Privacy Policy for Vestige

Introduction

At Vestige, accessible from https://vestige-gamma.vercel.app, the privacy and security of our visitors is a top priority. This Privacy Policy describes what personal data we collect, why we collect it, how we use and protect it, and what rights and choices you have.

This policy applies to information collected through our website only. It does not cover data collected offline or via third-party services that link to or from our site.

By accessing or using Vestige, you acknowledge that you have read and agree to this Privacy Policy. Questions or requests may be sent to ashborne.work@gmail.com.

Definitions

• Personal Data: Any information relating to an identified or identifiable person, including name, email, IP address, and online identifiers.
• Processing: Any operation on personal data, including collection, storage, use, transfer, and deletion.
• Data Controller: Stephen Thomas, determining the purposes and means of processing personal data on Vestige.
• You / User: Any individual accessing or using Vestige.

Information We Collect

1. Information You Provide Directly

• Contact form submissions: name, email address, and message content
• Account registration: name, email address, username, and encrypted password

2. Automatically Collected Data

• IP address, browser type and version, operating system, and device type
• Pages visited, time and date of visit, duration, and referring URL
• HTTP request headers and server log data
• Aggregated usage analytics via Google Analytics 4 or similar services

How We Use Your Information

We process personal data for the following purposes:

Analytics

We use Google Analytics 4 (GA4) to measure traffic and usage patterns. GA4 uses first-party cookies and does not use third-party cookies for cross-site tracking. Our privacy configuration includes:

• IP anonymisation enabled; your full IP address is never stored by Google
• Data retention configured to a maximum of 14 months
• We have signed a Data Processing Amendment with Google in accordance with GDPR
• GA4 data is not shared with Google for its own advertising purposes

You may opt out of Google Analytics tracking at any time via the Google Analytics Opt-Out Browser Add-on.

Third-Party Services and Integrations

We work with trusted third-party service providers who may access your personal data only to the extent necessary to perform services on our behalf. All processors are bound by Data Processing Agreements (DPAs). Categories include:

• Hosting and infrastructure: Cloud providers who host our website and databases
• Analytics: Tools for measuring usage and performance
• Security and monitoring: Fraud detection and uptime monitoring services

How We Share Your Information

We do not sell your personal information. Data is shared only in these limited circumstances:

• Service Providers: Trusted processors under contract who help operate our website; they may only process data as instructed by us.
• Legal Requirements: Where required by law, regulation, subpoena, or court order. We notify you where legally permitted before disclosing.
• Safety: To protect the rights, property, or safety of Vestige, our users, or the public.
• Business Transfers: In a merger, acquisition, or asset sale, your data may transfer. You will be notified via a prominent website notice and, where feasible, by email.
• With Your Consent: For any other purpose with your explicit prior consent.

Data Security

We implement appropriate technical and organisational measures to protect your personal data:

• HTTPS/TLS 1.2+ encryption for all data in transit
• Bcrypt or equivalent hashing for stored passwords; plaintext passwords are never stored
• Role-based access controls limiting data access to authorised personnel
• Regular security assessments, penetration testing, and vulnerability scanning
• Real-time monitoring systems for detecting suspicious activity

In the event of a personal data breach likely to result in risk to your rights, we will notify affected individuals and relevant supervisory authorities within the legally mandated timeframe (e.g. 72 hours under GDPR).

Data Retention

We retain personal data only as long as necessary to fulfil stated purposes or as required by law:

Your Privacy Rights

Depending on your location, you may have rights to access, correct, delete, restrict, or transfer your personal data. You may exercise these rights by contacting us at ashborne.work@gmail.com. We will respond within the timeframe required by applicable law. You will never be penalised or discriminated against for exercising your privacy rights.

GDPR - European Union Data Protection Rights

If you are in the EU or EEA, the General Data Protection Regulation (EU) 2016/679 grants you these rights:

• Right of Access (Art. 15): Request a copy of personal data we hold and how it is processed.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete data without undue delay.
• Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your data where no longer necessary, consent is withdrawn, or processing is unlawful, subject to legal retention obligations.
• Right to Restriction of Processing (Art. 18): Request we temporarily halt processing in certain circumstances.
• Right to Data Portability (Art. 20): Receive your data in a structured, machine-readable format (e.g. CSV/JSON) and transfer it to another controller where technically feasible.
• Right to Object (Art. 21): Object to processing based on legitimate interests or for direct marketing; we will cease unless we demonstrate compelling grounds.
• Rights re: Automated Decisions (Art. 22): Not be subject to solely automated decisions, including profiling, that produce significant legal or similarly significant effects, without human review.
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time where processing relies on it, without affecting the lawfulness of prior processing.

