Privacy Policy · Learn Spanish at Dusty Lighthouse

1.1In this Privacy Policy, unless the context otherwise requires, the following expressions bear the following meanings: “Service” means the website published at dustylighthouse.com together with all pages, features, content and functionality made available through it; “we”, “us” and “our” mean the operator of the Service; and “you” means the natural person accessing or using the Service.

1.2“Personal Data” means any information relating to an identified or identifiable natural person; “Processing” means any operation or set of operations performed upon Personal Data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure and destruction.

1.3“Controller” means the person which, alone or jointly with others, determines the purposes and means of Processing; “Processor” means a person which Processes Personal Data on behalf of the Controller; and “Sub-processor” means a Processor engaged by us in connection with the operation of the Service.

1.4“Companion” means the artificial-intelligence conversational character made available through the Service; “Companion Memory” means the profile described in the section governing browser storage below; and “Security Records” means the rate-limiting and blocking records described in the section governing Personal Data collected automatically.

1.5References to “GDPR” are to Regulation (EU) 2016/679 and, in relation to the United Kingdom, to the retained EU law version of that Regulation as supplemented by the Data Protection Act 2018. References to the “CCPA” are to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020. References to “PECR” are to the Privacy and Electronic Communications (EC Directive) Regulations 2003.

2.1Headings are inserted for convenience only and shall not affect the construction of this Privacy Policy.

2.2The words “include”, “includes” and “including” are to be construed as if followed by the words “without limitation”, and the enumeration of particular matters shall not be construed as limiting the generality of any preceding words.

2.3The singular includes the plural and vice versa; a reference to one gender includes every gender; and a reference to a person includes a natural person, a body corporate and an unincorporated association.

2.4A reference to a statute, statutory provision or subordinate legislation is a reference to it as amended, extended, consolidated or re-enacted from time to time, and includes any subordinate legislation made under it.

2.5Where this Privacy Policy states that we do not do something, that is a statement of present fact concerning the Service as operated at the date appearing at the head of this document, and not merely a statement of present intention. Should such a statement cease to be accurate, we shall amend this Privacy Policy in accordance with the section governing amendments.

2.6Any obligation not to do a thing includes an obligation not to permit or suffer that thing to be done.

3.1This Privacy Policy constitutes the information required to be provided to data subjects under Articles 13 and 14 of the GDPR and the corresponding provisions of other applicable data-protection legislation.

3.2It is a notice and not a contract. Nothing within it is a matter to which you are asked to agree in exchange for the Service, and your rights under data-protection law subsist irrespective of your acceptance of any terms.

3.3This Privacy Policy applies to Personal Data Processed in connection with your access to and use of the Service. It does not apply to any third-party website, platform or service, whether or not accessed by means of a link appearing upon the Service, nor to the independent Processing carried out by any payment provider with which you contract directly.

3.4Where any provision of this Privacy Policy is held by a court or competent authority to be invalid or unenforceable, that provision shall be severed and the remainder shall continue in full force and effect.

4.1Dusty Lighthouse is a Spanish-language learning website. In this Privacy Policy, “Dusty Lighthouse”, “we”, “us” and “our” mean the operator of that website.

4.2For the purposes of the GDPR and of equivalent legislation, we are the Controller in respect of the Personal Data described in this Privacy Policy. Where we engage third parties to Process Personal Data on our behalf, those parties act as Sub-processors and are identified in the section governing recipients.

4.3We are not required to designate a Data Protection Officer under Article 37 of the GDPR: we are not a public authority or body; our core activities do not consist of Processing operations which, by virtue of their nature, scope or purposes, require regular and systematic monitoring of data subjects on a large scale; and our core activities do not consist of Processing on a large scale of special categories of data or of data relating to criminal convictions and offences.

4.4All correspondence concerning privacy is handled at support@dustylighthouse.com.

