1. Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information
2. Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
- US CAN-SPAM Act 2009 (CAN-SPAN Act)
- US Children's Online Privacy Protection Act 1998 (COPPA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
3. Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Our blog
You can use the comment function to comment on articles on our blog. The comment function is an external service that we have integrated into our website, and is provided by Disqus, Inc., 301 Howard St., Suite 300, San Francisco, CA 94105 (hereinafter referred to as “DISQUS”). You can use the comment function either as a guest or as a registered user. If you wish to comment on articles on our website as a guest, you must first provide a name under which you wish to comment and a valid email address. This information will be transmitted to DISQUS and saved on their servers. You can also log in and comment using your access data from a pre-existing DISQUS user account or your Facebook, Google+ or Twitter account.
If you log in using your DISQUS access data, a connection will be made with the DISQUS server and DISQUS will be informed that you are visiting our website and using the comment function. This information will be associated with your DISQUS account. We have no influence on the scope of further data that is provided to DISQUS using the comment function and saved there. DISQUS is solely responsible for this data processing.
When using the comment function via your Facebook, Google+ or Twitter account, DISQUS connects to the relevant social network’s server via our website and informs it that you are visiting our website and using the DISQUS comment function. This information will be associated with your Facebook, Google+ or Twitter account. When registering for DISQUS, Facebook Google+ or Twitter will send your user ID to DISQUS if the login information provided and sent by our website (normally an email address) corresponds to the information saved on Facebook, Google+ or Twitter. At the same time, by logging in using Facebook, Google+ or Twitter you are authorizing DISQUS to use your data and also the functions of Facebook, Google+ or Twitter. You can find more information about this by logging in using your Facebook, Google+ or Twitter account. We have no influence on the volume of further data that is provided to Facebook, Google+ or Twitter using the comment function and saved there. Facebook, Google+ or Twitter is solely responsible for this data processing.
For further information regarding the purpose and scope of data collection, and regarding the further processing and use of your data by DISQUS, Facebook, Google+ or Twitter, see the privacy rules of the relevant service (see section 6.0).
3.3 Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). The SMTP servers used are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic newsletter-style emails from us.
4. How we store your personal information
As detailed in section 3.2 above, if you login / register on this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (Django-CMS). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
5. About this website's server
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6. Our third party data processors
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2. All of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7. Data breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.1 Change log
8.2 Contacting us
EPFL Innovation Park Building F
+41 21 353 99 65