Privacy Policy

Ari Leavesley ("Pushing Squares") Version 2.2 — Effective 30 July 2026 https://pushingsquares.com

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Policy update, 30 July 2026. Version 2.2 adds the SFL download email list (Section 4, row 11), its storage in Cloudflare D1 (Section 5), and aris-space.com to the scope of this policy (Section 2). This notice stays on this page until 29 August 2026.

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1. Data Controller (Art. 4(7), Art. 13(1)(a))

The controller responsible for the processing of your personal data is:

Ari Leavesley, trading as Pushing Squares United Kingdom (sole trader; no registered company) Privacy contact: ari@pushingsquares.com

Data Protection Officer (Art. 37): None appointed. The scale and nature of processing on this site does not meet the Art. 37(1) thresholds for mandatory DPO designation.

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2. Scope

This policy describes how Ari Leavesley processes personal data when you submit a qualm via this site, accept the cookie banner, or otherwise interact with pushingsquares.com or aris-space.com. It applies to all data subjects whose personal data is processed in connection with the site.

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3. Personal Data Collected (Art. 13(1)(c), Art. 14)

Categories of data subjects

• Qualm submitters
• Website visitors
• SFL download subscribers

Categories of personal data

Category	Specific items
Contact data	Email address you enter on the qualm form
SFL signup data	Email address, consent flag, source page, timestamp of signup
Submission content	Title and body text you write
Uploaded files	Any files or images you attach, and the contents of those files
Third-party data inside uploads	Names, faces, addresses, or messages of other people that appear in your screenshots, recordings, or documents (see warning below)
Technical data	Salted hash of your IP address (not the raw IP), user-agent string
Consent records	Timestamp of consent given, value of the aris_consent cookie
Analytics (with consent only)	Anonymous PostHog events and page views. No autocapture, no IP retention, no cross-site identifiers.

Sources (Art. 14(2)(f))

• Directly from you, via the qualm submission form, the SFL download form, and the cookie banner
• From your browser, in the case of technical data and analytics events

Third-party personal data in uploads. If a file you upload contains other people's personal data, Ari becomes a controller for that data too. Please redact names, faces, addresses, and messages that aren't relevant before uploading. If someone identifiable in an upload contacts Ari directly, their data will be deleted on request regardless of the underlying retention schedule.

Special category data. Please do not upload special category data within the meaning of Art. 9 UK GDPR (health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, sex life or sexual orientation). If special category data is received unsolicited, it will be deleted on sight and not used for any editorial purpose.

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4. Purposes and Legal Bases (Art. 6, Art. 13(1)(c)–(d))

#	Purpose	Data categories	Legal basis	Retention
1	Receive and read your qualm submission	Email, title, body, uploaded files	Consent (Art. 6(1)(a))	Email, title, body: 12 months from last contact, then deleted. Uploaded files: 30 days after a related post is published, or 12 months from submission, whichever sooner.
2	Email follow-up (clarifying questions; notify you when a related post goes live)	Email, title, body	Consent (Art. 6(1)(a))	Same as row 1
3	Use qualm content (anonymised / no identifying details) as raw material for public posts	Title, body, uploaded files	Legitimate interests (Art. 6(1)(f)) — see LIA below	As long as needed for the editorial output; not republished after deletion of the source qualm
4	Publish a post that names or identifies you	Email, name, any identifying details you agree to	Consent (Art. 6(1)(a)) — separate, explicit, in writing	For the lifetime of the published post
5	Detect and block abusive or automated submissions; investigate misuse	Salted IP hash, user-agent string	Legitimate interests (Art. 6(1)(f)) — see LIA below	90 days, then deleted
6	Bot challenge to prevent automated form abuse (Cloudflare Turnstile)	Turnstile token; signals processed by Cloudflare	Legitimate interests (Art. 6(1)(f))	Processed by Cloudflare per its DPA; not retained by Ari
7	Admin access control (Cloudflare Access)	Admin identity credentials (not visitor data)	Legitimate interests (Art. 6(1)(f))	For the duration of admin access
8	Operate the site (hosting, edge delivery via Vercel)	Standard web request metadata	Legitimate interests (Art. 6(1)(f))	Per Vercel's processor retention
9	Anonymous analytics (reserved)	Anonymous events, page views	Consent (Art. 6(1)(a)) — only after Accept on cookie banner	Not active on this site today. No analytics SDK is loaded. If analytics is introduced later, it loads only after Accept; deletion on request within 30 days.
10	Demonstrate consent under Art. 7(1)	aris_consent cookie value (and a matching local preference)	Legal obligation (Art. 6(1)(c))	As long as the related qualm or cookie choice exists
11	Deliver the SFL download and send occasional product emails about SFL and related tools	SFL signup data	Consent (Art. 6(1)(a)); given by checkbox at the point of download	Until you ask to be removed, then deleted within 30 days

Withdrawal of consent (Art. 7(3)): You can withdraw consent at any time by emailing ari@pushingsquares.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Withdrawal is processed within 30 days.

Legitimate interests assessments (Art. 6(1)(f))

Row 3 — Editorial use of qualm content for public posts.

