Privacy policy

Who we are #

This privacy policy explains how Context Visualised Limited ("CoVi", "we", "us") collects, uses and shares your personal data. Context Visualised Limited also trades as CoVi Analytics.

It applies when you:

• Use our website and blog
• Contact us through the Talk to us form, or by email
• Sign up to follow Halden
• Open an item in our library, or register for the full library
• Use Rulio, our free regulation search at rulio.covianalytics.com
• Create or sign in to a Context Visualised account

Data controller: Context Visualised Limited
Company number: 09907206
Registered office: 3 Lloyd's Avenue, London EC3N 3DS
ICO registration: ZA555645
Contact: privacy@covianalytics.com

1. Information you give us #

We collect information you give us directly, including when you:

• Send us a message through the Talk to us form
• Sign up to follow Halden
• Ask to open an item in our library
• Create a Context Visualised account
• Ask Rulio a question, or pin provisions and add notes in Rulio
• Email us, or otherwise contact us

The Talk to us form asks for your name, firm, role, email address, and what you are trying to fix. It does not ask for a phone number.

Follow Halden asks only for your email address.

Your account asks for your work email address and a password. You sign in with your password, or with a one-time code that we email to that address. If you choose a team in Rulio, we keep that choice with your account.

The library asks for your work email address, and for your agreement that we may contact you for feedback on what you use. That agreement is a condition of access. Library updates are a separate choice, and you can leave the box unticked. We store your email address, the item you asked for, your choices, the wording you agreed to and the time. Section 6b explains how it works.

Rulio keeps the questions you ask, the team you choose, and the provisions you pin with your notes. Section 6a explains what happens to each.

If you email us, we also hold whatever you choose to send.

2. Information we collect automatically #

When you visit our website, we collect:

• Log information. Browser type, access times, pages viewed, IP address, and the page you came from. Our server's access logs keep IP addresses for about 14 days. We do not record what you search for. We store the questions you ask Rulio, as described in section 6a.
• Device information. Device type, operating system and version, and screen size.
• Rulio. When you ask Rulio a question, we store a one-way code made from your IP address (a hashed IP) and the ID of your anonymous session (section 6a). Rulio never stores your IP address itself in its database.
• Cookies and similar technologies. Small files and scripts that tell us how the site is used. We set strictly necessary cookies automatically. We set analytics and marketing cookies only if you accept them. See section 3 and our cookie policy.

3. Analytics and marketing tags #

We use the tools below to understand how our website is used, and to show our ads to people who have visited it. Google Analytics and PostHog load only if you accept analytics cookies. The Google Ads tag and the LinkedIn Insight Tag load only if you accept marketing cookies. You accept them with "Accept all" in our cookie banner, or by turning them on under "Choose". Until you choose, none of them loads. Accepting analytics cookies alone never turns on advertising. "Reject all" is shown as an equal choice, and the site works the same either way.

• Google Analytics 4. Tells us which pages people visit, how they arrived, and which buttons they click. For example, whether someone opened a Halden report or sent the Talk to us form. Provided by Google Ireland Limited. If you accept both analytics and marketing cookies, we use Google Analytics data to build audiences for Google Ads (see "Advertising audiences" below).
• Google Ads. Our Google Ads tag loads only if you accept marketing cookies. It tells us which Google ads lead to visits and enquiries, and lets us show our ads on Google and its partner sites to people who have visited ours (remarketing). We have turned on Google signals. If you accept analytics and marketing cookies, Google may link your visit to your Google account. It does this only if you are signed in to Google and allow ad personalisation. It can then recognise you across devices and show you our ads. Without marketing cookies, Google collects no signals data from your visit. Provided by Google Ireland Limited.
• PostHog. Shows us how people use the site: session recordings, heatmaps of clicks and scrolling, and the paths people take from page to page. A session recording replays the pages you saw, your clicks and your scrolling. Everything you type into a form is hidden before it leaves your browser. PostHog loads and records only after you accept analytics cookies. If you reject them, PostHog does not run at all. We add the PostHog session ID to Google Analytics, so we can find the recording for a visit. We do not give PostHog your name or email address. Provided by PostHog Inc., on its EU Cloud in Frankfurt, Germany.
• LinkedIn Insight Tag. Tells us which LinkedIn campaigns bring people to the site, and gives us grouped reports on visitors' job titles and industries, which do not name anyone. Provided by LinkedIn Ireland Unlimited Company. LinkedIn acts as a joint controller for some Insight Tag data. If you accept marketing cookies, we also use it to show our ads on LinkedIn to people who have visited the site (retargeting), and to find LinkedIn members with profiles similar to our visitors (similar audiences).