5.1The Service is available internationally and is offered in the English language to persons learning Spanish. We do not restrict access by territory.

5.2Where you are located in the United Kingdom or the European Economic Area, the UK GDPR or the EU GDPR respectively applies to the Processing described in this Privacy Policy, and the provisions of this Privacy Policy addressed to such persons apply to you.

5.3Where you are located in a jurisdiction whose data-protection legislation confers rights exceeding those described in this Privacy Policy, we shall give effect to those rights to the extent that legislation applies to us.

5.4Nothing in this Privacy Policy is intended to deprive you of any protection conferred by the mandatory law of your place of residence.

6.1This section is provided for convenience only. It does not qualify, limit or vary any other provision of this Privacy Policy, and in the event of inconsistency the detailed provisions prevail.

• We set one cookie, only during sign-in, which expires within sixty seconds. We set no analytics cookies, no advertising cookies and no tracking cookies.
• We operate no analytics, no advertising and no tracking technologies. There is no analytics package, no measurement pixel, no fingerprinting and no third-party tracker deployed upon the Service.
• We do not sell or share Personal Data for monetary or other valuable consideration, nor for cross-context behavioural advertising, and have never done so.
• Your reading progress, study settings, points and chips are held upon your own device and are never transmitted to us.
• The Companion is the exception. Your messages, and the Companion Memory compiled from them, are transmitted to our servers and onward to third-party artificial-intelligence providers upon each message. We retain no copy, but the transmission occurs.
• The Personal Data we store is limited: an email address where you sign in or subscribe, and short-lived Security Records.

7.1The categories of Personal Data Processed by us, expressed in the terminology employed by the CCPA, are: identifiers, being an email address and an internet protocol address; commercial information, being membership tier and subscription status; internet or other electronic network activity information, being server request logs generated by our hosting provider; and account credentials, being the sign-in link identifier and session token which exist solely to keep you signed in.

7.2We Process no other category. In particular we Process no government identifier, no financial account number, no precise geolocation, no biometric or genetic information, no information concerning racial or ethnic origin, religious or philosophical belief, political opinion, trade union membership, health or sex life, and no inference drawn for the purpose of creating a profile.

7.3The content of messages composed to the Companion is Processed in transit as described below. Such content is determined entirely by you, and we neither solicit nor require any particular category of information within it.

8.1Email address. We Process your email address only where you take one of the steps described in this section.

8.2Request for a sign-in link. We transmit the address supplied to Stripe and to Patreon in order to determine whether an active subscription subsists in respect of it. Where one does, we record the address in our database and dispatch a single-use link to it. Where one does not, no account record is created, but the address is retained within the rate-limiting ledger for twenty-four hours.

8.3Subscription. Where you subscribe through Stripe or Patreon, that provider discloses to us the email address associated with the subscription.

8.4Message content. Where you elect to use the Companion, the text you compose is transmitted to our servers and onward to the artificial-intelligence providers identified below for the purpose of generating a response, a translation and word-level glossary entries.

8.5For the avoidance of doubt, browsing the Service, reading stories and studying flashcards require no account, no email address and no other identifier, and may be undertaken without providing any Personal Data to us beyond that which your device necessarily transmits in the ordinary course of making a request over the internet.

9.1Where you subscribe through Stripe or through Patreon, we obtain Personal Data relating to you from that provider and not from you directly.

9.2The categories so obtained are: the email address associated with the subscription; the membership tier; the status of the subscription; an identifier assigned by the payment provider, retained in order to reconcile subsequent events with your account; and the relevant billing period dates.

9.3We do not receive from either provider your payment card number, your bank account particulars, your postal address or your legal name. Neither source is a publicly accessible source.

9.4Where you subscribe but do not subsequently visit the Service, this Privacy Policy constitutes the information required to be provided under Article 14 of the GDPR in respect of Personal Data not obtained from the data subject, and we shall include a reference to it in the first communication addressed to you.

