Legal
Privacy Notice
This document is a draft pending review by qualified counsel and pending registration of the operating entity. It is published in this state deliberately — an unreviewed legal page marked as such is more useful than a confident-looking one that has never been checked.
Published in draft pending review by qualified counsel and pending registration of the operating entity. Until the entity exists there is no controller, and no personal data is being processed by anyone.
Controller
The controller is the operating entity named in the imprint, at the address published there. Contact details for data protection enquiries are published alongside it.
What we collect, and why
We collect as little as the transaction allows.
| Data | Why | Lawful basis (GDPR Art. 6) |
|---|---|---|
| Name, email, delivery address | To take, dispatch and invoice your order | 6(1)(b) performance of a contract |
| Company name, VAT identifier | To invoice correctly and apply the right VAT treatment | 6(1)(b) and 6(1)(c) legal obligation |
| Research-use confirmation: the text you accepted, word for word, and the time | To evidence that we sold to a qualified purchaser | 6(1)(c) legal obligation |
| Order and payment records | Statutory accounting and tax retention | 6(1)(c) legal obligation |
| Batch and shipment records | Product traceability and liability defence | 6(1)(c) and 6(1)(f) legitimate interests |
| A partner code you applied to your order | To credit the partner whose code you chose to apply | 6(1)(b) performance of a contract |
| Visits through a partner link: the partner code, the page you landed on, the host that referred you (not the full address), a flag for automated traffic, and a daily-salted hash of your IP address and browser user agent | To pay partners correctly and to detect abuse | 6(1)(f) legitimate interests |
| Partner registration and account: name, email address, where you publish, and company, VAT identifier and country where given; a password kept only as an argon2id hash; payout details (a Bitcoin wallet address) and every change to them; any notes we make about the account | To run the affiliate programme, pay commission and keep the records the law requires | 6(1)(b) and 6(1)(c) legal obligation |
We do not collect special-category data. We do not ask for, and do not want, any information about your health.
What we do not do
- No advertising cookies, no tracking pixels, no third-party analytics that identify you
- No profiling and no automated decision-making with legal effects
- No sale, rent or trade of your data, to anyone, ever
- No third-party font, script or asset host — the site makes no request to any domain other than its own, so visiting a page does not disclose your IP address to a third party
Analytics
We use a cookieless, EU-hosted analytics service that records aggregate page views without setting a cookie or storing an identifier that can be traced back to you. Because no personal data is processed for analytics, no consent banner is required and none is shown. That is the whole reason we chose it.
Partner links and codes
Some links to this site come from partners in our affiliate programme. A partner link carries a code: ?ref= and the code at the end of the address, or the short form /r/ and the code.
Arriving through a partner link stores nothing on your device. The page shows a notice that names the code, says that the partner earns a commission and that your price is unchanged, and offers "Apply to my order" and "Dismiss". "Dismiss" stores nothing. The code is taken out of the address bar either way.
"Apply to my order" stores the code in your browser's local storage, beside your cart. So does typing a code into "Have a partner code?" at the cart or at checkout. The code is then one visible line in the cart and at checkout, and you can remove it there at any time. It is not a cookie, and your browser does not attach it to requests. It reaches our server twice: once when it is checked, at the moment you press "Apply to my order" or type it in, and once as part of an order you place. It does not lapse: it stays in your browser, as that visible line, on every order you place from it, until you remove it or apply another code. It lives in your browser only. Nothing on our servers ties you to a partner, so an order from another device, or after you have cleared your browser's storage, carries no code unless you apply one again.
The site can be set to apply a partner code on arrival instead. That setting is off, and it stays off unless this notice is changed first to say so.
The visit itself is logged on our server. For each visit through a partner link we record the code, the page you landed on, the host that referred you, a flag for automated traffic, and a hash. The hash is SHA-256 over your IP address and browser user agent, made with a random salt held only in server memory and replaced every UTC day. We never store the IP address and we set no cookie. The hash does tell one visitor from another, within a single day: that is what it is for, so that a partner's count of visitors is not a count of page loads. Once a day's salt is gone its hashes cannot be recomputed by anyone, including us, and cannot be linked to a hash from another day.
Raw visit rows are deleted after 90 days. Daily counts per partner are kept.
The code changes no price. The rules partners work under are in the affiliate programme terms.
Affiliate partners
If you register as a partner we hold what the table above lists. We cannot verify your email address, because no system of ours sends email.
Commission is paid in Bitcoin, to the wallet address you enter. A wallet address is public on its blockchain, and payouts to it are visible there to anyone.
Sign-in attempts to the partner area are rate-limited with the same daily-salted hash of your address. No IP address is stored. Each attempt is recorded with the email address that was typed into the form, whether or not it belongs to a partner, and those records are deleted after 30 days.
Every change to a payout address is recorded with its time, and a new address waits before a payout is prepared for it. A transfer cannot be recalled, so an address that nobody has had time to notice is not paid.
Cookies and local storage
- No advertising cookies and no analytics cookies.
- One cookie exists. It is a strictly necessary session cookie for partners who sign in to the partner area. It is limited to that area and set only when a partner registers, signs in or sets a new password. Visitors to the shop never receive it.
- Your cart, and a partner code you applied, live in your browser's local storage. Both are put there by your own actions, both are visible to you, and both can be removed by you.
Nothing else is stored on your device. For that reason no consent banner is shown.
Who else sees your data
Only parties that must, to fulfil your order:
- the carrier, for delivery
- our bank or the Bitcoin payment infrastructure, for payment
- our accountant and tax authority, for statutory records
- the customs authority, where an import declaration requires it
Where you applied a partner code to your order, that partner sees that an order was placed with their code, the date it was paid and its commissionable value. The partner never sees who placed it, and never sees what it contained.
Each receives the minimum needed. We do not transfer personal data outside the EEA for marketing purposes. Where an international shipment requires a transfer, it is limited to what the customs declaration demands.
How long we keep it
Order, invoice and accounting records for the statutory retention period applicable to the entity's state of establishment — typically six to ten years. Batch traceability records for as long as product liability exposure persists under Directive (EU) 2024/2853. Everything else is deleted when the purpose ends.
Raw rows for visits through a partner link are deleted after 90 days; daily counts per partner are kept. Records of sign-in attempts to the partner area are deleted after 30 days. A partner's ledger and payout records are accounting records and are kept for the same statutory period, together with the account they belong to.
Your rights
Under GDPR Articles 15 to 22 you may request access to your data, rectification, erasure, restriction of processing, portability, and you may object to processing based on legitimate interests. Ask, and we will answer within one month.
Where we hold data to satisfy a statutory retention duty we cannot delete it on request, and we will tell you plainly which duty applies rather than refusing without explanation.
You may complain to the supervisory authority in your country of residence or place of work.
Security
Data is held on infrastructure in the European Union. Payment credentials never reach our servers: bank transfers happen at your bank, and Bitcoin payments settle to a node we operate without us handling card or account credentials at any point.
Orders are stored on our own server. The public website writes an order through a database role that cannot read a customer's name, email address or delivery address back out of it. Partner passwords are stored only as argon2id hashes.
Changes
Material changes are dated at the foot of this page. The version that applied when you ordered governs that order.