GDPR Compliance Notice

Borrowed and modified from Charlie Stross.

Here’s what you need to know about this website and GDPR:

This may look like a personal blog, and as such you might think it’s exempt from GDPR (Article 2 states that the regulation doesn’t apply to the processing of personal data “by a natural person in the course of a purely personal or household activity”). However, this blog may be considered an adjunct to my business (information technology consulting) and may be used for marketing purposes from time to time. Prudence dictates that I should comply with the requirements of the GDPR—not to mention ethics: GDPR is about protecting individuals’ privacy, and I’m all in favour of that.

I do business on such a small scale that, essentially, I’m responsible for everything on this website. (I sometimes pay other folks consultancy fees to do design or technical maintenance tasks I’m not competent to do myself.) Thus, all the corporate roles and responsibilities outlined in GDPR (such as the Data Protection Officer) devolve to me.

This website retains blog entries and blog comments and webmentions. By posting an entry on this blog, or by commenting on an entry, you are implicitly agreeing to let me republish your material around the world. (This is mentioned in the moderation policy which you were advised to read before commenting, and I make it clear to the invited guest bloggers in their intro email.)

This website runs on top of a software stack using Linux, WordPress, MySQL, JetPack the Apache web server. Yes, Apache saves log files. These are only digested for statistical analysis of overall traffic. Stuff it knows about you includes the IP address your browser request came from, the page requested, the referrer page (if any), and your browser identification string (if any). If this worries you, you’re welcome to use a VPN and obfuscate or anonymize any or all of these things: you won’t be blocked (although it may make posting comments problematic if you block cookies and/or javascript).

This website does not attempt to track you, does not knowingly feed your personally identifiable information to any other business or advertising affiliate or network—I don’t even use Google Analytics—and I don’t intend to start collecting or processing personally identifiable information.

This website may leak information about your session to third parties if you allow it to load content from Amazon.com or Automattic’s JetPack (hint: the merchandise links), and if you view it with image loading enabled (I sometimes post image links that direct to websites I don’t control).

If you want to exercise your right to be forgotten or have personal information removed from this site, Contact me via DM on Twitter (@khurtwilliams). Note that I am not a corporation with a dedicated IT support staff, I have a full-time day job, a family, and I spend a few weeks each year travelling, frequently without a laptop. In other words, I have a life. If you don’t get a reply within a week, email me again—I probably didn’t get your request or I was swamped by other stuff.

Once I receive a GDPR request I will comply with it promptly, but bear in mind I’m a human being with a day job, and this blog is a peripheral pursuit. If your requests become an irritant (e.g. if you request multiple fiddly comment deletions or edits across multiple threads) I may just erase all your content and ban you from the blog in future. (GDPR gives you a right to be forgotten; it does not impose an obligation to be remembered.)

Information collected by Automattic’s JetPack

This website may leak information about your session to third parties if you allow it to load content from Amazon.com or Automattic’s JetPack (hint: the merchandise links), and if you view it with image loading enabled (I sometimes post image links that direct to websites I don’t control).

Activity Log

This feature only records activities of a site’s registered users, and the retention duration of activity data will depend on the site’s plan and activity type.

Data Used: To deliver this functionality and record activities around site management, the following information is captured: user email address, user role, user login, user display name, WordPress.com and local user IDs, the activity to be recorded, the WordPress.com-connected site ID of the site on which the activity takes place, the site’s Jetpack version, and the timestamp of the activity. Some activities may also include the actor’s IP address (login attempts, for example) and user agent.

Activity Tracked: Login attempts/actions, post and page update and publish actions, comment/pingback submission and management actions, plugin and theme management actions, widget updates, user management actions, and the modification of other various site settings and options. Retention duration of activity data depends on the site’s plan and activity type. See the complete list of currently-recorded activities (along with retention information).

Data Synced (?): Successful and failed login attempts, which will include the actor’s IP address and user agent.


Comment Likes

This feature is only accessible to users logged in to WordPress.com.

Data Used: In order to process a comment like, the following information is used: WordPress.com user ID/username (you must be logged in to use this feature), the local site-specific user ID (if the user is signed in to the site on which the like occurred), and a true/false data point that tells us if the user liked a specific comment. If you perform a like action from one of our mobile apps, some additional information is used to track the activity: IP address, user agent, timestamp of event, blog ID, browser language, country code, and device info.

Activity Tracked: Comment likes.


Contact Form

Data Used: If Akismet is enabled on the site, the contact form submission data — IP address, user agent, name, email address, website, and message — is submitted to the Akismet service (also owned by Automattic) for the sole purpose of spam checking. The actual submission data is stored in the database of the site on which it was submitted and is emailed directly to the owner of the form (i.e. the site author who published the page on which the contact form resides). This email will include the submitter’s IP address, timestamp, name, email address, website, and message.

