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source_hash: e083f9d16b60d02db26df97b3103c4b3bde8784ef67ad0c7f698a90b09ccd2a2
post: /posts/privacy
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# Context Pack: Site Privacy Policy

Reference for version 2.3, effective 5 August 2026. This pack summarises the existing policy; it is not independent verification of the site's operations, processor certifications or assessments. Use the policy's actual clauses when answering a rights or retention question.

Canonical page: https://aris-space.com/documents/privacy (also /privacy).
Controller: Ari Leavesley, trading as Pushing Squares, a UK sole trader with no registered company.
Privacy contact: ari@pushingsquares.com.
Scope: pushingsquares.com and aris-space.com, including qualms, SFL downloads, cookies and other site interactions. Night-Owl has separate policies under /documents/legal/.

## Verbatim excerpts

> Their data will be deleted on request, regardless of the normal retention schedule.

> Submissions are not used to train AI models. Data is not sold or used for advertising.

> The site does not carry out solely automated decision-making, including profiling, that produces legal or similarly significant effects.

## Collection and boundaries

Qualm data includes email, title, body, uploaded files and any personal data inside them. SFL signup records contain email, consent flag, source page and timestamp. Technical records use a salted IP hash, not raw IP, plus user-agent; consent records include a timestamp and aris_consent value.

Third-party personal data in uploads makes Ari a controller for that data too. Submitters should redact irrelevant identifying details; identifiable people may contact Ari and have their data deleted regardless of normal retention. Unsolicited Article 9 special category data is deleted on sight and not used editorially.

The collection table says anonymous analytics have no autocapture. Later analytics clauses specify no autocapture of form fields, no IP retention or cross-site advertising identifiers, and masked replay inputs. Preserve those stated scopes; do not infer wider technical behaviour from this pack.

## Eleven purposes and retention

1. Receive/read qualms: consent, Art. 6(1)(a). Email/title/body stay 12 months from last contact. Uploads stay until 30 days after a related post or 12 months from submission, whichever is sooner.
2. Follow-up questions and related-post notifications by email: consent; same retention as row 1.
3. Anonymised editorial use: legitimate interests, Art. 6(1)(f), for as long as editorial output needs it; no republication after the source qualm is deleted.
4. Identifying publication: separate, explicit written consent; retained for the published post's lifetime.
5. Abuse detection/investigation: legitimate interests; salted IP hash and user-agent retained 90 days.
6. Turnstile anti-abuse: legitimate interests; Cloudflare processes tokens/signals under its DPA; Ari does not retain them.
7. Cloudflare Access: legitimate interests; admin identity, not visitor data, for the duration of admin access.
8. Vercel hosting: legitimate interests; web-request metadata under processor retention.
9. Anonymous analytics/session replay: consent, only after Accept; Decline keeps PostHog off. Deletion on request within 30 days.
10. Demonstrating consent: legal obligation, Art. 6(1)(c); cookie/local preference for as long as the related qualm or choice exists.
11. SFL downloads and occasional SFL/related-tool product emails: checkbox consent; until removal is requested, then deletion within 30 days.

Consent withdrawal is available at any time by email, processed within 30 days, without changing the lawfulness of earlier processing. Earlier deletion where consent is the basis is actioned within 30 days.

## Stated assessments, processors and transfers

No DPO is appointed: the policy says its processing does not reach Article 37(1) thresholds. Editorial necessity treats real submissions as the only authentic source of the problems; synthetic/aggregated material would not serve that purpose. Names, emails, file contents and identifying screenshots are not published without separate explicit written consent. Spam prevention uses the stated minimum effective signal, a 90-day salted hash without cross-site identifiers. The policy also gives necessity/balancing assessments for Turnstile, Access and hosting.

The four listed processors are Vercel (hosting), Neon (submission-text Postgres, US-East), Cloudflare (R2, Turnstile, Access and EU-region D1 SFL signups) and PostHog (consented analytics). The policy states written Art. 28 DPAs. No sharing beyond processors unless required by law or allowed by explicit prior written permission.

All four are described as US-based and DPF-certified, with the UK Extension to the EU-US Data Privacy Framework as the transfer mechanism; Vercel has SCC fallback, Cloudflare/PostHog also list SCCs. The policy says a transfer impact assessment has been conducted and safeguards are available on request. These are policy assertions, not fresh findings in this rewrite. Follow the policy's linked processor references for its sources.

## Rights, cookies and changes

Subject to UK GDPR conditions: access, correction, erasure, restriction, portability, objection, the right not to be subject to a solely automated decision, consent withdrawal and supervisory-authority complaint. Email the privacy contact; responses are provided within 30 days. The Article 22 statement concerns solely automated decisions producing legal or similarly significant effects; do not broaden it to a claim that no automation exists.

aris_consent stores accepted/declined for one year, with a matching local preference. The policy treats it as necessary under PECR Reg. 6(4). Clerk and Stripe set necessary session/security cookies only when sign-in/checkout is used; the processor table separately lists the four providers above. Do not invent a resolution of that difference. Accept loads optional PostHog analytics and replay; Decline keeps them off. Clear site cookies/data and reload to change the choice.

Material changes are announced in a page banner for 30 days. The August activation notice is explicitly historical: it was scheduled to remain until 4 September 2026. The rewrite does not create a new policy version or restart that window. Questions/complaints go to ari@pushingsquares.com; the lead authority is the ICO, https://ico.org.uk.
