Who is responsible
The controller of your personal data is Calyer Consulting LLC, a Delaware limited liability company operating from New York and Lisbon. For anything related to your data, email ben@calyerconsulting.com. I read and answer these messages myself.
The short version
- No contact forms, accounts, analytics scripts, advertising, or tracking cookies.
- My hosting provider processes basic technical data, such as your IP address, to deliver and protect the site.
- If you email me, I keep your message so I can reply and do business with you.
- I never sell your data or add you to a mailing list.
When you visit this site
The site is hosted on Cloudflare. Like any web server, Cloudflare receives technical information with each request: your IP address, browser and device type, the page requested, the referring page, and the time of the request.
This is used to deliver the site, defend it against attacks and abusive bots, and produce aggregate traffic statistics. I can see those statistics and security events in Cloudflare’s dashboard, which can include IP addresses. I don’t combine this with other data or use it to identify visitors.
Legal basis: legitimate interests in running a secure, working website (GDPR Article 6(1)(f)). Cloudflare keeps this data for limited periods under its own retention policies.
Cookies
This site sets no analytics, advertising, or tracking cookies, and runs no third-party scripts.
As part of its bot protection, Cloudflare may set short-lived security cookies, such as __cf_bm, or cf_clearance after a security check. They exist only to tell people apart from automated traffic, are strictly necessary for security, and don’t require consent. You can block or delete them in your browser; the site may then ask you to pass a security check.
When you email me
If you write to me, I receive your name, email address, and whatever you include in the message. I use it to reply, discuss a possible engagement, and keep normal business records.
Email is hosted by Zoho, with mailboxes stored in Zoho’s EU data center.
Legal basis: taking steps at your request before entering into a contract (Article 6(1)(b)), and legitimate interests in responding to inquiries and running the business (Article 6(1)(f)).
Retention: inquiries that don’t lead to an engagement are deleted when no longer needed, generally within two years. Correspondence that becomes part of a client engagement is kept for as long as the engagement and applicable record-keeping obligations require.
Who processes data for me
- Cloudflare
- Website hosting, content delivery, DNS, and security.
- Zoho
- Business email, hosted in the EU.
Both act on my behalf under data processing terms. Neither may use the data for its own marketing.
International transfers
Cloudflare operates a global network and is based in the United States, so website request data may be processed outside the EU. Cloudflare participates in the EU–US Data Privacy Framework and also offers the European Commission’s Standard Contractual Clauses. If you email me while I’m in the US, I may read your message there.
Your rights
Under the GDPR you can ask me to:
- tell you what personal data I hold about you and give you a copy
- correct data that’s wrong
- delete your data
- restrict or object to how I use it
- send it to you or another organization in a portable format
Email ben@calyerconsulting.com and I’ll respond within one month. I may ask you to confirm your identity first.
You can also complain to a data protection authority. In Portugal that’s the Comissão Nacional de Proteção de Dados (CNPD), or you can contact the authority where you live or work. I’d appreciate the chance to sort it out with you first.
Other things worth knowing
- I don’t use automated decision-making or profiling.
- Links to other sites, such as LinkedIn, are covered by those sites’ own privacy policies.
- This site isn’t directed at children.
- To report a security vulnerability, see security.txt.
If this notice changes, I’ll update the date at the top of the page.