This policy explains what personal data is collected when you use yurgenschembri.com, including the free tools and any products you buy from me, and what happens to it.
The short version
- No cookies, no advertising, no tracking across other websites.
- I use Microsoft Azure Application Insights to see which pages and tools get used. Some tools send the values you type into them as part of this (see below).
- Tools that remember your work keep it in your own browser, not on a server.
- Purchases go through a third-party platform. I receive your name, email and order details, never your payment details.
- I never sell your data.
Who I am
This website is run by me, Yurgen Schembri Xuereb, based in Malta. I am the data controller for the personal data described here. You can contact me about anything in this policy at info@yurgenschembri.com.
What I collect and why
Usage analytics
Every page loads Microsoft Azure Application Insights. It records the pages you view, how long you spend on them, your browser, device type and operating system, the page that referred you, and an approximate location (country and city) worked out from your IP address. By default Application Insights uses your IP address only to estimate that location and does not store the full address. It is set up not to use cookies, so it cannot recognise you between visits.
I use this to understand which content and tools are useful and to spot errors. The legal basis is my legitimate interest in running and improving the site.
What the free tools send
When you use a tool, an analytics event is recorded so I can see how it is being used:
- FIRE calculator: when you run a projection, the figures you entered are sent: ages, withdrawal rate, and the assets, incomes and expenses you added, including any labels you gave them.
- Baby Name League: the names you enter, the votes and the final results.
- Secret Santa: only the number of participants, number of exclusions and how long the draw took. Participant names are not sent.
None of this is linked to your name or email, and I do not try to identify anyone from it. Still, please don't put anything that identifies you, such as your name or account numbers, in the labels you type into the FIRE calculator.
Data stored in your browser
The FIRE calculator and Baby Name League save your progress in your browser's local storage so it is still there when you come back. This data stays on your device and is not sent to me through this mechanism. You can remove it by using the tool's reset option or clearing your browser's site data. Because it is only used to provide the feature you asked for, it does not need consent.
Hosting
The site is hosted on Microsoft Azure. Like any web host, Microsoft processes your IP address and request details to deliver pages and keep the service secure.
Emails
If you email me, I receive your email address and whatever you write. I use it only to reply and to keep a record of our conversation. The legal basis is my legitimate interest in answering you, or taking steps towards a contract if you are asking about work.
Purchases
Digital products are sold through third-party platforms (currently Payhip, and possibly Gumroad or Lemon Squeezy). The platform handles checkout, payment and sales tax, and collects what it needs for that, under its own privacy policy. I receive your name, email address, country, what you bought and the price paid. I never see your card or payment details.
I use this to deliver your purchase, provide support and updates, handle refunds, and keep the accounting records the law requires. The legal bases are performing our contract and complying with my legal obligations. I will only send you marketing emails if you have opted in, and you can unsubscribe at any time.
Who I share data with
- Microsoft (Azure hosting and Application Insights), as my processor.
- The sales platform you buy through: Payhip, Gumroad or Lemon Squeezy.
- My accountant and the tax authorities, where needed for tax and accounting.
Some of these providers process data outside the European Economic Area, including in the United States. Where they do, the transfer is covered by an adequacy decision (such as the EU-US Data Privacy Framework or the UK adequacy decision) or by the European Commission's standard contractual clauses.
How long I keep it
- Analytics data: up to 31 days, then deleted automatically.
- Emails: as a record of our conversation, for as long as it may be useful to refer back to it. I review my inbox from time to time and delete old messages, and I'll delete yours on request.
- Purchase records: as long as Maltese tax and accounting law requires.
Your rights
Under the GDPR you can ask me to give you a copy of your personal data, correct it, delete it, restrict or object to how I use it, or give it to you in a portable format. To do any of these, email info@yurgenschembri.com. Because analytics data is not tied to your name, I may not be able to find the records that relate to you.
If you are unhappy with how I handle your data, you can complain to the Information and Data Protection Commissioner in Malta (idpc.org.mt) or the data protection authority where you live. I'd appreciate the chance to sort it out first.
Children
The site is not aimed at children, and I do not knowingly collect data from anyone under 16.
Changes to this policy
If I change how I handle data, I will update this page and the date at the top. See also the Terms of Use.