9.5You are entitled to exercise every right set out below in respect of such Personal Data as though you had provided it to us directly.

10.1Internet protocol address. Our servers necessarily receive the internet protocol address from which each request originates, as does every website. We Process that address for two purposes only: the enforcement of rate limits, and the detection and blocking of automated abuse directed at the sign-in and Companion endpoints.

10.2Prior to storage, an IPv6 address is truncated to its /64 network prefix; an IPv4 address is retained in full. Each stored record comprises the derived key and a timestamp and nothing further. No account identifier is associated with it and it is not linked to your reading activity.

10.3Email address within Security Records. Where you request a sign-in link, your email address is additionally written to the same rate-limiting ledger, so that a single address cannot be targeted repeatedly. This occurs irrespective of whether a subscription subsists in respect of that address, and the entry is erased within twenty-four hours.

10.4Server logs. Our hosting provider generates operational logs which may record internet protocol address, request path, timestamp, user agent and error diagnostics. Such logs are generated and retained under that provider’s own arrangements. We maintain no separate analytics repository derived from them.

10.5Categories not collected. Through our account system we do not collect your name, postal address, telephone number, date of birth, precise geolocation, contacts, or any special category of Personal Data within the meaning of Article 9 of the GDPR. We construct no advertising profile and we do not track you across other websites.

10.6The Companion is a distinct matter and is dealt with expressly below. Where you volunteer information concerning yourself in conversation, that information may be recorded within the Companion Memory and transmitted as described. That is a consequence of the feature operating as designed and of the content which you elect to supply.

11.1We set exactly one cookie, and only upon sign-in. Where you activate a sign-in link, we set a cookie named dusty_session_handoff for the sole purpose of conveying the newly established session to the login page.

11.2That cookie subsists for sixty seconds; is restricted by path to a single endpoint; is marked httpOnly and is therefore not readable by scripts; is marked SameSite=Lax; and is deleted upon being read. It exists in order that session particulars need not travel within a web address, where they would be recorded in browser history and server logs.

11.3That cookie is strictly necessary for the provision of a service which you have expressly requested, namely signing you in, and accordingly falls within the exemption from the consent requirement in Article 5(3) of Directive 2002/58/EC and Regulation 6(4) of PECR.

11.4Save as aforesaid, we set no cookies whatsoever: no analytics cookie, no advertising cookie, no functional cookie and no third-party cookie. There is accordingly no consent banner, for the reason that there is no non-essential storage to which you could meaningfully consent or object.

11.5Our hosting provider may set operational cookies of its own in connection with the delivery and protection of the Service. Such cookies are not set by us, are not within our control, and are not employed by us for analytics or advertising.

11.6Should we hereafter place upon your device anything which is not strictly necessary, we shall seek your consent beforehand in the manner required by law.

12.1The greater part of what the Service remembers is retained within your browser’s localStorage, upon your own device. Regulation 6 of PECR and Article 5(3) of Directive 2002/58/EC apply to the storing of information upon terminal equipment generally and are not confined to cookies; we treat them accordingly.

12.2Each item enumerated below is strictly necessary for the provision of a service which you have expressly requested — remaining signed in, retaining the settings you selected, resuming the lesson you began, continuing the conversation you started — and no item is employed for analytics, advertising, measurement, profiling or tracking of any description.

• Your sign-in token — a signed token recording your email address, membership tier and expiry. This is transmitted to our servers as a request header in order that your membership may be verified.
• Reader and study settings — your study mode, voice selections and display preferences.
• Flashcard and lesson progress.
• Points, chips and unlocks in respect of the in-application progression system.
• Companion conversation history and the identity of the Companion with whom you last conversed.
• The Companion Memory. In the course of conversation an artificial-intelligence model reads your messages and extracts particulars which you have volunteered — such as your first name, city, country, occupation, age and stated reason for learning Spanish — together with recurring themes, undertakings you have given, and a rolling summary of the conversation. This is the mechanism by which the Companion exhibits memory.
• Minor technical values, including a storage-format version marker and the timestamp of your most recent membership refresh.