Legal Bases for Processing: Art. 6(1)(a) Consent; Art. 6(1)(b) Contract; Art. 6(1)(c) Legal obligation; Art. 6(1)(f) Legitimate interests. For special category data, we rely on Art. 9(2)(a) explicit consent or other applicable bases.

International Transfers: Transfers outside the EEA are protected by EU Standard Contractual Clauses (SCCs, Commission Decision 2021/914), adequacy decisions, or other lawful Chapter V GDPR mechanisms.

Data Protection Officer: Where legally required, a DPO has been appointed. Contact: ashborne.work@gmail.com.

We will respond to GDPR requests within 30 days (extendable by 2 months for complex cases). You may also lodge a complaint with your EU Member State's supervisory authority (DPA).

UK GDPR - United Kingdom Rights

If you are in the UK, your rights under the UK GDPR and Data Protection Act 2018 mirror those under EU GDPR listed above. The Information Commissioner's Office (ICO) is the UK supervisory authority: ico.org.uk. International transfers from the UK are governed by UK International Data Transfer Agreements (IDTAs) or UK addendums to EU SCCs as approved by the UK Secretary of State.

CCPA / CPRA - California Consumer Privacy Rights

The California Consumer Privacy Act (CCPA), as amended by the CPRA (effective January 1, 2023), grants California residents:

• Right to Know: Disclosure of categories and specific pieces of personal information collected, sources, purposes, and third parties with whom data is shared.
• Right to Delete: Request deletion of personal information, subject to exceptions (completing transactions, security, legal obligations).
• Right to Correct: Request correction of inaccurate personal information we hold.
• Right to Opt Out of Sale or Sharing: Opt out of the sale or sharing of personal information for cross-context behavioural advertising. We do not sell personal information. Should this change, we will add a "Do Not Sell or Share My Personal Information" link to our homepage.
• Right to Limit Sensitive Personal Information: Restrict use of sensitive personal information to necessary purposes only.
• Right to Non-Discrimination: We will not deny service, charge different prices, or provide lower quality because you exercised a CCPA right.

Personal information collected in the past 12 months: Identifiers (name, email, IP address); Internet or network activity (browsing history, site interactions); Commercial information (if purchases made); Geolocation data (if location features used); Inferences drawn to build user profiles.

Submit CCPA requests to ashborne.work@gmail.com. We verify identity and respond within 45 days (extendable by 45 days). Authorised agents may submit requests on your behalf with proper documentation.

Other US State Privacy Rights: Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Oregon (OCPA), and other states with similar privacy laws may exercise equivalent rights by contacting ashborne.work@gmail.com.

COPPA - Children's Online Privacy Protection

Vestige is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13 (or under 16 in jurisdictions where a higher threshold applies, such as certain EU member states under GDPR Art. 8).

If we discover we have inadvertently collected data from a child under the applicable age threshold without verified parental consent, we will delete it immediately. Parents or guardians who believe their child has submitted data on Vestige should contact us at ashborne.work@gmail.com. We will investigate and take corrective action within 72 hours of notification.

Where our service intentionally serves users under 13, we collect minimum necessary data only, obtain verifiable parental consent (VPC) prior to any collection, provide parents the right to review, correct, and delete their child's data, and do not condition participation on disclosing more data than strictly necessary.

Links to External Websites

Vestige may contain links to third-party websites. Once you leave our site, this Privacy Policy no longer applies. We have no control over and accept no responsibility for external sites' content, privacy policies, or practices. We recommend reviewing the privacy policy of any third-party site you visit.

Do Not Track (DNT) Signals

Some browsers transmit "Do Not Track" signals to websites. There is currently no universally accepted standard for how websites must respond to DNT signals. At this time, Vestige does not alter its data collection practices in response to DNT browser signals. We will review this position as industry standards evolve.

Changes to This Privacy Policy

We may update this Privacy Policy periodically. When material changes are made, we will update the "Last Updated" date at the top and post a prominent notice on our website. Your continued use of Vestige after any modification constitutes acceptance of the revised policy. We encourage you to review this page periodically.

Contact Us

For questions, data subject requests, or privacy complaints, please contact us:

• Website: https://vestige-gamma.vercel.app
• Email: ashborne.work@gmail.com
• Data Controller / Owner: Stephen Thomas

We aim to respond to all enquiries within 5 business days, and within applicable legal deadlines for formal data subject requests.