Privacy policy

01Who is responsible

The controller responsible for personal data on this website is:

I have not appointed a data protection officer, as none is required for a personal website of this kind. For any privacy question or request, email me at the address above.

02Visiting the site

This website is static: there are no user accounts, forms, comments or logins. It is hosted and delivered by Cloudflare, Inc. (Cloudflare Pages and Cloudflare's network), which acts as my processor under its Data Processing Addendum.

What is processed

When your browser requests a page, Cloudflare necessarily receives and processes technical data, including:

• your IP address and the country derived from it;
• the date and time of the request and the page or file requested;
• the referring page, if your browser sends it;
• your browser type, operating system and device type (user agent).

Why, and on what legal basis

• To deliver the pages you request and keep them available and fast.
• To protect the site against attacks, abuse and automated traffic.
• To see aggregated traffic statistics in Cloudflare's dashboard, such as the number of visits and visitors' countries.

The legal basis is my legitimate interest in running a secure, working website (Article 6(1)(f) GDPR). I use this data only to operate and secure the site. I do not use it to identify you, build profiles or combine it with other data.

How long it is kept

Log and analytics data is kept by Cloudflare for limited periods set out in its policies, and is then deleted or aggregated. I do not download or keep separate copies.

03Transfers outside the EU

Cloudflare, Inc. is based in the United States (101 Townsend St., San Francisco, CA 94107, USA). Cloudflare is certified under the EU–U.S. Data Privacy Framework, including the UK extension and the Swiss–U.S. Data Privacy Framework, and its Data Processing Addendum also incorporates the EU Standard Contractual Clauses (Articles 45 and 46 GDPR). More information: Cloudflare Privacy Policy ↗ and Cloudflare GDPR information ↗.

04Contacting me

If you email or call me, or message me on LinkedIn, I process the information you send: typically your name, contact details, the content of your message and any attachments.

• Purpose: to reply to you and, where relevant, to discuss internships or other professional opportunities.
• Legal basis: steps taken at your request before entering into a contract, such as an internship (Article 6(1)(b) GDPR); otherwise my legitimate interest in answering messages sent to me (Article 6(1)(f)).
• Where it is stored: emails are stored in my EDHEC Business School mailbox; LinkedIn messages are stored by LinkedIn.
• How long: for as long as the conversation needs it. I delete correspondence at the latest 24 months after our last contact, unless you ask me to delete it sooner or I am legally required to keep it.

Providing this information is voluntary. Without it, I cannot reply to you.

05External links

This site links to other websites, such as LinkedIn. It does not embed social media plugins, videos, maps or other third-party content, so no data is sent to those services unless you click a link. Once you do, the other site's privacy policy applies. The site tells browsers to share only its domain name, not the page you were on, when you follow an external link.

06What I don't do

• No cookies are set by this site, and no local storage or similar technologies are used. See the cookie policy.
• No analytics or tracking scripts, advertising, pixels or fingerprinting.
• No fonts, scripts or other files are loaded from third-party servers such as Google.
• No selling or sharing of personal data, and no newsletters.
• No automated decision-making or profiling within the meaning of Article 22 GDPR.

07Your rights

Under the GDPR you have the right to:

• access the personal data I hold about you (Article 15);
• have inaccurate data corrected (Article 16);
• have your data erased (Article 17);
• restrict how it is processed (Article 18);
• receive it in a portable format (data portability, Article 20);
• object to processing based on legitimate interests, on grounds relating to your particular situation (Article 21);
• withdraw consent at any time, where processing is based on consent (Article 7(3)).

To exercise any of these rights, email alexander.vershinin@edhec.com. It is free of charge. I will reply within one month, or tell you within that month if I need up to two more months for a complex request (Article 12(3)). I may ask for information to confirm your identity.

Data processed only by Cloudflare in its logs is not linked to your name, so I usually cannot find it on request. Cloudflare's own privacy policy explains how to contact it directly.

08Complaints

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state where you live, work or where the alleged infringement took place (Article 77 GDPR). For example:

• Greece: Hellenic Data Protection Authority, www.dpa.gr ↗
• France: Commission Nationale de l'Informatique et des Libertés (CNIL), www.cnil.fr ↗

I would appreciate the chance to resolve any concern first, so please feel free to email me.

09Other information

Security

The site is served only over encrypted HTTPS connections and sends security headers that restrict what the pages may load.

Children

This site is not directed at children under 16, and I do not knowingly collect their personal data.

Changes to this policy

I will update this policy if the site changes, for example if analytics were ever added. The date at the top shows the latest version.