Two of the foregoing categories leave your device. Your reading progress, study settings, points and chips are never transmitted to us. Your conversation history and the Companion Memory are transmitted to our servers, and onward to the artificial-intelligence providers, upon each message you send, that being the only means by which context may be maintained. We retain no copy, but the transmission is real and is disclosed accordingly.

You may erase all of the foregoing at any time by clearing site data for this domain within your browser settings. Doing so will sign you out and will reset your local progress and the Companion Memory, none of which we are able to restore, for the reason that we never held a copy.

13.1The Companion is a fictional character generated by third-party large language models. It is not a natural person, it holds no professional qualification of any description, and its output may be inaccurate, incomplete or wholly fabricated.

13.2Upon your sending a message, the text is transmitted directly to DeepSeek, presently our sole model provider, for the purpose of generating a response, a translation and word-level glossary entries. No intermediary router is involved. DeepSeek Processes the message under its own terms and privacy policy.

13.3Transmitted with each message are your recent conversation history and the Companion Memory, both of which are held within your browser as described above, in order that context and memory may be maintained.

13.4We do not store your messages or the Companion Memory upon our servers. They traverse our infrastructure in the course of transmission to the providers identified above and are not written to our database. The only subsisting copy resides within your browser.

13.5We do not use anything you compose to train artificial-intelligence models. We are not, however, in a position to give that undertaking on behalf of the providers to whom your messages are routed, certain of whose endpoints may employ submitted prompts to improve their own systems under their own terms. We disclose this rather than give an assurance we cannot honour.

13.6Accordingly, and because your messages leave our infrastructure, you are asked not to enter passwords, financial particulars, health information, or any other matter which you would not wish a third-party artificial-intelligence provider to Process. You are further put upon notice that anything you disclose concerning yourself may be recorded within the Companion Memory and retransmitted with subsequent messages.

14.1Spoken audio within the Service is produced by the speech-synthesis interface built into your browser and not by us.

14.2Depending upon your browser and operating system, the text to be spoken may be processed locally upon your device or transmitted to your browser or device vendor. Such Processing is governed by that vendor’s privacy policy and lies outside our control.

14.3Within the reader, hover translations are served from a static dictionary file downloaded to your device. Consulting a word transmits nothing to us and generates no record.

14.4Within the Companion, word-level translations are generated by the artificial-intelligence providers, with the consequence that the sentence under consideration is transmitted to them together with the remainder of the conversation.

15.1We Process Personal Data only for the purposes set out below and in reliance upon the legal bases there identified. Where more than one basis is identified in respect of a purpose, the basis applicable depends upon the circumstances described.

• To authenticate you and verify membership — email address and subscription status. Performance of a contract to which you are party.
• To generate Companion responses — message content and Companion Memory. Performance of a contract where you are a member; consent where you are not, given by electing to send a message and withdrawable at any time.
• To prevent abuse — Security Records derived from internet protocol address and email address, employed for rate limiting and automated blocking. Our legitimate interests in maintaining availability and controlling cost.
• To send transactional correspondence — sign-in links and essential account notices. Performance of a contract. We send no marketing correspondence and maintain no mailing list.
• To comply with legal obligations — taxation, accounting and record keeping in respect of payments. Compliance with a legal obligation.
• To establish, exercise or defend legal claims — such Personal Data as is relevant to the claim. Our legitimate interests.

We shall not Process Personal Data for a purpose incompatible with that for which it was collected. Where we propose to Process Personal Data for a new purpose, we shall inform you and, where the law so requires, obtain your consent beforehand.

16.1We rely upon legitimate interests in respect of abuse prevention and the defence of legal claims only. The following is a summary of the balancing exercise conducted in respect of abuse prevention, disclosed so that you may evaluate it rather than take it upon trust.

