Last updated: 30 May 2018

The Privacy Policy of this Portal operated by Robert Dragan (“I”, “we”, “us”, “our”), and the separate Terms of Use and Cookie Policy, make up this Portal’s “Terms and Conditions”. By continuing to use this Portal you agree to all of these Terms and Conditions.

1. Overview

This Portal collects Personal Data for the following purposes and using the following services:

Analytics: Google Analytics
Personal Data: Cookies and Usage Data
Commenting: Facebook Comments
Personal Data: Cookies and Usage Data
Managing Contacts and Sending Messages: MailChimp
Personal Data: first name, last name and email address
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies.
Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Portal.
Data Processor
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Subject
An identified or identifiable natural person, meaning someone who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
European Union
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Unless otherwise specified, the Owner of this Portal is the same person or entity as the Data Controller.
Personal Data (or Data)
Any information relating to a Data Subject.
This website and all associated applications and software infrastructure that enable it to collect and process Personal Data.
The service provided by this Portal, including access to the text, images, graphics, logos and other documents on this website.
Usage Data
Information collected automatically through this Portal or third-party services by this Portal, which may include: the IP addresses of the computers utilised by the Users who use this Portal; the features of the browser, device and operating system utilised by the User; the page requested by the User identified through its URI address (Uniform Resource Identifier); various details about the request including the time of the request, the method utilised to submit the request to the server, and the country of origin; information about page visits, including time spent on each page and sequence of visited pages; and information about the server response, including the size of the file received in response and the numerical code indicating the status of the server’s answer (successful outcome, error, etc.).
The individual using this Portal who, unless otherwise specified, coincides with the Data Subject.

3. Owner and Data Controller

Robert Dragan
Postal address
4th Floor Market Chambers
5-7 St Mary St
Cardiff, CF10 1AT
United Kingdom

4. Collection of Personal Data

4.1 General considerations

This Portal collects, directly or through third parties, the following general categories of data: Cookies, Usage Data, first name, last name and email address. In the cases where the Personal Data is collected automatically, the User may have the option to issue a “Do Not Track” request (see 8.3). Sub-sections 4.2 - 4.4 provide details on each type of Personal Data being collected.

Cookies and other tracking software are used to provide the Service, in addition to any other purposes described in this policy and in the Cookie Policy).

4.2 Analytics: Google Analytics

Analytics software enables the Owner to monitor, analyse web traffic and to keep track of User behaviour.

Google Analytics is a web and mobile analytics service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of this Portal and to prepare reports on its activities. Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

Personal Data collected by Google
Cookies and Usage Data
Place of processing
United States
Privacy Policy by Google
Privacy PolicyOpt Out. Privacy Shield participant.

4.3 Commenting: Facebook Comments

Commenting services allow Users to comments on the contents of this Portal.

Facebook Comments is a commenting service provided by Facebook Inc. (“Facebook”) enabling the User to leave comments on pages on this Portal. Facebook may collect User Data, even when the User is not using the commenting system on the page.

Personal Data collected by Facebook
Cookies and Usage Data
Place of processing
United States
Privacy Policy by Facebook
Privacy Policy. Privacy Shield participant.

4.4 Managing Contacts and Sending Messages: MailChimp

Managing Contacts and Sending Messages services make it possible to manage contacts, collect their Personal Data (like email address or name) and to contact those Users.

MailChimp is an email address management and message sending service provided by The Rocket Science Group. MailChimp may track and report on viewing status of messages delivered to the User.

Personal Data collected by MailChimp
First name, last name and email address
Place of processing
United States
Privacy Policy by MailChimp
Privacy Policy. Privacy Shield participant.

User Personal Data is collected to provide its Services, as well as for the following purposes: Analytics, Commenting, Managing Contacts and Sending Messages.

Personal Data may be processed by the Data Controller in one or more of the following circumstances:

  • Consent: Users have given their consent for one or more specific purposes;
  • Contract: provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • Legal obligation: processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

6. Processing of Personal Data

6.1 Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using sound IT infrastructure and organisational procedures for the indicated purpose. In order to provide the Service, identify bugs, communicate with the User or any of the other purposes identified in this policy, the Owner may appoint other people or external parties (including, but not limited to, staff, hosting providers, email providers) as Data Controllers of the Personal Data.

6.2 Place of processing

The Processing of Personal Data is conducted in the operating offices of the third parties specified in section 4, as well as at the operating offices of the Owner and the other places where the Owner may conduct his business from time to time.

6.3 Retention

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.


  • Personal Data collected for legitimate interests of the Owner shall be retained as long as needed to fulfil such purposes.
  • Personal Data collected to fulfill a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data for which the User has given consent may be retained for longer periods of time, until the consent is withdrawn.

7. User rights

Users may exercise certain rights regarding their Personal Data processed by the Owner, including the following:

Access their Data
Users have the right to request access to their Personal Data.
Withdraw their consent
At any time, the User has the right to withdraw consent that was previously granted.
Object to processing of their Data
Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Verify and seek rectification
Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data
Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed
Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller
Users have the right to receive Personal Data they have provided to a controller in a structured, commonly used and machine readable format. They also may request for the Personal Data to be transmitted to another controller.
Contact their data protection authority
Users have the right to bring a claim before their competent data protection authority.

All requests related to these User rights should be directed at the Owner (see section 3), who will respond within one calendar month. Usually, dealing with these requests is free of charge, but for repeated or laborious requests, the User may be asked to pay a small processing fee.

8. Additional information

8.1 Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Portal may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Portal or the related Services.

8.3. How “Do Not Track” requests are handled

This Portal does not support “Do Not Track” requests, but the third party providers identified in section 4 may, so please consult their privacy policies directly.

8.4 Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time. Wherever possible, notice will be given to Users on this page and possibly within this Portal, or by messaging the Users if the relevant Personal Data has been collected.