Privacy Policy

Who is responsible for it

Oleksandr Lubnin trading as SeoExpert is the controller of the personal data described on this page. The address at the head of this page is the address for any question about it, and contact@seoexpert.space is the quickest way to ask one.

This is an individual trading under a business name, not a company, so there is no company number to quote. A data protection officer is not required for a business of this kind and none has been appointed; questions come to the person named above.

What is collected, and where it comes from

Four things, and they arrive in different ways.

• What you write in an enquiry. Your name, your email address, your business, and whatever you say about what you need written. It reaches me as an email, sent by you.
• What is said in an interview. A recording of the conversation and the notes taken from it, including the name and role of the person interviewed and anything they say about their work.
• What goes into a piece. Where a case study is written, the names, words and details of the customer being written about, as far as they have agreed to have them published.
• What the hosting provider records. Ordinary server logs for pages served from this site: an internet address, the time, the page asked for and the browser that asked. These are a by-product of serving a page, not something this site asks for.

There is nothing else. This site sets no cookies, stores nothing in your browser, loads no fonts or scripts from anybody else's servers, and carries no analytics, no advertising pixels and no social media buttons.

What the request form does, exactly

The form on the contact page does not send anything. It checks your answers, gives the brief a reference and writes it out as plain text, then hands that text to your own email program as a message addressed to me. Until you press send in your own email program, nothing has left your device and I have not seen it.

Nothing typed into the form is stored in your browser, and the form has no address to post to: a browser with JavaScript turned off cannot submit it at all, which is deliberate - a form without a destination would otherwise put every answer into the address bar and from there into logs and browser history.

Why it is held, and on what basis

Enquiries are read and answered, and the answer is kept with them, so that what was quoted and what was agreed can be checked later. The basis for that is the contract between us and the steps taken at your request before it is made - Article 6(1)(b) of the UK GDPR - and, for an enquiry that never becomes a commission, the legitimate interest in being able to show what was said to somebody who comes back three months later (Article 6(1)(f)).

Interview recordings and notes exist so that your expert can be quoted as they put it rather than as it was remembered, and so that a challenge to something in a finished piece can be answered by going back to what was actually said. That is the contract again, and the legitimate interest in being able to stand behind published work.

Invoices and the records behind them are kept because tax law requires records of what was sold and to whom (Article 6(1)(c)).

Server logs are kept briefly so that a hosting provider can see that its servers are working and being used as they should be, which is its legitimate interest and mine.

The person you put forward for an interview

Where you nominate somebody to be interviewed, their name, role and words become personal data that I hold about them and not about you. Two things follow, and both are yours to do before the call.

Tell them what the conversation is for, that it will be recorded, that what they say may be quoted in material published under your business's name, and that they can ask me what is held about them or ask for it to be deleted. Nobody should arrive at an interview without knowing those four things.

The same applies to a customer of yours who agrees to be written about: they see the draft before it is published, and what is kept about them is kept for the reasons set out above and for no longer than is said below.

Anyone whose words are held here can write to contact@seoexpert.space directly, whoever commissioned the piece. They do not have to go through you, and a request from them is answered as it would be from anybody else.

Who else sees it

As few as the work allows. There is no team here, so nothing is shared internally.

• The hosting provider that serves these pages and carries the mailbox. No provider is named here because none has been appointed yet; whoever it is will be named in writing to anybody who asks.
• An accountant, who sees the sales records and the invoices behind them.
• A bank or payment provider, which sees what it needs to move a payment. Card details are never handled by this business: where a payment provider is used, the card is entered on that provider's own pages.
• Whoever the law requires, where there is a legal obligation to hand something over.

Nothing is sold, rented, shared for advertising, or passed to anybody who is not on this list.

Where it is kept

The intention is that everything stays inside the United Kingdom: the pages, the mailbox, the recordings and the files. The hosting and mailbox providers have not been appointed yet, and the requirement placed on them will be that they serve from inside the United Kingdom.

If that ever ceases to be true - if a provider is used that stores or processes data elsewhere - this passage will say which provider, which country and what the transfer relies on, and it will say it before the transfer starts rather than afterwards.

How long it is kept

An enquiry that does not become a commission is kept for twelve months from the last message and is then deleted, which is long enough for somebody who went quiet in March to come back in the autumn and be recognised.

An interview recording, and the notes taken from it, are kept for six months after the piece has been handed over. That covers the period in which a piece is normally queried, and after it the recording is deleted; the finished piece and the list of facts you confirmed are kept with the commission.

The record of a commission - the brief, the confirmation, the drafts, the invoice - is kept for six years from the end of the tax year it falls in, which is the period tax records have to be available for.

Server logs are kept for 30 days by the hosting provider and are then overwritten.

What you can ask for

You can ask for a copy of what is held about you; for anything wrong in it to be corrected; for it to be deleted; for its use to be restricted while something is being sorted out; for a copy in a form you can take elsewhere; and you can object to its being used where the basis for using it is a legitimate interest. Where anything is ever done on the basis of consent, that consent can be withdrawn at any time, and withdrawing it does not make what was done before it unlawful.

Write to contact@seoexpert.space, or to the postal address at the head of this page. A request is acknowledged within two working days and answered within one month. There is no charge. If a request cannot be met in full - because a record has to be kept for tax, for instance - you are told which part and why.

Giving your details is not compulsory in the abstract, but a piece of writing cannot be commissioned anonymously: without a name, an email address and somebody to interview, there is nothing to agree and nothing to write from.

Nothing here is decided automatically. There is no profiling, no scoring and no automated decision-making of any kind: every reply, quotation and draft is written by a person.

If you are not satisfied

Raise it here first, at contact@seoexpert.space, and it will be looked at properly. If you are still unhappy you have the right to complain to the Information Commissioner's Office, which is the United Kingdom's supervisory authority for data protection. Complaining to the ICO is free, and it does not stop you taking any other route open to you.

The ICO is at Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, and its guidance and complaint forms are at ico.org.uk.

Changes to this page

This page is revised when what it describes changes - a hosting provider appointed, a retention period altered, a new way of receiving enquiries - and the date of the current revision is at the head of it. A change that affects how personal data already held is used is told to the people it affects rather than left to be noticed.