Governance
- Version
- Version 2.1
- Last Revised
- Controller
- Joel R. Klemmer
- Requests
- Contact page
This Privacy Policy does not constitute legal advice. No representation is made that the site complies with any specific jurisdictional privacy regime unless corresponding technical and administrative controls have been implemented.
Section 1. Identity of the Controller
The data controller for purposes of applicable data protection law is Joel R. Klemmer.
All privacy-related requests must be submitted through the Contact page of this site. Requests should include sufficient detail to identify the requester and the nature of the request.
Identity Verification
To protect against unauthorized disclosure, reasonable verification measures may be required prior to fulfilling a request. Verification may include confirmation of the email address used in prior communications, contextual information relating to site interaction, or other reasonable steps proportionate to the sensitivity of the information requested.
Appeals
If a request is denied in whole or in part, an appeal may be submitted through the Contact page. Appeals will be reviewed and responded to within a reasonable timeframe consistent with applicable law.
Response Timeframe
Verified requests are addressed within the timeframe required by applicable law, typically within 30 to 45 days depending on jurisdiction and complexity.
Section 2. Scope and Nature of the Site
This website is an informational and institutional authority site. It does not:
- Sell products or services
- Process payments
- Operate subscription or membership programs
- Conduct behavioral advertising
- Engage in cross-context tracking
- Intentionally collect sensitive categories of personal data
The site may provide downloadable materials, including media kits, press kits, photographs, and PDF documents.
We collect and retain only the information necessary to fulfill the purposes described in this policy.
Section 3. Categories of Information Processed
We collect the categories of personal information described below for the purposes described in Section 5 of this policy.
3.1 Information Voluntarily Submitted
When information is submitted through the Contact form, the following categories may be processed:
- Name
- Email address
- Organization or affiliation, if provided
- Message content
- Attachments voluntarily submitted
This information is processed solely for purposes of responding to the inquiry and maintaining appropriate communication records.
3.2 Technical and Usage Information
Standard technical data may be processed automatically in connection with requests to the site, including:
- Internet Protocol address
- Browser type and version
- Device metadata
- Timestamps of requests
- Pages accessed
- Referrer information
- Requested file paths
- Download activity relating to photographs, media kits, press materials, or PDF documents
This data is processed for site delivery, operational integrity, diagnostics, and security monitoring. It is not used for advertising, cross-site tracking, or behavioral profiling.
3.3 Consent Status Information
Where cookies are used, consent preferences are stored in a first-party consent cookie. This record reflects consent status and does not contain personal information beyond the preference selection.
3.4 Sensitive Personal Information
This site does not intentionally collect sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law. If sensitive information is voluntarily submitted, it will be processed only as necessary to respond to the communication.
Section 4. Legal Bases for Processing
Where applicable under relevant law, personal information is processed under one or more of the following legal bases:
- Consent, for optional analytics and non-essential cookies
- Legitimate interests, including maintaining site functionality, ensuring security, responding to inquiries, and preserving records integrity
- Compliance with legal obligations
Where processing is based on legitimate interests, we assess that such interests are not overridden by fundamental rights and freedoms of affected individuals.
Where processing is based on consent, consent may be withdrawn at any time as described below.
Section 5. Purpose of Processing
Personal information is processed solely for the following purposes:
- Responding to inquiries and communications
- Maintaining and delivering site functionality
- Protecting platform integrity and preventing misuse
- Documenting communications where necessary for governance or record integrity
- Complying with applicable legal obligations
The site does not use artificial intelligence systems to evaluate, score, profile, or make decisions about visitors. No automated decision-making produces legal or similarly significant effects.
Section 6. Cookies and Similar Technologies
Cookies and similar technologies are used as described in the separate Cookie Policy.
Essential cookies support core functionality and consent storage. Optional analytics or functional cookies load only after explicit opt-in. Marketing or advertising cookies are not used.
The site does not engage in device fingerprinting or cross-site behavioral profiling.
Some browsers transmit privacy signals such as Global Privacy Control. This site does not engage in sale or cross-context behavioral advertising. Where legally applicable, recognized signals are interpreted consistently with the stated practices of this site.
Section 7. Disclosure of Information
Personal information is not sold and is not shared for cross-context behavioral advertising.
Information may be disclosed only in limited circumstances:
- To infrastructure providers responsible for hosting, content delivery, operational security, or consent-based analytics
- Where required by law, court order, or valid legal process
- Where necessary to protect rights, security, or integrity of the site
Service providers process limited technical data necessary to deliver the site and operate under contractual or equivalent obligations. They are not authorized to use site data for independent marketing or profiling.
Section 8. International Transfers
Data may be processed in infrastructure provider locations that may be outside the jurisdiction of the visitor. Where legally required, appropriate safeguards such as contractual protections or recognized adequacy mechanisms may be relied upon.
No representation is made regarding jurisdiction-specific compliance unless corresponding safeguards have been implemented.
Section 9. Data Retention
Personal information is retained only for as long as operationally necessary and legally appropriate. Retention periods are determined based on operational necessity, legal obligations, security requirements, and record integrity considerations.
In general:
- Contact submissions are retained for up to twenty-four months unless extended for documented governance, dispute resolution, or legal process
- Server and security logs are typically retained for up to ninety days unless required for incident investigation
- Backup systems retain data on a rolling basis for operational resilience
- Consent records are retained while active or until reset
Where a legal preservation obligation applies, information may be retained for the duration of that obligation.
The site does not maintain long-term behavioral tracking archives.
Section 10. Data Security
Reasonable administrative, technical, and structural safeguards appropriate to the nature of the information processed are applied. These may include:
- Encryption in transit
- Access controls and least-privilege practices
- Rate limiting and abuse protection
- Infrastructure-level monitoring
- Backup and restoration procedures
No guarantee of absolute security is made.
Security Incident Response
If unauthorized access to personal information under our control is identified, the incident will be assessed and notification provided to affected individuals or regulators where required by applicable law.
Section 11. Individual Rights
Depending on jurisdiction, individuals may have rights including:
- Access to personal information
- Correction of inaccurate information
- Deletion where legally permitted
- Restriction of processing
- Data portability where applicable
- Objection to processing based on legitimate interests
- Withdrawal of consent
- Appeal of denied requests
- Lodging a complaint with a competent supervisory authority
All requests must be submitted through the Contact page and are subject to reasonable verification.
Section 12. Children
This site is not directed to children. Personal information from children under thirteen years of age is not knowingly collected. If such information is identified as having been submitted without appropriate consent, it will be deleted.
The site does not knowingly sell or share personal information of individuals under sixteen years of age.
Section 13. External Links and Embedded Content
This site may contain links to third-party websites. Those websites operate under their own privacy policies and practices. No responsibility is assumed for third-party privacy practices.
Embedded content may transmit technical data such as IP address where necessary for delivery.
Section 14. Legal Requests
Information may be disclosed where required by law, court order, or valid legal process.
Section 15. Withdrawal of Consent
Where processing is based on consent, consent may be withdrawn at any time using the cookie preferences control or by submitting a request through the Contact page. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Section 16. Complaints
Individuals located in jurisdictions with data protection authorities may lodge a complaint with their local supervisory authority. Individuals are encouraged to contact the site through the Contact page prior to lodging a formal complaint so that concerns may be addressed directly where possible.
Section 17. Policy Updates
This Privacy Policy may be updated when material changes occur. The revision date appears at the top of the page. Material changes will be prominently indicated. Continued use following updates indicates awareness of the revised policy.