Advertising audiences. If you accept marketing cookies, your visit can add you to an audience in Google Ads or LinkedIn. We use audiences only to show our own ads to you or to people like you. We may also use where your visit came from. For example, we may show a Google ad to someone who arrived from LinkedIn, or a LinkedIn ad to someone who arrived from a Google ad. Audiences built from Google Analytics data also need analytics cookies. If you withdraw marketing consent under "Cookie settings", your visits stop adding you to our audiences. To leave an audience straight away, change your ad settings with Google or LinkedIn.

Contact details sent to Google. If you accept marketing cookies, the Google tag on our pages looks for contact details: an email address, a phone number, a name or an address. It can find them in what you type into our forms as you send them, and in contact details shown on the page. Your browser turns each one into a scrambled code (a SHA-256 hash) before anything leaves it. Google Ireland Limited receives the codes, not the plain details. Google uses them to match your visits and enquiries to Google accounts. A code is not anonymous: Google can match it to an account it already holds. We use the match to measure which ads lead to enquiries, and to support audiences in our linked Google Ads account. This runs only if you accept marketing cookies. To stop it, choose "Reject all", or turn marketing off under "Cookie settings" in the footer. Your later visits then send nothing. Google keeps the codes under its own privacy policy. To stop Google using your activity for personalised ads, change your settings at myadcenter.google.com. To ask about data we have shared, write to privacy@covianalytics.com.

Where your visit came from. We add campaign tags (UTM parameters) to links we share, so we can see which posts and emails bring people to the site. When you send the Talk to us form or the Follow Halden form, we store these details with it:

• The campaign tags, including any search term in the link (utm_term)
• The page you came from (the referrer)
• The first page you landed on
• Any ad click ID: gclid from Google Ads, or li_fat_id from LinkedIn

We keep these details with your enquiry in our customer records system, Attio. Attio Ltd is a UK company, and it hosts our data on Google Cloud.

If you accept marketing cookies, we also remember these details from your first visit: for the current tab in covi_first_touch, and for 90 days in our own cookie, covi_ft. So if you come back later and send a form, we can see what first brought you here. Without marketing consent, we use only the details of the page where you send the form.

You can change your choice at any time through "Cookie settings" in the footer of any page.

4. Information from other sources #

We may receive information about you from other sources and combine it with what we hold. For example, LinkedIn may tell us that a visit came from one of our campaigns. If you click one of our ads, Google or LinkedIn adds a click ID to the link, and we store it with your enquiry (section 3). We may also receive information from people you have authorised to share it with us.

5. How we use your information, and our lawful basis #

We do not sell your personal data. We do not use it for automated decisions that have legal or similarly significant effects on you. Rulio's replies point you to provisions; they are not decisions about you.

6. The Halden email #

If you follow Halden, we send one email a month, "This month at Halden", and a short alert when we publish a new report. We send nothing else to this list unless you agree.

When you sign up, we first email you a link to confirm the address. You join the list only when you click it. When you click, we store your IP address, your browser details and the name of your network with the sign-up record. It is our proof that the owner of the address confirmed it. We keep it in our live records for 2 years from when you confirmed, even if you unsubscribe sooner. Copies in our backups leave within about 6 months.

Every email has an unsubscribe link. One click takes you off the list.

We send our emails through Resend, run by Plus Five Five, Inc. in the United States. Our emails carry no tracking pixel and no tracked links.

6a. Rulio and your account #

What Rulio is. Rulio is our free regulation search at rulio.covianalytics.com. You can search and open any rule without an account. Rulio points you to provisions. It does not give advice, and it does not tell you whether you comply.

Your account. Our sign-in service is Clerk, Inc., in the United States. Clerk holds your email address and your password, emails you a one-time sign-in code if you choose that, and sets the cookies that keep you signed in. Clerk stores your password as a hash, and we never see it. Clerk also checks passwords against lists of known breached passwords. If you sign in from a device Clerk does not recognise, Clerk emails you a code to confirm it is you, and then remembers that device. Clerk works for us under its data processing terms, and hosts data mainly on Google Cloud and Cloudflare. One account works for Rulio and the full library. We keep your email address, your Clerk account ID and the team you choose.