• Interest: Running a useful public knowledge resource that helps others solve the same problems.
• Necessity: Real submissions are the only authentic source of the problems written about; synthetic or aggregated data would not serve the editorial purpose.
• Balancing: No name, email, file contents, or identifying screenshots are published without separate explicit written consent (row 4). Submitter expectations are managed by prominent consent language at point of collection. Minimal risk of harm given that nothing personally identifying ever leaves the editorial filter without a second consent event.

Row 5 — Spam and abuse prevention.

• Interest: Maintaining the integrity of a public submission form.
• Necessity: Some signal is required to detect repeat abuse; pseudonymised IP (salted hash) is the minimum effective.
• Balancing: IP is hashed, never stored raw. Retained 90 days only. No cross-site identifiers. Low impact on the data subject.

Rows 6–8 — Bot challenge, admin gating, hosting.

• Interest: Operating a secure, available site.
• Necessity: Each service performs a function that cannot reasonably be performed without it (bot challenge, admin authentication, hosting).
• Balancing: Each processor operates under an Art. 28 DPA. Data passing through is the minimum needed to perform the function. Low impact on the data subject.

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5. Recipients of Personal Data (Art. 13(1)(e), Art. 28)

Personal data is processed on Ari's behalf by the following processors, each under a written data processing agreement that meets the requirements of Art. 28 UK GDPR.

Recipient	Role	Purpose	Country
Vercel Inc.	Processor (Art. 28)	Hosting and edge delivery; receives the qualm form submission and serves the site	United States
Neon Inc.	Processor (Art. 28)	Postgres database; stores submission text	United States (US-East)
Cloudflare, Inc.	Processor (Art. 28)	Object storage (R2) for uploaded files; bot challenge (Turnstile); admin access gating (Access); D1 database storing the SFL signup list (EU region)	United States / North America
PostHog Inc.	Processor (Art. 28)	Anonymous analytics; loads only after cookie consent	United States

Personal data is not shared with anyone outside these processors except where required by law or with your explicit prior written permission.

What is not done with your data:

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

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6. International Data Transfers (Chapter V, Art. 44–49)

All four processors above are based in the United States. Transfers from the UK rely on the UK Extension to the EU-U.S. Data Privacy Framework (the "UK-US Data Bridge") for processors that are certified, supplemented by Standard Contractual Clauses where appropriate.

Recipient	Country	Mechanism	Verified at
Vercel	United States	UK Extension to the EU-US Data Privacy Framework (DPF-certified) + SCCs as fallback	Vercel DPF compliance
Neon	United States	UK Extension to the EU-US Data Privacy Framework (DPF-certified)	Neon DPA & GDPR statement
Cloudflare	United States	UK Extension to the EU-US Data Privacy Framework (DPF-certified) + SCCs	Cloudflare and GDPR compliance
PostHog	United States	UK Extension to the EU-US Data Privacy Framework (DPF-certified) + SCCs	PostHog DPA

A transfer impact assessment has been conducted with reference to each processor's published security and disclosure posture. You may request a copy of the safeguards relied on by contacting the address in Section 1.

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7. Retention (Art. 5(1)(e), Art. 13(2)(a))

Personal data is retained only for as long as necessary for the purposes described in Section 4. Specific periods are listed in the table in Section 4. Where a basis is consent, you can request earlier deletion at any time and it will be actioned within 30 days.

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8. Your Rights (Art. 12–22, Art. 77)

Subject to the conditions in UK GDPR, you have the following rights:

• Right of access (Art. 15)
• Right to rectification (Art. 16)
• Right to erasure / "right to be forgotten" (Art. 17)
• Right to restriction of processing (Art. 18)
• Right to data portability (Art. 20)
• Right to object (Art. 21)
• Right not to be subject to a solely automated decision (Art. 22)
• Right to withdraw consent at any time (Art. 7(3))
• Right to lodge a complaint with a supervisory authority (Art. 77)

To exercise any of these, email ari@pushingsquares.com. Responses are provided within 30 days.

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9. Automated Decision-Making and Profiling (Art. 22)

No solely automated decision-making, including profiling, that produces legal effects or similarly significant effects is carried out.

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10. Cookies and Similar Technologies

Consent record. The cookie banner sets aris_consent (accepted or declined) for one year, plus a matching browser preference so the banner stays dismissed. That cookie is strictly necessary to operate the consent mechanism and is set under PECR Reg. 6(4).

Necessary service cookies. Sign-in (Clerk) and checkout (Stripe) set their own session/security cookies only when you use those features. They are not advertising trackers.

Analytics. No analytics or advertising cookies are loaded on this site today. If optional analytics is introduced later, it will load only after you choose Accept on the cookie banner, without autocapture of form fields, without IP retention, and without cross-site advertising identifiers.

You can change your choice at any time by clearing site cookies (and site data) in your browser and reloading the page.

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11. Changes to This Policy

The version and effective date at the top reflect the latest revision. Material changes will be communicated via a banner at the top of this page for 30 days.

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12. Contact and Complaints (Art. 77)

Questions or complaints about this policy: ari@pushingsquares.com.

You also have the right to lodge a complaint with a supervisory authority. The lead supervisory authority for this site is the Information Commissioner's Office (ICO), ico.org.uk.

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End of policy — version 2.2, effective 30 July 2026.