Privacy Policy

Last updated: 3 September 2025

1) Who we are (Data Controller)

Website: https://joycebutalale.scratchpub.com
Controller: Joyce Butalale (ScratchPub)
Contact for privacy matters: privacy@scratchpub.com]
Postal address: Gombe/Kinshasa office]

This website is a presentation site about Joyce and her work. It allows visitors to learn more and to contact her via a form. We do not run ads or analytics on this site.

This notice explains what personal data we collect, why we collect it, how long we keep it, and your rights under applicable data protection laws (notably the EU/UK GDPR).


2) What data we collect

a) Contact form (you provide it)

  • Identification and contact data (e.g., name, email, phone if provided)

  • The message you send and any other information you choose to include

b) Technical & security data (collected automatically)

  • IP address, date/time, pages visited, referrer URL, and user-agent (browser/OS)

  • Basic cookies that are strictly necessary to operate the site and the form (no marketing or analytics cookies)

We do not intentionally collect special category data (e.g., health, religion). Please avoid including such details in your message.


3) Why we use your data (purposes) and legal bases

PurposeExampleLegal basis
Respond to your inquiryReplying to your contact form messageArt. 6(1)(b) GDPR (pre-contractual steps) or Art. 6(1)(f) (legitimate interest in answering business inquiries)
Site security and reliabilityServer logs, spam/misuse prevention, uptimeArt. 6(1)(f) GDPR (legitimate interests)
Legal complianceHandling legal requests, retention dutiesArt. 6(1)(c) GDPR (legal obligation)

We do not use your data for profiling or targeted advertising.


4) How long we keep your data

  • Contact form messages: up to 12 months after last interaction (or longer if needed to handle your request or legal obligations), then securely deleted.

  • Server logs: typically 30 days (host default), then automatically deleted.

  • Cookies: only essential cookies; session cookies expire when you close your browser or after their functional lifetime.

You can ask us to delete your contact message earlier (see Your rights, below).


5) Who can access your data (recipients)

We share data only with service providers needed to run this website and process your message, for example:

  • Hosting provider (web server and email delivery)

  • Website software (WordPress and the form plugin)
    These processors act under contract and follow our instructions. We do not sell or rent your personal data.


6) International transfers

If a provider stores or accesses data outside the EEA/UK, we rely on appropriate safeguards (e.g., Standard Contractual Clauses) or adequacy decisions. You may request details of the safeguards used for your data.


7) Your rights (EU/UK GDPR)

You have the right to access, rectify, erase, restrict, object to processing, and data portability where applicable. If we rely on consent (not typical on this site), you can withdraw it at any time.

To exercise your rights, contact us at [replace with email]. You also have the right to lodge a complaint with your local data protection authority (e.g., CNIL in France, your EU authority, or the ICO in the UK).


8) Cookies

We use only strictly necessary cookies to make the site function (e.g., basic WordPress/session functionality or to remember simple preferences). We do not use analytics, advertising, or social tracking cookies on this site.

You can control cookies via your browser settings. If you block essential cookies, some features (like the form) may not work properly.


9) Children

This site is intended for business inquiries from adults. If you are under the age required by your local law (e.g., 16 under the GDPR), please ask a parent or guardian to contact us on your behalf.


10) Security

We implement reasonable technical and organizational measures to protect your data (HTTPS, server hardening, access controls). However, no method of transmission or storage is 100% secure.


11) Changes to this policy

We may update this policy to reflect changes to our practices or legal requirements. We will post the new version with an updated “Last updated” date.


12) How to contact us

For any privacy questions or requests: [replace with email]
Postal address: [replace with address]


13) Legal note

This policy provides general information and is not legal advice. Your specific compliance requirements can vary by jurisdiction and services used.