When you ask Rulio a question. OpenAI's models write Rulio's replies, through a ChatGPT subscription. When you ask, we send OpenAI your question, the team you chose, up to six short previous messages in that conversation, and the public provisions Rulio found. We do not send your name, your email address, your pinned items or your notes. OpenAI OpCo, LLC, a US company, processes this content in the United States as an independent controller, under its own privacy policy, not as our processor. We have switched off the setting that lets OpenAI use this content to improve its models. The software on our server that connects to OpenAI also keeps a copy of each question and reply. We delete those copies within 90 days.

Question logs. We keep each question and its reply for up to 90 days, with a hashed IP and your anonymous session ID, or your account if you are signed in. We use them to apply the daily question limits, keep costs in check and prevent abuse. After 90 days we delete the question, the reply and the hashed IP. We keep only counts and costs, with no question text.

Your anonymous session. When you first use Rulio, it sets a cookie, cv_sid, holding a random ID. It lets us count questions for the daily limit without an account. We delete the session 30 days after you last use it.

Pinned items, lists and notes. When you sign in, you can pin provisions, group them in lists and add notes. We keep them until you delete them, or until you delete your account.

Deleting your account. Once signed in, use "Delete account" in the Rulio account menu. We then delete your account, your pinned items, your lists and your notes. We delete the text of your questions and Rulio's replies. We keep an anonymous count of questions asked, with no text and nothing that links it to you, so our daily limits keep working. We also delete your Clerk account, which ends your full library access.

Backups. Every day, we copy our data from our server to a Google Workspace Shared Drive in our own account. We encrypt the copies before they leave our server. The key stays on our server and in our password manager. The copies hold:

• The website files and server settings. These hold no personal data.
• The forms archive: Talk to us and Follow Halden submissions (name, firm, role, work email, message and the confirmation record), and library access records (a hash of your email address, its domain, the terms version and times).
• The Rulio database: accounts, pinned items, notes and usage.
• Analytics data: Google Analytics reports, Search Console queries, PostHog events (which carry pseudonymous IDs) and social post statistics.
• PostHog session recordings, which we collect only with analytics consent.

We keep the newest copy from each of the last 7 days, 5 weeks and 6 months. We keep recordings in backups for at most 90 days. When you delete your data or withdraw consent, we remove it from our live systems straight away. We do not edit backup copies. Your data leaves them as they roll off, within about 6 months (recordings within 90 days). We use backups only to restore our service, never to bring deleted personal data back for any other use.

No advertising. Rulio shows no ads and runs no analytics or advertising tags. We do not use your Rulio data for advertising.

Alerts. When something in Rulio breaks, it emails our team through Resend. These alerts hold no personal data.

Where it runs. Rulio runs on a server we rent from Hetzner Online GmbH, in Helsinki, Finland.

6b. The library #

What it is. Our library holds resources such as process maps, control lists, risk registers and training material. Anyone can see the list of items and their summaries.

One item. To open one item, enter your work email address on that item's page and agree that we may contact you for feedback. We then email you a link to check the address is yours. When you click it, we set a cookie, cv_lib, that gives your browser access to that one item for 90 days. Asking for a second item, with the same email or from the same browser, takes you to registration. We use only the cv_lib cookie to tell whether it is the same browser.

Checking requests. To stop automated requests, we check your IP address, your browser details and the name of your network when you click the link. We check them in memory and do not store them. We keep only the result of the check, and delete it after 30 days.

The full library. Register for a Context Visualised account (section 6a) to open every item. After you first sign in, we ask you once to agree to the same feedback condition, and offer the optional library updates.

Work emails only. We check each address against a list of personal and disposable email providers, and check that its domain receives email. We refuse personal addresses such as Gmail or Outlook, and we do not store addresses we refuse. Accounts with a personal address cannot open the library or pin provisions in Rulio. If you signed up with one, Clerk may hold it until you delete the account.

Feedback contact. Agreeing that we may contact you for feedback is a condition of access, set out in our Terms of access. We contact you about the library items you use.