Data Synced (?): Post and post meta data associated with a user’s contact form submission. If Akismet is enabled on the site, the IP address and user agent originally submitted with the comment are synced, as well, as they are stored in post meta.


Gravatar Hovercards

Data Used: This feature will send a hash of the user’s email address (if logged in to the site or WordPress.com — or if they submitted a comment on the site using their email address that is attached to an active Gravatar profile) to the Gravatar service (also owned by Automattic) in order to retrieve their profile image.


Jetpack Comments

Data Used: Commenter’s name, email address, and site URL (if provided via the comment form), timestamp, and IP address. Additionally, a jetpack.wordpress.com IFrame receives the following data: WordPress.com blog ID attached to the site, ID of the post on which the comment is being submitted, commenter’s local user ID (if available), commenter’s local username (if available), commenter’s site URL (if available), MD5 hash of the commenter’s email address (if available), and the comment content. If Akismet (also owned by Automattic) is enabled on the site, the following information is sent to the service for the sole purpose of spam checking: commenter’s name, email address, site URL, IP address, and user agent.

Activity Tracked: The comment author’s name, email address, and site URL (if provided during the comment submission) are stored in cookies. Learn more about these cookies.

Data Synced (?): All data and metadata (see above) associated with comments. This includes the status of the comment and, if Akismet is enabled on the site, whether or not it was classified as spam by Akismet.


Likes

This feature is only accessible to users logged in to WordPress.com.

Data Used: In order to process a post like action, the following information is used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID (on which the post was liked), post ID (of the post that was liked), user agent, timestamp of event, browser language, country code.

Activity Tracked: Post likes.


Notifications

This feature is only accessible to registered users of the site who are logged in to WordPress.com.

Data Used: IP address, WordPress.com user ID, WordPress.com username, WordPress.com-connected site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Some visitor-related information or activity may be sent to the site owner via this feature. This may include: email address, WordPress.com username, site URL, email address, comment content, follow actions, etc.

Activity Tracked: Sending notifications (i.e. when we send a notification to a particular user), opening notifications (i.e. when a user opens a notification that they receive), performing an action from within the notification panel (e.g. liking a comment or marking a comment as spam), and clicking on any link from within the notification panel/interface.


Protect

Data Used: In order to check login activity and potentially block fraudulent attempts, the following information is used: attempting user’s IP address, attempting user’s email address/username (i.e. according to the value they were attempting to use during the login process), and all IP-related HTTP headers attached to the attempting user.

Activity Tracked: Failed login attempts (these include IP address and user agent). We also set a cookie (jpp_math_pass) for 1 day to remember if/when a user has successfully completed a math captcha to prove that they’re a real human. Learn more about this cookie.

Data Synced (?): Failed login attempts, which contain the user’s IP address, attempted username or email address, and user agent information.


Search

This feature is only available to sites on the Professional plan.

Data Used: Any of the visitor-chosen search filters and query data in order to process a search request on the WordPress.com servers.


Sharing

Data Used: When sharing content via email (this option is only available if Akismet is active on the site), the following information is used: sharing party’s name and email address (if the user is logged in, this information will be pulled directly from their account), IP address (for spam checking), user agent (for spam checking), and email body/content. This content will be sent to Akismet (also owned by Automattic) so that a spam check can be performed. Additionally, if reCAPTCHA (by Google) is enabled by the site owner, the sharing party’s IP address will be shared with that service. You can find Google’s privacy policy here.


WordPress.com Stats

Data Used: IP address, WordPress.com user ID (if logged in), WordPress.com username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code. Important: The site owner does not have access to any of this information via this feature. For example, a site owner can see that a specific post has 285 views, but he/she cannot see which specific users/accounts viewed that post. Stats logs — containing visitor IP addresses and WordPress.com usernames (if available) — are retained by Automattic for 28 days and are used for the sole purpose of powering this feature.

Activity Tracked: Post and page views, video plays (if videos are hosted by WordPress.com), outbound link clicks, referring URLs and search engine terms, and country. When this module is enabled, Jetpack also tracks performance on each page load that includes the Javascript file used for tracking stats. This is exclusively for aggregate performance tracking across Jetpack sites in order to make sure that our plugin and code is not causing performance issues. This includes the tracking of page load times and resource loading duration (image files, Javascript files, CSS files, etc.). The site owner has the ability to force this feature to honor DNT settings of visitors. By default, DNT is currently not honored.