Privacy

Who runs this site

Miles Rothoerl, a freelance broadcast journalist based in the UK. I am the controller for the personal data described here. You can reach me at miles@milesrothoerl.com.

Hosting and server logs

The site is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. Each time a page is requested, the web server records technical access data: the file requested, the date and time, the response status, the amount of data transferred, browser and operating system, the referring page, and the IP address of the requesting device.

IONOS states that visitor IP addresses in these logs are anonymised on collection, that log data is held for a maximum of eight weeks, and that it is not passed to third parties or transferred outside the EEA. I hold no separate copy of the logs, and I make no attempt to identify individual visitors from them.

The lawful basis is legitimate interests under Article 6(1)(f) UK GDPR. The interest is keeping the site available, working correctly and secure, and being able to investigate technical faults or misuse. I have assessed this against visitors’ interests and consider the processing necessary and low-impact, given the data is anonymised and short-lived.

My hosting contract is with IONOS in Germany, whose servers – and, therefore, the data outlined above – sit in the EEA. Transfers from the UK to EEA countries are covered by UK adequacy regulations. IONOS acts as my processor and only handles this data on my instructions; a data processing agreement under Article 28 UK GDPR is in place. IONOS’s privacy information is at ionos.de/terms-gtc/datenschutzerklaerung.

Visitor statistics

I can see how many times each page has been viewed, and when. This comes from IONOS SiteAnalytics, which is part of the hosting product rather than a separate analytics service. It works from the server log or a counting pixel, sets no cookies, and does not follow you between sites.

IONOS states that the visitor’s IP address is anonymised immediately on transmission and processed without personal reference, that no data is passed to third parties, and that nothing here allows conclusions to be drawn about individual visitors. I see aggregates of the following: page view counts, visit duration, referring site, approximate location and browser and operating system data. It is held for eight weeks.

The lawful basis is legitimate interests under Article 6(1)(f) UK GDPR: understanding in general terms which work on this site people are reading.

Typefaces

The typefaces are served by Adobe Fonts. When a page loads, your browser requests the font files from Adobe’s servers. Adobe states that this request gives it, among other things, the fonts served, the identifier of the font project, the hostname of the page loading them, and your IP address – which it says it receives in order to deliver the font but does not store. Adobe states that it does not set cookies to serve fonts on websites.

The lawful basis is legitimate interests under Article 6(1)(f): presenting the site as designed. If you would rather this did not happen, blocking use.typekit.net in your browser substitutes a default typeface and leaves the site fully readable.

This involves a transfer to the United States. Adobe Inc. is certified under the UK Extension to the EU–US Data Privacy Framework, which the UK recognised as providing an adequate level of protection in the Data Protection (Adequacy) (United States of America) Regulations 2023. Adobe's font-specific notice is at adobe.com/privacy/policies/typekit.html, its general policy at adobe.com/privacy/policy.html, and its transfer position at adobe.com/privacy/eudatatransfers.

Video

The video player on these pages is provided by Wistia, Inc., 120 Brookline Street, Cambridge, Massachusetts, USA. It loads with the page rather than on a click, so it loads whether or not you play anything. That request gives Wistia your IP address, the page you are on, which videos are on it, and browser and operating system data. Wistia's player in turn loads an error-monitoring library from Sentry, operated by Functional Software, Inc. of San Francisco, which receives your IP address in the course of that request. Sentry is engaged by Wistia rather than by me.

My account is set to Wistia's Privacy Mode, which anonymises the IP address on collection and disables the session tracking that would otherwise recognise you as a returning viewer. What I see is how many times each video has been played and how much of it people watch.

Pressing play stores your position in that video in your browser, so it can resume where you left off. Nothing is stored before you press play, and you can clear it through your browser's site-data settings at any time.

The lawful basis for loading the player is legitimate interests under Article 6(1)(f): showing broadcast work in the form it was made in. The lawful basis for storing your playback position is your consent, given by pressing play after the notice shown next to it.

Both companies are certified under the UK Extension to the EU–US Data Privacy Framework. Wistia's privacy policy is at wistia.com/privacy and Sentry's at sentry.io/privacy.

If you email me

My mailbox is provided by IONOS, under the same German hosting contract, and is read by me. I do not add correspondents to any mailing list, and I do not pass correspondence to anyone else except where I am legally required to.

The lawful basis is legitimate interests under Article 6(1)(f): dealing properly with correspondence sent to me. I keep messages for as long as is reasonably necessary to handle the enquiry and to keep a sensible record of professional contact – in practice, up to three years from the last exchange – after which they are deleted, unless a specific matter, legal obligation or potential legal claim requires me to keep them longer.

Who else is involved

Three organisations receive personal data in connection with this site: IONOS, which provides the hosting, the visitor statistics and my mailbox; Adobe, which serves the typefaces; and Wistia, which provides the hosting for embedded videos. There is no advertising network, third-party analytics platform, tag manager or content delivery network on these pages.

Links off this site

Portfolio items link out to platforms including Wistia and LinkedIn, and to news publishers’ own websites. Nothing is embedded here, so those platforms receive nothing until you choose to follow a link. Once you do, their own notices apply and this one does not.

Your rights

Depending on the circumstances and the lawful basis involved, you may have the right to request access to personal data I hold about you, to have it corrected or erased, to restrict how it is processed, to object to processing, and to receive it in a portable form. Because the processing here rests on legitimate interests, the right to object is the one most likely to be relevant. In practice I hold very little: anonymised server and statistics data held by IONOS, and any email you have sent me.

Make a request, or complain about how I have handled your data, by emailing miles@milesrothoerl.com. I will acknowledge it, look into it and tell you the outcome without undue delay – and in any case within no more than one month. If you are not satisfied, you can complain to the Information Commissioner’s Office at ico.org.uk. You do not have to come to me first.