16.2Purpose. To maintain the availability of the sign-in and Companion endpoints for genuine users, and to prevent automated attacks which would otherwise exhaust the cost of operating the Service and render it unavailable to everyone.

16.3Necessity. Rate limiting cannot operate without an identifier per requester, and prior to authentication the internet protocol address is the only identifier available. We adopt the least identifying form available to us, truncating IPv6 addresses to the network prefix. No less intrusive means of achieving the purpose is available to us.

16.4Balance. Security Records are never linked to your reading activity, never employed for profiling or advertising, never sold or shared, and erased within twenty-four hours. We regard the impact upon your privacy as minimal, and as clearly outweighed by the necessity of maintaining the Service in existence.

16.5You are entitled to object to this Processing at any time upon grounds relating to your particular situation. Upon receipt of an objection at support@dustylighthouse.com we shall cease the Processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, and we shall in every case notify you of the outcome and of our reasons.

17.1Where we rely upon consent, that consent is sought by way of a freely given, specific, informed and unambiguous indication of your wishes, signified by a clear affirmative action.

17.2Where you are not a member and elect to use the Companion, we rely upon your consent, signified by your composing and sending a message.

17.3You may withdraw consent at any time, and it shall be as easy to withdraw as to give. Withdrawal is effected by ceasing to send messages and clearing your conversation history within the application or by clearing site data within your browser.

17.4Withdrawal of consent does not affect the lawfulness of Processing carried out in reliance upon consent before its withdrawal.

18.1We do not solicit and have no lawful basis for Processing special categories of Personal Data within the meaning of Article 9 of the GDPR, and no feature of the Service requests such information.

18.2Should you volunteer such information within a message to the Companion, you are asked not to do so. We retain no copy of any message upon our servers, and the content is Processed in transit only for the purpose of generating a response which you have requested.

18.3We do not Process Personal Data relating to criminal convictions or offences.

19.1We limit the Personal Data we Process to that which is adequate, relevant and necessary in relation to the purposes for which it is Processed. The account record we maintain comprises an email address, a membership tier, a payment-provider designation and identifier, and subscription dates.

19.2We take reasonable steps to ensure that Personal Data is accurate and, where necessary, kept up to date. You may correct inaccurate Personal Data by exercising the right of rectification described below.

19.3Personal Data is treated as confidential and is not disclosed save as described in the section governing recipients or as required by law.

20.1We engage the following Sub-processors in order to operate the Service. Each receives only such Personal Data as is necessary for its function and Processes the same under its own agreement and privacy policy.

We do not sell, let, trade or otherwise make available Personal Data to any other party. We may disclose Personal Data where required by law or by valid legal process, or where necessary to establish, exercise or defend legal claims.

In the event that the Service is transferred to another operator, account information may transfer with it, and we would publish notice upon the Service before any such transfer took effect.

21.1We engage a Sub-processor only where it offers sufficient guarantees to implement appropriate technical and organisational measures, and only under an agreement imposing obligations of confidentiality and security.

21.2A Sub-processor is permitted to Process Personal Data only upon our instructions and for the function described, and is not permitted to Process it for its own purposes save to the extent permitted by its own terms in respect of matters such as fraud prevention, security and compliance with law.

21.3We may add to or replace a Sub-processor as the Service develops. Where such a change materially affects the Processing described in this Privacy Policy, we shall update this Privacy Policy and, where required, give notice in accordance with the section governing amendments.

22.1Paid memberships are billed by Stripe or by Patreon. Payment card numbers and bank particulars are entered upon the systems of the relevant provider. We do not receive, view or store your payment card number at any time.

22.2From such providers we receive the email address associated with the subscription, the tier, the status of the subscription, an identifier assigned by the provider, and the relevant billing period dates.

22.3We employ that information solely in order to determine the access to which your account is entitled and to reconcile subsequent billing events with it.