Library updates. A separate box you can leave unticked. We send library updates only if you tick it, from a separate list, and you can unsubscribe at any time.

What we store. Your email address, the item or items, your choices, the wording you agreed to and the time. We keep this on our own server in Finland, and add it to a "Library" list in our customer records system, Attio. If you register, Attio also records that you are a member.

7. Who we share your information with #

We share your information only in these cases:

• Service providers. Companies that run services for us under contract. They may use your data only to provide their service to us:
• Hetzner Online GmbH, which rents us the server in Helsinki, Finland, that runs our website, forms, library and Rulio.
• Attio Ltd, our customer records system, hosted on Google Cloud. It holds Talk to us enquiries and the "Library" list.
• Resend (Plus Five Five, Inc., US), which sends our emails, including the Halden email and library emails.
• Clerk, Inc. (US), our sign-in service, and Cloudflare, which protects Clerk's sign-in service from bots.
• Google Ireland Limited (Google Analytics) and PostHog Inc. (PostHog EU Cloud, Frankfurt), only if you accept analytics cookies.
• LinkedIn Ireland Unlimited Company (Insight Tag), only if you accept marketing cookies. LinkedIn acts as a joint controller for some Insight Tag data.
• Google (Google Workspace Shared Drive), where we keep our encrypted backup copies, in our own account.
• Advertising platforms. If you accept marketing cookies, Google (Google Ads) and LinkedIn receive data about your visit, and use it to show our ads and to build our audiences. For Google, this includes hashed contact details (section 3). Each uses it under its own privacy policy.
• OpenAI. When you ask Rulio a question, OpenAI OpCo, LLC (US) receives the content described in section 6a and processes it as an independent controller, under its own privacy policy.
• Legal requirements. When the law, a regulator or a court requires it.
• Business transfers. If we are involved in a merger, sale, financing or acquisition.
• With your consent. When you have asked us to, or agreed.

We may also share aggregated or de-identified information that cannot reasonably identify you.

8. International transfers #

Some of our service providers process data outside the UK, including in the United States. When that happens, we rely on the UK Extension to the EU-US Data Privacy Framework if the provider is certified. Otherwise we use the UK Addendum to the EU standard contractual clauses, or the ICO International Data Transfer Agreement.

Our server, with our website, forms, library and Rulio, is in Helsinki, Finland. PostHog stores our data in its EU Cloud in Frankfurt, Germany. UK law treats data protection in the EU as adequate, so storage there needs no extra safeguard. PostHog Inc. is a US company, and any access from the US is covered by its data processing agreement.

Google and LinkedIn may process advertising data in the United States. Google may also process our encrypted backup copies outside the UK, including in the United States. Clerk and Resend are US companies and may process your data in the United States. OpenAI OpCo, LLC is a US company and processes the content of your Rulio questions in the United States.

You can ask us for a copy of the safeguards we use at privacy@covianalytics.com.

9. How long we keep your information #

We keep personal data only as long as we need it for the purposes in this policy:

