Our website address is: http://lethosdesigns.com
- [ 1 ] Core beliefs
PII Data is a liability, it should only be collected and processed when absolutely necessary.
User privacy and data protection are human rights.
We have a duty of care to the people within our data.
We will never sell, rent or otherwise distribute or make public your personal information.
We loathe spam as much as you do!
- [ 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)
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.
- [ 3.0 ] 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 Cloudflare (CF) to track user interaction, also for caching, firewall, anti-DDOS and anti-spam. We also use WordFence (WF) and WP Cerber Security & Antispam (CSA), wordpress plugins, for the same reasons.
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 and to prevent spam.
Although CF, WF and CSA could record data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
Although CF, WF and CSA also records an IP address which could be used to identify you, but often no context. They grant us access to “flagged” IP address’ for the purposes of using them antispam and DDOS measures.
We consider Cloudflare, Wordfence and WP Cerber Security & Antispam to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop CF, WF and CSA from tracking any part of your visit to pages within this website.
In addition to Cloudflare, Wordfence and WP Cerber Security & Antispam, this website may collect information (already held in the public domain) attributed to the IP address of the computer or device that is being used to access it.
- [ 3.2 ] Our blog
When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Should you choose to add a comment to any posts that we have published on our blog, the name and email address you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed.
Your comment and it’s associated personal data will remain on this site until we see fit to either
1.) remove the comment
2.) remove the blog post.
Should you wish to have the comment and it’s associated personal data deleted, please put your email in here (Login Required) using the email address that you commented with or do the same if you don’t have an account on our contact us page.
If you are under 16 years of age you MUST obtain parental consent before posting a comment on our blog.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.
- [ 3.3 ] Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page, 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). Our own SMTP servers 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. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
- [ 3.4 ] Media
If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
- [ 3.5 ] Cookies
If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
- [ 4.0 ] How we store your personal information
As detailed in section 3.2 above, if you submit a comment to a blog post published 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 (WordPress). 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.
- [ 4.1 ] How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
- [ 4.2 ] Where we send your data
Visitor comments may be checked through an automated spam detection service, either or both, Wordfence and WP Cerber Security & Antispam.
- [ 5 ] About this website’s server
This website is hosted by OrangeWebsite (Hosting), based in Iceland.
Known for years strong protections on Privacy, Freedom and Anonymity.
It is the place to keep your data, if you care about it being protected.
We have a hosted with many services, but the legal protections, being in Iceland, matters more than while at the same time, being position about half way between US and EU.
Full details of OrangeWebsite (Hosting)’s data centre can be found here.
- [ 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 2.0. All 4 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 ] Data Controller
The data controller of this website is: Lethos Ltd, a UK Private limited Company
- [ 9 ] Data Protection Officer
Mr. C Bourton
- [ 10.1 ] Change log
23/05/2018 – version 1.2 – Updated sections 3.1, 3.2 and 6, added sections 3.4 and 3.5, also 4.1 and 4.2.