Privacy Policy

This Privacy Policy explains how personal information is collected and used when you visit The Detail is (always) in the Devil website, contact us, subscribe to episode alerts or choose to receive WhatsApp updates.

1. Who is responsible for your information?

The data controller is:

Francisco Oliva
2 Poplar Lodge
Gibraltar
Email: f.oliva62@gmail.com

The public-facing project is known as The Detail is (always) in the Devil.

2. Information we collect

Depending on how you use the website, we may collect:

• your email address and, if you provide it, your first name when you subscribe to episode alerts;
• your telephone number, profile details and messages if you contact us or opt in through WhatsApp;
• the content of enquiries or feedback you send to us;
• your subscription preferences and records of consent;
• technical and security information such as IP address, browser type, device information, timestamps and server logs;
• website usage information where you have consented to analytics cookies; and
• advertising interaction information where you have consented to marketing cookies.

Please do not send sensitive personal information unless it is necessary for your enquiry.

3. How and why we use your information

Where processing is based on consent, you may withdraw that consent at any time without affecting processing that took place before withdrawal.

4. Email updates

If you subscribe, we will use your details to send new episode alerts and closely related podcast news. We will not add you to unrelated marketing lists.

You can unsubscribe at any time using the link in an email or by contacting us. After you unsubscribe, we may retain the minimum information needed to respect your choice and prevent further messages.

5. WhatsApp updates

WhatsApp updates are optional. If you choose to contact or follow us through WhatsApp, WhatsApp will process information under its own terms and privacy policy. We will use your details only for the updates or conversation you requested and will not add you to a list without an affirmative opt-in.

6. Cookies, analytics and advertising

We use strictly necessary storage to operate the website and remember your privacy choices. We use analytics, marketing and embedded-media technologies only after you give the relevant consent.

You can accept, reject or change your choices at any time through Cookie settings in the footer. More information is available in our Cookie Policy.

7. Embedded content and external services

The website may link to or, with your consent, display content from services such as Spotify, YouTube, Substack, Meta platforms and WhatsApp. These providers may receive information about your device and interaction when you open their services or enable embedded content. Their own privacy policies apply to their processing.

Where possible, we provide ordinary outbound links so that you can choose whether to visit a third-party service.

8. Who we share information with

We may use trusted service providers to host the website, manage subscriptions, deliver email, provide analytics, prevent abuse and maintain the website. They may process personal information only as needed to provide their services and subject to appropriate contractual and security requirements.

The email-delivery provider must be listed here before launch:

• Website hosting and content delivery: Cloudflare
• Newsletter/email delivery: [TO CONFIRM]
• Analytics: Google Analytics 4, if enabled after consent
• Advertising: Meta Pixel, if enabled after consent
• Spam prevention: internal controls only

We may also disclose information where required by law or where reasonably necessary to establish, exercise or defend legal claims.

We do not sell personal information.

9. International transfers

Some service providers may process information outside Gibraltar. Where personal information is transferred internationally, we will use providers and safeguards appropriate to the destination and applicable data-protection requirements. You may contact us for more information about relevant safeguards.

10. How long we keep information

We retain personal information only for as long as reasonably necessary for the relevant purpose:

• subscription details are kept while you remain subscribed;
• unsubscribe records may be retained as a suppression record so that your choice is respected;
• enquiries are normally kept for up to 24 months after the last meaningful contact, unless a longer period is needed for a legal or operational reason;
• security logs are normally kept for up to 90 days, unless needed to investigate an incident; and
• cookie and analytics retention is described in the Cookie Policy and relevant service settings.

11. How we protect information

We use reasonable technical and organisational measures designed to protect personal information. These include access controls, secure connections, limited administrative access, software updates and appropriate provider agreements. No internet service can guarantee absolute security.

12. Your rights

Subject to applicable law, you may have the right to:

• ask for access to your personal information;
• ask us to correct inaccurate or incomplete information;
• ask us to erase information;
• ask us to restrict how information is used;
• object to certain processing;
• receive information you provided in a portable format where applicable;
• withdraw consent at any time; and
• complain to the relevant data-protection authority.

To exercise a right, email f.oliva62@gmail.com. We may need to verify your identity before responding.

You may also contact the Gibraltar Regulatory Authority, Gibraltar's data-protection supervisory authority, through its current contact details at gra.gi.

13. Children

The website and subscription services are intended for a general adult audience and are not directed at children. We do not knowingly collect personal information from children through the website. If you believe a child has provided personal information, please contact us so that we can review and, where appropriate, delete it.

14. Changes to this policy

We may update this Privacy Policy when the website, service providers or legal requirements change. The latest version will be published on this page with a revised date.

15. Contact

For privacy questions or requests, contact:

Francisco Oliva
Email: f.oliva62@gmail.com
Address: 2 Poplar Lodge, Gibraltar