Privacy Policy
This Privacy Policy explains how I, Ivan Khokhlov ("I", "me"), handle personal data when you visit ivankhokhlov.com, subscribe to my newsletter, or email me. I process personal data only as described here, in line with the Swiss Federal Act on Data Protection (nDSG) and, where applicable, the EU General Data Protection Regulation (GDPR).
I am the controller for this data. You can reach me at hello@ivankhokhlov.com.
1. What data I collect and why
Newsletter. If you subscribe, I collect and store your email address for the sole purpose of sending you the newsletter. The legal basis is your consent (Art. 6(1)(a) GDPR / nDSG). Signup is double opt-in: after you submit the form you get a confirmation email, and nothing is sent to you until you click the link in it. An unconfirmed address is stored only so the confirmation can be matched, and you can withdraw your consent at any time (see Section 4). Emails are sent through Amazon SES in the EU (Frankfurt).
Email to me. If you write to hello@ivankhokhlov.com or ivan@ivankhokhlov.com, your message, your email address and any attachments are received through Amazon SES and stored so I can read and reply. The legal basis is my legitimate interest in answering correspondence (Art. 6(1)(f) GDPR), or the performance of a contract where one applies.
Spam protection. The newsletter form is protected by Cloudflare Turnstile, which checks that the submission comes from a person rather than a script. It receives your IP address and basic browser signals for that check. Turnstile is a privacy-preserving alternative to a CAPTCHA: it does not track you across sites and does not build an advertising profile. The legal basis is my legitimate interest in keeping the form usable (Art. 6(1)(f) GDPR).
Analytics. I use PostHog, hosted in the EU, to understand which pages people read. It records page views and basic technical data (browser, screen size, referrer, a truncated IP for coarse country-level location). I do not use it for advertising and I do not sell or share this data. The legal basis is my legitimate interest in understanding what is worth writing (Art. 6(1)(f) GDPR).
Server logs. The hosting provider automatically records standard technical data — IP address, browser type, the pages requested, the time of access — to operate and secure the site. The legal basis is my legitimate interest in a secure, functioning website (Art. 6(1)(f) GDPR).
2. Third-party content
Web fonts. The site loads Merriweather and Merriweather Sans from Google Fonts. When a page loads, your IP address is transmitted to Google so the font files can be served. This is used only to deliver the fonts. Google's handling of data is governed by its own privacy policy: https://policies.google.com/privacy
There are no embedded videos, no social-media widgets, and no advertising scripts on this site.
3. Where your data is stored
Newsletter subscriptions, inbound email and analytics are stored on infrastructure in the European Union (Frankfurt, Germany). Some technical data reaches providers outside the EU/EEA — Cloudflare for spam protection, Google for fonts, and the hosting provider's edge network. Those transfers are governed by the providers' own safeguards, including the EU Standard Contractual Clauses.
4. Your rights
You have the right to access the personal data I hold about you, to have it corrected or deleted, to restrict or object to its processing, and to data portability. Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of earlier processing.
To unsubscribe from the newsletter, use the link at the bottom of any email I send you — it works with one click and needs no account. To exercise any other right, email hello@ivankhokhlov.com. If you believe I have handled your data unlawfully, you may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local supervisory authority.
5. How long I keep data
I keep your newsletter email address until you unsubscribe or ask me to delete it; an unconfirmed subscription is deleted after 30 days. Email correspondence is kept as long as it is useful for the conversation and any follow-up. Analytics data and server logs are kept only as long as needed for security and operational purposes, then deleted or anonymised.
6. Cookies
This site sets no tracking or advertising cookies. PostHog stores a first-party identifier in your browser so repeat visits are not counted as new people; Cloudflare Turnstile may set a short-lived token while it verifies a form submission. If you sign in to the private admin area — which only I can do — a session cookie is set for that purpose.
7. Changes to this policy
I may update this Privacy Policy from time to time. The current version is always available on this page, with the date of the last update shown above.
8. Contact
For any questions about this Privacy Policy or your data, email hello@ivankhokhlov.com.