Privacy policy

The controller under the General Data Protection Regulation (GDPR) is the publisher of The Phangan Edit:

We have not appointed a data protection officer. Please send any question about your data to the e-mail address above.

In short

• No cookies, and nothing is stored in your browser (no local storage).
• No analytics, advertising or social media scripts, no external fonts, maps or videos. Every file of a page comes from phanganedit.com.
• When you follow a link to a villa’s website, we count the click without your IP address and without any identifier.

Hosting and delivery of the pages

The site is hosted by Cloudflare, Inc. (USA) on its Workers platform. When you open a page, your browser sends technical data, as it does with any website: your IP address, the address of the requested page, date and time, browser type and version (user agent) and the referring page. Cloudflare processes this data on our behalf (Art. 28 GDPR) to deliver the page and to protect the site against attacks and misuse. We do not keep our own log of page views. Cloudflare keeps this data only as long as it needs it for delivery and security, under its data processing terms.

Cloudflare also asks browsers that support Network Error Logging to report failed connections to our site to Cloudflare (a.nel.cloudflare.com). Such a report contains the page address and the type of error and is sent from your IP address. Cloudflare uses it to find network problems.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a website that works and is secure.

Cloudflare may process data in the USA. Cloudflare, Inc. is certified under the EU-U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Art. 45 GDPR).

Clicks to villa websites

Links to a villa’s offer (for example “Check availability”) go through an address of ours, phanganedit.com/go/…, which forwards you straight away to the villa’s own website or, if it has none, to its listing on Airbnb. For each such click we record the date and time, the villa, the position of the link on our site, the path of our page you came from (or only “external” or “direct”) and the country, which Cloudflare derives from your IP address. We do not store your IP address, your browser type, a cookie or any other identifier, so a click cannot be linked to you. The records are kept in Cloudflare Workers Analytics Engine, which deletes them automatically after about 3 months. We may keep monthly totals derived from them (number of clicks per villa, link position, page and country), which describe no single click, for as long as we need them to compare months. We use the records to see which pages and links are useful.

The forwarded link carries the parameters utm_source=phanganedit, utm_medium=referral, utm_campaign (position of the link) and utm_content (path of our page), so that the target website (the villa’s site or Airbnb) can see that the visit came from The Phangan Edit. What the target website then does with your visit is governed by its own privacy policy. These parameters contain no data about you.

Our Worker keeps no request log: the per-request entries of Cloudflare Workers Logs (with IP address, browser type and approximate location) are switched off. Workers Logs keeps only error messages of our code, which we use to find errors, and deletes them automatically after at most 7 days.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is knowing which content readers find useful.

Cookies and your device

This site sets no cookies and uses no local storage, session storage or similar technology. Filters in the villa catalogue are kept only in the page address. We do not store information on your device and do not access information stored on it beyond what is strictly necessary to show you the page you asked for (Art. 399 of the Polish Electronic Communications Law and § 25(2) no. 2 of the German TDDDG). That is why there is no cookie banner.

Fonts, images and maps

Fonts, images and the island map are served from phanganedit.com. We draw the map ourselves; no external map service is loaded. While it shows our pages, your browser therefore connects to no server other than phanganedit.com, apart from the error reports to Cloudflare described above (Network Error Logging).

E-mail

When you write to redakcja@phanganedit.com, Cloudflare Email Routing forwards your message to a mailbox at Google (Gmail), where we read and answer it. We process your e-mail address, your name if you give it, and the content of your message in order to reply. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in answering messages. Writing to us is voluntary; without your e-mail address we cannot reply.

Recipients of the message are Cloudflare (Email Routing, see above) and Google, the provider of the mailbox (Google Ireland Limited, Ireland, and Google LLC, USA). Google may process the message in the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework, for which the European Commission has adopted an adequacy decision (Art. 45 GDPR).

We delete the correspondence 12 months after the matter is closed, unless we need it longer to establish, exercise or defend legal claims.

Links to other websites

Our pages link to villa websites, booking platforms, maps and sources. When you follow such a link, the privacy policy of the other website applies. Apart from the parameters described above for links to villa websites, other websites receive from us at most our domain name as the referring page (Referrer-Policy: strict-origin-when-cross-origin), not the address of the page you were reading.

No automated decisions

We make no automated decisions and create no profiles.

Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), and data portability (Art. 20). Write to us at redakcja@phanganedit.com. Click records contain nothing that identifies you, so we cannot attribute them to you (Art. 11 GDPR).

You also have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The authority competent for us is the President of the Personal Data Protection Office in Poland (Prezes Urzędu Ochrony Danych Osobowych, PUODO), ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl. You can also turn to the authority in the EU country where you live or work.