• Talk to us messages. 2 years from our last contact with you, unless you become a client. This covers our customer records system and our own backup of form entries.
• Where an enquiry came from. The campaign tags, search term, referrer, landing page and click IDs stored with an enquiry. We keep them for as long as the enquiry itself.
• Halden sign-ups you never confirm. If you do not click the confirmation link, we delete the sign-up after 7 days.
• The Halden list. Until you unsubscribe, or 2 years after you confirmed, whichever comes first.
• Halden confirmation record. The time you confirmed, with your IP address, browser details and network name. 2 years in our live records from when you confirmed, even if you unsubscribe sooner. Copies in our backups leave within about 6 months. It is our proof that you agreed.
• Library updates. Until you unsubscribe, or 3 years after you subscribed or last confirmed, whichever comes first.
• Google Analytics data. 14 months.
• PostHog data. Session recordings stay on PostHog for 30 days. We keep other PostHog data for no longer than 14 months.
• The covi_ft cookie. 90 days in your browser.
• Advertising audiences. Lists we use to show ads keep you for up to 90 days on Google and up to 180 days on LinkedIn. Google lists we use only to exclude people, or as a starting point for other lists, keep you for up to 540 days. Withdrawing marketing consent stops your visits adding you to them.
• Hashed contact details sent to Google. Google holds them under its own privacy policy. Turning marketing cookies off stops new codes being sent.
• LinkedIn Insight Tag data. LinkedIn removes members' direct identifiers within 7 days, and deletes the remaining Insight Tag data within 180 days.
• Your account. Until you delete it.
• Pinned items, lists, notes and your team choice. Until you delete them, or delete your account.
• Rulio question logs. Up to 90 days. Then we delete the question, the reply and the hashed IP, and keep only counts and costs, with no question text.
• Copies kept by the software that connects to OpenAI. Deleted within 90 days.
• Your anonymous Rulio session. Deleted 30 days after you last use it.
• Clerk. Until you delete your account. After that, as set by Clerk's data processing terms.
• Library access and choices. While your access lasts, plus 24 months. Requests you never confirm are deleted after 7 days.
• The "Library" list in Attio. 2 years from our last contact with you.
• The cv_lib cookie. 90 days in your browser.
• Backups. The newest copy from each of the last 7 days, 5 weeks and 6 months. Backups of PostHog session recordings: at most 90 days. Data you ask us to delete leaves our live systems straight away, and leaves the backups within about 6 months. We do not edit backups, and we use them only to restore our service.
• Server access logs. About 14 days.
• Legal and business records. As the law and our legitimate business needs require.

10. Your rights under UK data protection law #

You have these rights over your personal data:

• Access. Ask for a copy of the personal data we hold about you.
• Rectification. Ask us to correct data that is wrong or incomplete.
• Erasure. Ask us to delete your data in certain circumstances. This covers the copies in our customer records system and our email tool.
• Restriction. Ask us to limit how we use your data in certain situations.
• Data portability. Receive your data in a portable format.
• Object. Object to how we use your data, including for direct marketing.
• Withdraw consent. Where we rely on consent, withdraw it at any time. For the Halden email and library updates, use the unsubscribe link. For cookies, use "Cookie settings" in the footer.

You can ask us to stop contacting you for feedback at any time, with the link in any feedback email or by emailing us. Because feedback contact is a condition of library access, your library access then ends.

You can delete your account yourself in Rulio (section 6a). For a copy of your data, or to use any other right, email privacy@covianalytics.com. We will respond within one month.

You can also complain to the Information Commissioner's Office (ICO) at ico.org.uk.

11. Marketing preferences #

You can unsubscribe from any marketing email with the link at the bottom, or by emailing privacy@covianalytics.com. Creating an account does not sign you up for marketing emails.

12. Cookies and your choices #

When you first visit, our cookie banner asks whether to allow analytics and marketing cookies. "Accept all", "Reject all" and "Choose" sit side by side, with equal weight. "Choose" lets you turn analytics and marketing cookies on or off one by one. Strictly necessary cookies are always on, because the site needs them to work.

You can change your choice at any time through "Cookie settings" in the footer of any page. You can also block or delete cookies in your browser settings, though some parts of the site may then not work as expected.

If you open a library item, we set a strictly necessary cookie, cv_lib, that remembers your access for 90 days. If you sign in for the full library, Clerk's sign-in cookies apply on our website too.

Rulio, at rulio.covianalytics.com, uses only strictly necessary cookies: its own session and security cookies, Clerk's sign-in cookies, and the bot protection cookies Cloudflare sets for Clerk. It runs no analytics or advertising tags, so it does not ask for cookie consent.

Our cookie policy lists every cookie and tag we use. Advertising and audience tags run only under marketing cookies, never under analytics cookies alone.

13. Security #

We use appropriate technical and organisational measures to protect personal data from unauthorised access, change, disclosure or destruction. No internet transmission is completely secure.

14. Children's privacy #

Our website, Rulio and the library are for business use. They are not intended for anyone under 18. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will delete it.

15. Social sharing and links #

Our website may include buttons that let you share pages on social media, and links to other sites. If you use them, the social media provider or other site may collect information about you under its own privacy policy. Please check their policies.

16. Changes to this policy #

We may update this policy from time to time. When we do, we will change the date at the top. Where the change matters, we will also tell you on our website or by email.

Questions about this policy? #

Email: privacy@covianalytics.com
Address: Context Visualised Limited, 3 Lloyd's Avenue, London EC3N 3DS
ICO registration: ZA555645