Privacy

Who is responsible

Subject Matter Records is run by Janko Bartelink [LEGAL FORM], Twente Area, The Netherlands. I am the controller for everything on this page. Write to [email protected] for any question or request about your data. I answer within a month, usually much sooner.

The bulletins

When you leave your address on the bulletins page, I keep:

• your e-mail address;
• where the sign-up came from: the page, or the short link you followed (for example "ig" for Instagram);
• the date of the text you agreed to, so I can show which words you saw;
• when you signed up, when you confirmed, and when you stopped, if you do;
• which bulletins were sent to your address, and when.

Nothing else: no name, no location, no IP address. You first receive a mail asking you to confirm. Until you do, nothing is sent to you. If you never confirm, the address is deleted after 30 days.

I use the address for one thing: sending you the bulletins, the office's news about the archive, at most a few times a month. I do not sell it, share it or add it to anything else. The basis is your consent (article 6(1)(a) GDPR). Every bulletin ends with a link to stop, which works with one click. After you stop, I keep the address marked as stopped, with the date, for one year, so I can show that you stopped and when. Then it is deleted with everything listed above.

The bulletins are plain text. They contain no tracking pixel and no tracked links, so I cannot see whether you opened one or what you clicked in it.

Who handles it for me

Two companies process the bulletin data on my behalf, under a data processing agreement with each:

• Cloudflare runs the small program that takes sign-ups and keeps the list, in its database service D1. Cloudflare also hosts this site.
• Resend delivers the mail. It sends from its region in Ireland, but keeps its records of each mail (address, subject, delivery status) in the United States.

Both are American companies. Data that reaches the United States is protected under the EU-US Data Privacy Framework, under which both are certified, and the standard contractual clauses in their agreements.

What I count

Links in my posts elsewhere go through short addresses such as office.subjectmatterrecords.com/go/ig. When you follow one, I count the click: which link, the date and time, the page you came from if your browser says so, and whether the visitor looks like a person or a program. No IP address and no cookie.

This site uses Cloudflare Web Analytics to count visits per page. It sets no cookies, stores nothing in your browser, and does not recognise you on a next visit. I see totals only.

I count so I know which channels lead people here. The basis is my legitimate interest (article 6(1)(f) GDPR), and none of these counts can be traced back to you.

Visiting the site

Like any web host, Cloudflare receives your IP address and browser details when it delivers a page, an image or a soundfile, and may keep them briefly in its logs to keep the service running and secure. I do not see or use them. The site itself sets no cookies. Apart from Cloudflare's visit counter it loads no code from anyone else until you ask for it.

Ordering a copy

This site takes no orders and no payments. The request slip sends you to Bandcamp, the sales agent for the archive's sound. What you give there (name, address, payment) is handled by Bandcamp under its ownprivacy policy. Bandcamp tells me what it needs to get your order to you, and I use that only for the order.

The slip can also show Bandcamp's player. It loads only when you click "Load the Bandcamp player", because Bandcamp may then set its own cookies.

Writing to me

Mail to [email protected] is forwarded by Cloudflare to my Google mailbox (Gmail). I keep your letter and my answer as long as the correspondence is useful, and delete them when you ask.

Your rights

You can ask to see what I keep about you, to have it corrected or deleted, to limit its use, to receive it in a file, and to object to the counting. You can withdraw your consent for the bulletins at any time. The link in every bulletin does that at once. Write to [email protected].

If you think I handle your data wrongly, you can complain to the Dutch supervisor, theAutoriteit Persoonsgegevens. I would rather hear it from you first.

Changes

When this page changes, the version date at the top changes with it. If a change affects what happens to your address, I say so in a bulletin first.