23.1We operate from the United States, and our Sub-processors Process data in the United States and in other countries. Where you are located outside the United States, use of the Service involves the transfer of your Personal Data to a jurisdiction whose data-protection law may differ from that of your own.

23.2Adequacy. Several of our Sub-processors are certified under the EU-US Data Privacy Framework and its UK Extension. Transfers to a certified provider are covered by the European Commission’s adequacy decision of 10 July 2023 and by the corresponding United Kingdom regulations, and require no further safeguard.

23.3Standard Contractual Clauses. In respect of Sub-processors which are not so certified, we rely upon the Standard Contractual Clauses incorporated into the relevant provider’s data processing agreement and, in respect of United Kingdom transfers, upon the International Data Transfer Addendum.

23.4Supplementary measures. All data in transit is encrypted by means of transport layer security; data at rest with our database provider is encrypted; and the Personal Data we hold is confined to an email address, a membership tier, a payment-provider identifier and short-lived Security Records.

23.5Copies. You may request a copy of the transfer safeguards applicable to your Personal Data, including the relevant Standard Contractual Clauses, by writing to support@dustylighthouse.com. We shall furnish the same free of charge within one month, with commercially confidential terms redacted.

23.6You should be aware that the law of the United States may permit public authorities to access data held by United States providers in circumstances which have no exact equivalent in the law of the United Kingdom or of the European Union.

24.1We retain Personal Data only for so long as is necessary for the purposes for which it was collected, save where a longer period is required or permitted by law.

24.2The following schedule reflects the retention windows actually implemented within the Service. A scheduled task operates daily in order to give effect to them.

A limited number of blocks issued in respect of mechanically impossible request bursts are set to an indefinite duration and are retained until removed manually. Should you consider that your address has been blocked in error, you may write to us and the block will be reviewed.

Records held by our Sub-processors — hosting logs, payment records and message delivery logs — are retained under those providers’ own schedules, and payment records are customarily retained for a period of years in order to satisfy financial regulation.

25.1We implement appropriate technical and organisational measures having regard to the state of the art, the costs of implementation, and the nature, scope, context and purposes of Processing, as well as the risk to the rights and freedoms of natural persons.

25.2The measures presently implemented include those enumerated below, each of which is a statement of fact and not of aspiration.

• All traffic is served over HTTPS, with strict transport security asserted.
• Sign-in links are cryptographically signed, expire fifteen minutes after issue, and are capable of being redeemed once only, replay being rejected.
• Session tokens are cryptographically signed and are verified upon the server upon every protected request.
• The sign-in and Companion endpoints are rate-limited, and repeated failures trigger an automatic block, ordinarily of between one hour and seven days, an extreme burst pattern being capable of indefinite blocking.
• Database credentials are held server-side and are at no point exposed to the browser.

No system of security is impregnable, and we are unable to guarantee absolute security. You acknowledge that transmission over the internet is not wholly secure and that any transmission is at your own risk.

26.1Where a personal data breach occurs which is likely to result in a risk to the rights and freedoms of natural persons, we shall notify the competent supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it.

26.2Where such a breach is likely to result in a high risk to your rights and freedoms, we shall communicate it to you without undue delay, describing its nature, the likely consequences, and the measures taken or proposed.

26.3Where you become aware of any circumstance suggesting that Personal Data has been compromised, you should notify us at support@dustylighthouse.com.

27.1Depending upon your place of residence you may be entitled to exercise the rights set out in this section. The exercise of any right is free of charge.

