Privacy Policy for 'talk.digerty.com' · Digerty

Effective Date: April 1, 2025

1. Introduction

Welcome to talk.digerty.com (the ‘Service’), the official comment system and community forum for the digerty.com digital magazine. This Service is operated by NAKARMA LTD (‘we’, ‘us’, ‘our’), a company registered in Hong Kong.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Service (talk.digerty.com). This policy applies only to the Service located at talk.digerty.com and does not apply to the main digerty.com website or any other services, which may have their own separate privacy policies.

We are committed to protecting your personal data and respecting your privacy. Please read this Privacy Policy carefully. By using the Service, you agree to the collection and use of information in accordance with this policy. If you do not agree with the terms of this privacy policy, please do not access or use the Service.

2. Data Controller

The data controller responsible for your personal data under this Privacy Policy is:

NAKARMA LTD Hong Kong Contact Email for Privacy Matters: [email protected]

3. Information We Collect

We may collect personal data about you in a variety of ways when you use the Service. The types of personal data we may collect include:

Account Information:
- Username (publicly visible)
- Email address (kept private, used for account management and notifications)
- Password (stored securely using hashing; never stored in plain text)
- Optional profile information you choose to provide (e.g., display name, biography, avatar) (publicly visible if provided)
Content and Activity Data:
- Posts, comments, and messages you submit to the Service (public posts/comments are visible to others, including federated instances)
- Votes (upvotes/downvotes) you cast on content
- Communities you subscribe to
- Content you save
- Reports you submit about content or users
- Private messages sent or received via the Service (if this feature is enabled)
Technical and Usage Data:
- IP address (collected during registration, login, and when posting content, primarily for security, moderation, and troubleshooting purposes)
- Log data, which may include information such as your device’s Internet Protocol (‘IP’) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other diagnostic data.
- Information collected via Cookies (see Section 10).

4. How We Use Your Information

We use the information we collect for purposes compliant with applicable data protection laws, including Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) and the UK General Data Protection Regulation (UK GDPR). These purposes include:

To Provide and Maintain the Service: Operating the forum, displaying content, facilitating user interaction (comments, posts, votes), managing user accounts.
To Manage Your Account: Sending necessary administrative communications (e.g., password resets, important service updates).
To Improve the Service: Analyzing usage patterns (often in aggregated, non-identifiable form) to understand how the Service is used and identify areas for improvement.
For Security and Moderation: Monitoring for suspicious activity, preventing spam, enforcing our Terms of Service, investigating violations, protecting the rights and safety of users and the public. IP addresses and activity logs are crucial for this purpose.
To Comply with Legal Obligations: Responding to lawful requests from authorities, court orders, or legal processes under applicable law (including Hong Kong and UK law).

Our legal basis for processing your data typically includes the necessity to perform the service you requested (i.e., provide the forum functionality), our legitimate interests (e.g., security, service improvement), compliance with legal obligations, and potentially your consent for optional data or activities.

We do not sell your personal data. We may share your information in the following circumstances:

Public Content and Federation: Your username and any public content you post (comments, posts in public communities) are inherently public and will be visible to other users of the Service. Crucially, because talk.digerty.com uses the Lemmy software, public posts and comments may be shared (‘federated’) with other independent Lemmy instances across the internet. We do not control these other instances.
Service Providers: We may share necessary information with third-party vendors and service providers who perform services on our behalf, such as website hosting (currently Vultr, with servers located in the UK), data storage, security monitoring, or email delivery. These providers are obligated to protect your data and use it only for the purposes we specify.
Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency) in accordanceance with applicable law, including the laws of Hong Kong and the UK.
Protection of Rights: We may disclose information where we believe it necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person, illegal activities, or as evidence in litigation.
Business Transfers: If NAKARMA LTD is involved in a merger, acquisition, or asset sale, your personal data may be transferred as part of that transaction, subject to confidentiality agreements and notice where required by law.

