Privacy

Who is responsible

The controller of any personal data the Wire handles is Rafael Garcia del Valle, a sole proprietorship (enkeltpersonforetak) registered in Norway, organisation number 936 731 546, Vei 232-9, 9170 Longyearbyen, Svalbard, Norway. Write to editor@svalbardwire.com.

The Norwegian Personal Data Act (personopplysningsloven) and the General Data Protection Regulation (GDPR) apply to the Wire. They apply on Svalbard too: the regulation of 15 June 2018 on the processing of personal data extends them to Svalbard, apart from GDPR article 56 and chapter VII. The supervisory authority is Datatilsynet, the Norwegian Data Protection Authority.

Reading the site

The site sets no cookies, has no accounts and carries no advertising. The two typefaces are served from the Wire's own server, so your browser sends nothing to a font service.

The site runs one analytics script, Vercel Web Analytics, served from the Wire's own address. It counts page views without cookies. For each page view it records the time, the page address without anything after the question mark, the page you came from, the country, region and city the request comes from, your browser and operating system with their versions, and whether you use a phone, a tablet or a computer. It tells one visitor from another by a code made from the request, which is reset every day, so a reader cannot be followed from one day to the next or from one site to another; the record is not tied to your IP address. No profile of you is built and nothing is shared for advertising. The legal basis is the Wire's legitimate interest in knowing what is read (GDPR article 6(1)(f)).

The same script also counts, without cookies, whether an article was read to the end, and which of the Wire's own tagged links, on its Facebook posts and in its weekly email, brought a visit. These counts carry only the page address and the name of the link. Nothing in them identifies a person.

Vercel, which hosts the site, keeps a standard request log: the address asked for, the time, the browser string and your IP address. Vercel keeps those logs for a limited period under its own terms, and the Wire reads them only to find faults. The legal basis is the Wire's legitimate interest in running a working, secure site (GDPR article 6(1)(f)).

The search box sends your words to the Wire's server, which answers and keeps no record of the query beyond that same request log, where it appears as part of the address. The analytics script leaves the words out.

The Screen, the list of recent videos from local channels, shows each video's thumbnail from YouTube's image server. Your browser fetches that picture from Google when the section is on screen, so Google sees the request and your IP address; the Wire sends no referrer with it and loads nothing else from Google.

Links to sources, to Visit Svalbard, to Google Maps, to TripAdvisor and to YouTube leave the site. What those sites record is governed by their own policies.

The Book links

When you press Book on a tour, the Wire records the tour, the page you came from and a 16-character code made from your IP address, your browser string and the date. The IP address itself is not stored; the code cannot be turned back into it, and it changes every day. The record exists to count how many readers go on to Visit Svalbard, under the same legitimate interest. The booking itself happens on Visit Svalbard's site, under its policy; the Wire sees nothing of it.

The Facebook app

The Wire's Facebook app posts to the Wire's own Facebook Page only, once a day, with lines already published on that day's page. It reads the comments on those posts and hides them, because the Wire does not answer on Facebook; a comment that points to an error is checked against the Wire's corrections.

For each comment the app stores the text, the time and the comment's id. It stores no name and no profile id of the person who wrote it. Apart from that it reads nothing from Facebook but the Page's follower count, once a week. How Facebook itself handles your comment is governed by Meta's policies.

The weekly email

The weekly email is sent through Buttondown (Buttondown, LLC, Richmond, Virginia, United States), which handles the subscribers' data for the Wire as its processor, under its data processing agreement.

When you sign up, Buttondown stores your email address, the time of your subscription, your IP address and the address of the page you signed up from. The Wire leaves Buttondown's open and click tracking off, so no record is kept of whether you open an email or follow its links.

After you sign up, Buttondown sends one email with a link to confirm the subscription (double opt-in); no weekly email comes until you confirm. Every weekly email has a link to unsubscribe.

Buttondown keeps the data in the United States, on Amazon Web Services. The transfer from Norway is covered by the European Commission's standard contractual clauses (controller to processor), which Buttondown's data processing agreement incorporates.

The legal basis is your consent (GDPR article 6(1)(a)), which you withdraw by unsubscribing. To have your address deleted, write to editor@svalbardwire.com; it is deleted within a month of the request, as set out under Your rights.

Writing to the Wire

A letter to the contact address is kept as correspondence, with your name and address as you gave them, for as long as it takes to answer and, where it reports an error, to document the correction. The corrections log records that a report was made and what source it pointed to, not who made it.

Where the data is kept

The Wire's database, including the Book records and the stored comments, is kept by Supabase in Frankfurt, in the European Union. The request logs and the page-view counts are kept by Vercel. The weekly email's subscribers are kept by Buttondown, as set out above. All three act on the Wire's instructions under their data processing terms. Nothing the Wire records about a reader is sold, shared or passed to anyone else.

Your rights

You can ask what the Wire holds about you, have it corrected or deleted, have its use restricted, object to it, or receive a copy. Write to editor@svalbardwire.com. You get an answer, and anything to be deleted is deleted, within a month of the request, as the law requires.

If you think the Wire handles your data wrongly, you can complain to Datatilsynet at datatilsynet.no.