Data subjects in the United Kingdom, the EEA and Switzerland

The UK GDPR or the EU GDPR confers upon you each of the following. These are rights, and not requests which we may refuse at will:

• Access — to confirmation as to whether Personal Data concerning you is Processed, to a copy of it, and to the information set out in Article 15.
• Rectification — of Personal Data which is inaccurate, and completion of Personal Data which is incomplete.
• Erasure — in the circumstances for which Article 17 provides.
• Restriction — of Processing in the circumstances for which Article 18 provides.
• Portability — to receive Personal Data which you provided in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible.
• Objection — to Processing founded upon legitimate interests, upon grounds relating to your particular situation. We conduct no direct marketing.
• Withdrawal of consent — at any time where Processing is founded upon consent.
• Not to be subject to a decision based solely upon automated Processing producing legal effects or similarly significantly affecting you.
• Complaint to a supervisory authority.

28.1Requests should be addressed to support@dustylighthouse.com from the address in respect of which you wish us to act.

28.2Verification. That address being the only identifier we hold, we may be unable to give effect to a request which we cannot match to an account. Where we entertain reasonable doubt as to identity we may request further information, which shall be used solely for verification and erased thereafter.

28.3Timescales. We shall respond within one month of receipt. Where a request is particularly complex or where several requests have been made, we may extend that period by up to two further months, in which event we shall notify you within the first month of the extension and of the reasons for it.

28.4Refusal. Where we decline to act upon a request, we shall inform you of the reasons, of your right to complain to a supervisory authority, and of your ability to seek a judicial remedy.

28.5Authorised agents. You may act by an authorised agent where the applicable law so permits. We may require written authority signed by you and may verify the agent’s authority directly with you.

28.6Effect of erasure. Erasure of your account removes your record from our database, Security Records containing your email address being cleared automatically within twenty-four hours. It does not erase progress or Companion Memory held upon your own device, for which you should clear site data, and it does not cancel a subscription, which must be cancelled with Stripe or Patreon directly, failing which charges will continue to be levied. Where you request erasure while a subscription subsists we shall draw this to your attention before acting.

29.1Should you be dissatisfied with our handling of your Personal Data, we ask that you raise the matter with us first at support@dustylighthouse.com, so that we may investigate and respond. You are under no obligation to do so.

29.2You may complain to the supervisory authority of your habitual residence, your place of work, or the place of the alleged infringement. In the United Kingdom this is the Information Commissioner’s Office (ico.org.uk). Within the EEA, the register of national authorities is published by the European Data Protection Board at edpb.europa.eu. In Switzerland it is the Federal Data Protection and Information Commissioner (edoeb.admin.ch).

29.3You additionally have the right to an effective judicial remedy against a supervisory authority or against us.

30.1We do not buy, sell or share the Personal Data of 100,000 or more consumers or households, and we derive no revenue from selling or sharing Personal Data, with the consequence that the thresholds for application of the CCPA are not met.

30.2We observe its principal protections irrespective of whether it formally applies to us, those being the right to know what Personal Data is collected and the sources and purposes of collection; the right to delete; the right to correct; the right to opt out of sale or sharing; and the right against discrimination for the exercise of any right.

30.3We have not sold Personal Data and have not shared it for cross-context behavioural advertising, at any time, including throughout the preceding twelve months. There is accordingly no “Do Not Sell or Share My Personal Information” mechanism upon the Service, there being nothing to which it could apply.

30.4We do not use or disclose sensitive Personal Data for any purpose beyond performing the service requested, and accordingly the right to limit its use does not arise.

30.5We operate exclusively online and deal with you directly, and accordingly an email address is the only method of submitting requests which we are required to offer. We shall respond within 45 days.

31.1Other United States jurisdictions. The comprehensive privacy legislation of Virginia, Colorado, Connecticut and Utah applies by reference to thresholds of consumer volume or revenue which we do not meet. Where such legislation nevertheless applies to us, we shall give effect to the rights it confers.

31.2Canada. Where the Personal Information Protection and Electronic Documents Act applies, you have rights of access and correction, and support@dustylighthouse.com is the channel by which the person accountable for Personal Data may be reached.

