inaccurate data corrected (Article 16),
• have data erased (Article 17),
• obtain restriction of processing (Article 18),
• receive your data in a portable format (Article 20),
• object to processing based on legitimate interests (Article 21),
• withdraw consent at any time, with effect for the future (Article 7(3)).

Requests can be sent to [email protected]. We answer within one month and will ask for no more information than is needed to identify the data concerned.

12. Complaints to a supervisory authority

You may lodge a complaint with a data protection supervisory authority. For our establishment, that is the Italian authority:

• Garante per la protezione dei dati personali, Piazza Venezia 11, 00187 Roma, Italy — garanteprivacy.it

Visitors in the United Kingdom may instead complain to the Information Commissioner's Office — ico.org.uk.

13. Changes to this policy

We update this policy when the website or the processing changes. The review date at the top shows when the current version was published. Where a change affects consent-based processing, we will ask again rather than rely on an earlier agreement.