This policy explains what personal data Portolan (ma-delta.com) collects, why, where it is stored and what choices you have. We collect as little as we can: there are no user accounts, no newsletters and no advertising trackers on this site.
1. Who is responsible
The controller of your personal data, a private individual who owns and runs ma-delta.com. For any privacy question or request, email edit@ma-delta.com with “Privacy” in the subject line.
2. What we collect
- Comments. If you leave a comment: the name or nickname you enter, your email address, the comment text, the date and time, your IP address and browser details.
- Emails to the editors. If you write to us: your email address, your name if you give it, and the content of your message.
- Analytics. Only if you accept analytics cookies: a cookie identifier, IP address (used to estimate your location; Google Analytics 4 does not log or store it), device and browser type, approximate location (country, city), the pages you view, how you arrived and your interactions with the page. This data is collected by Google Analytics 4.
- Server logs. Our hosting server records IP addresses, request times and the pages requested, to protect the site from attacks and fix errors.
We do not ask for or collect payment details, ID numbers or sensitive data such as health information.
3. Why we use it and our legal basis
| Purpose | Data | Legal basis (GDPR) |
|---|---|---|
| Publishing and moderating comments, fighting spam | comment data | legitimate interests in running an open comment section (Art. 6(1)(f)) |
| Answering your email | email data | legitimate interests in responding to you (Art. 6(1)(f)) |
| Understanding which articles are useful | analytics data | your consent through the cookie banner (Art. 6(1)(a)) |
| Security and keeping the site running | server logs | legitimate interests in protecting the site (Art. 6(1)(f)) |
We do not sell your data, use it for advertising or share it for marketing.
4. What other visitors see
Published comments show only the name you entered, the date and the comment text. Your email and IP address are never published.
5. Who receives your data
- Hosting provider. The site, including comments and server logs, is hosted by a hosting provider on servers in the Russian Federation.
- Google. Analytics data is processed by Google Ireland Limited and Google LLC (USA) under Google’s data processing terms.
- Authorities, only where the law requires it.
6. International transfers
If you visit from the European Economic Area or the UK, your data is transferred outside it. The Russian Federation, where the site is hosted, is not covered by a European Commission adequacy decision. We limit what is stored there to what the site needs to work: comments, emails and server logs. Analytics data sent to Google LLC in the United States is covered by the EU-U.S. Data Privacy Framework, in which Google participates, and by standard contractual clauses.
7. How long we keep it
- Comment data: for as long as the comment is published, or until you ask us to delete it.
- Emails: as long as needed to deal with your message, and no longer than three years.
- Analytics: no longer than 14 months, the retention period set in our Google Analytics account.
- Server logs: for the period set by the hosting provider.
8. Cookies
We use necessary cookies that keep the site working and remember your cookie choice, and analytics cookies that load only with your consent. Details are in our Cookie Policy. You can change your choice at any time through the “Cookie settings” link at the bottom of every page.
9. Your rights
Depending on where you live, you can ask us to:
- tell you what personal data we hold about you and give you a copy;
- correct inaccurate data;
- delete your data, including your comments;
- restrict or object to how we use your data;
- transfer data you gave us to you in a common format;
- withdraw your consent at any time, without affecting earlier processing.
You also have the right to complain to the data protection authority in your country. We answer requests within one month. To delete a comment, send us a link to it from the email address you used.
10. Children
Portolan is a business reference site and is not directed at children under 16. We do not knowingly collect their data.
11. Security
The site uses HTTPS encryption, access to the admin area is limited and password-protected, and the site software is kept up to date. Only the site owner can access commenters’ email and IP addresses.
12. Changes to this policy
We may update this policy, for example when we add a new service. The effective date at the top shows the current version.