31.3Brazil. Where the Lei Geral de Proteção de Dados applies, you have rights of confirmation, access, correction, anonymisation, portability, deletion and information concerning sharing, and support@dustylighthouse.com is our designated channel for such requests.

31.4The enumeration of a jurisdiction in this section is not an admission that its legislation applies to us, and the omission of a jurisdiction is not an assertion that it does not.

32.1Certain browsers transmit a “Do Not Track” or Global Privacy Control signal.

32.2We conduct no tracking, serve no advertising and undertake no sale or sharing of Personal Data, with the consequence that there is no Processing which such a signal could disable. Where we hereafter undertake any Processing to which such a signal is applicable, we shall honour it.

33.1No statute requires you to furnish us with Personal Data. Whether provision is necessary depends solely upon what you wish to do.

33.2Reading stories, studying flashcards and browsing. No Personal Data is required. No account, no email address, nothing.

33.3Signing in and holding a membership. Your email address is contractually necessary, being the sole means by which you are connected to the subscription for which you have paid. In default of provision we are unable to sign you in. No other consequence follows.

33.4Using the Companion. The message you compose is necessary for the obvious reason that no response can be generated to a message which has not been sent. Where the feature is not used, nothing is transmitted.

33.5Internet protocol address. This cannot be withheld from any website, ours included, that being the mechanism by which your request is delivered. We Process it only as described above.

34.1We do not profile you, we do not score you, and we take no decision in respect of you producing legal effects or similarly significantly affecting you by automated means.

34.2We do operate one automated process. Our servers automatically throttle or block requests from an internet protocol address which exceeds a fixed rate limit, or which repeatedly fails authentication.

34.3The logic is a counter and not a profile. Requests bearing a given IP-derived key are counted within a fixed window, and where the count crosses a threshold further requests are refused for a fixed period. No human characteristic is involved, and the determination is incapable of considering your email address, your membership or your reading activity, none of which is linked to such records.

34.4The consequence is that you would be unable to sign in or to use the Companion from that network until the block lapses, ordinarily within minutes to hours. Your membership, your billing and your ability to read the Service are unaffected.

34.5Although we do not regard this as a decision attracting Article 22 of the GDPR, we afford the safeguards of that Article in any event: upon writing to support@dustylighthouse.com a human being shall review the block, shall consider any representations you wish to make, and shall lift it where it was wrongly imposed. No charge is made and no justification is required of you.

35.1The Service is intended for adults and is not directed to children. You must be at least 18 years of age to use any part of the Service, including those parts which require no account.

35.2We do not knowingly collect Personal Data from any person under 18 years of age, and the Service contains no feature soliciting a date of birth, a school, a parent’s particulars or any other matter directed to a child.

35.3Where you believe that a person under 18 has furnished us with Personal Data, you should write to support@dustylighthouse.com and we shall erase the same promptly.

36.1The Service may contain links to websites which we do not control. This Privacy Policy does not apply to any such website.

36.2We accept no responsibility for the content, availability or privacy practices of any third party, and you are advised to consult the privacy policy of any website you visit.

37.1We may amend this Privacy Policy from time to time as the Service develops. The date appearing at the head of this document identifies the current version.

37.2Where an amendment is material we shall publish a prominent notice upon the Service.

37.3Where an amendment would materially affect the manner in which we use Personal Data already held concerning you, we shall notify you by email in advance of its taking effect wherever we hold an address for you.

37.4Where the applicable law requires your consent we shall seek it properly, rather than treating your continued use of the Service as agreement. Consent by inertia is not consent.

38.1This Privacy Policy is written in the English language. Any translation is provided for convenience only, and in the event of conflict the English text prevails.

38.2Our failure to exercise or enforce any right shall not constitute a waiver of that right.

38.3Nothing in this Privacy Policy confers any right upon a third party.

39.1All enquiries, requests and complaints concerning privacy should be addressed to support@dustylighthouse.com.

39.2Email is the contact channel we operate, and correspondence sent to that address is read.