6. Data Processing Location and International Transfers

NAKARMA LTD is a company based in Hong Kong. However, the primary servers used to host and operate the talk.digerty.com Service are located in the United Kingdom (UK).

Therefore, when you use the Service, your personal data will be transferred to and processed primarily in the UK. By using the Service, you consent to this transfer and processing.

We ensure that such transfers and processing comply with applicable data protection laws. This includes compliance with:

Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) regarding the responsibilities of the data controller.
The UK General Data Protection Regulation (UK GDPR) regarding the processing activities occurring within the UK.

If you are accessing the Service from other regions, please be aware that your data is being processed in the UK under these legal frameworks. Furthermore, as noted in Section 5, public content may be federated globally to other Lemmy instances outside of our control.

7. Data Security

We implement reasonable administrative, technical, and physical security measures designed to protect your personal data processed on servers located in the UK from unauthorized access, use, alteration, or disclosure. This includes measures like using HTTPS encryption for data transmission and hashing passwords. However, please be aware that no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against interception or misuse. We cannot guarantee the absolute security of your personal data.

8. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by applicable law (including HK PDPO and UK GDPR).

Account Information: Retained for as long as your account is active, and for a reasonable period thereafter to allow for account recovery or to comply with legal obligations.
Content Data (Posts, Comments): May be retained indefinitely as part of the public forum record, unless deleted by you (where possible) or by administrators/moderators in accordance with our Terms of Service. Note that due to federation, copies may persist on other instances even after deletion on our Service.
Log Data (IP Addresses, etc.): Typically retained for a limited period (e.g., 90-180 days) for security, troubleshooting, and analysis purposes, after which it may be deleted or anonymized, unless required for ongoing investigations or legal reasons.

Depending on your location and applicable law (primarily Hong Kong PDPO and UK GDPR), you may have certain rights regarding your personal data:

Right of Access: You may have the right to request access to the personal data we hold about you.
Right to Correction (Rectification): You have the right to request correction of inaccurate or incomplete personal data. You can often update your account information directly through your profile settings.
Right to Erasure (Deletion): You may have the right to request the deletion of your personal data, subject to certain exceptions (e.g., where retention is necessary for legal compliance or maintaining the public record of the forum). Account deletion can typically be requested.
Right to Restrict Processing: You may have the right to request the restriction of processing of your personal data under certain conditions (especially under UK GDPR).
Right to Object to Processing: You may have the right to object to our processing of your personal data under certain conditions (especially under UK GDPR, e.g., processing based on legitimate interests).
Right to Data Portability: You may have the right to request the transfer of the data that we have collected to another organization, or directly to you, under certain conditions (especially under UK GDPR).

To exercise these rights, please contact us using the details provided in Section 2. We may need to verify your identity before processing your request. If you are unsatisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority (e.g., the Privacy Commissioner for Personal Data in Hong Kong, or the Information Commissioner’s Office (ICO) in the UK).

10. Cookies and Tracking Technologies

Consistent with our commitment to digital liberty, we do not use cookies or similar technologies for tracking, analytics, advertising, or other non-essential purposes on the Service (talk.digerty.com).

However, the underlying Lemmy software, like most web applications requiring user accounts, may use essential cookies that are strictly necessary for the basic functionality of the Service. This typically includes session cookies required to keep you logged in as you navigate the site. These functional cookies do not track your activity across different websites and are fundamental to providing a usable logged-in experience.

You can usually configure your browser to block cookies, but please be aware that blocking essential functional cookies will likely prevent you from logging into and using core features of the Service.

11. Children’s Privacy

The Service is not intended for use by individuals under the age of eighteen (18). We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18 without verification of parental consent where required, we will take steps to remove that information from our servers. If you believe that we might have any information from or about a child under 18, please contact us.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the ‘Effective Date’ at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the Service after the posting of changes constitutes your acceptance of such changes.