Privacy
We keep as little as we can: no real names, no employer names, no advertising, nothing sold.
Who is responsible
The controller of your personal data is:
European Finance Observatory, run by Christian Martorana, a private individual.Email: contact@europeanfinanceobservatory.comFor any privacy request write to support@europeanfinanceobservatory.com.
What we process, why, and on what basis
| Activity | Purpose | Legal basis |
|---|---|---|
| Delivering and protecting the site | Serve pages, stop abuse and limit repeated requests | Legitimate interest, Art. 6(1)(f) GDPR |
| Visit counts | Count visits in aggregate, without cookies | Legitimate interest, Art. 6(1)(f) GDPR |
| Account and sign-in | Sign you in with an emailed link and keep you signed in | Contract, Art. 6(1)(b) GDPR |
| Member profile: role, level, city or country | Show you the right salaries, calculator defaults and news | Contract, Art. 6(1)(b) GDPR |
| Member profile: optional fields | Anonymous community statistics, only if you tick the box | Consent, Art. 6(1)(a) GDPR, withdrawable at any time |
| Friday newsletter | Send the weekly email, ordered for the scope you follow | Consent, Art. 6(1)(a) GDPR, double opt-in |
| Phone notifications | Send at most one notification a day for the scope you follow | Consent, Art. 6(1)(a) GDPR, given by turning them on |
| Questions, corrections and tips | Answer the question of the week and correct the site | Legitimate interest, Art. 6(1)(f) GDPR |
| Notices of illegal content | Handle notices under the Digital Services Act and reply to the notifier | Legal obligation, Art. 6(1)(c) GDPR (DSA Art. 16 and 17) |
| Salary contributions (when the salaries section opens) | Publish pseudonymous salary statistics | Legitimate interest, Art. 6(1)(f) GDPR |
| Encrypted backups | Recover the service after a failure | Legitimate interest, Art. 6(1)(f) GDPR |
Your member profile
Your role, your level (not for students) and your city or country are needed for the member service: personalised salaries, calculator defaults and news (Art. 6(1)(b) GDPR). Every other field is optional, each with "prefer not to say".
The optional fields are used only if you tick "Include my profile in anonymous community statistics", and only for statistics in which no count below 10 people is shown (Art. 6(1)(a) GDPR). You can withdraw this consent in one tap on your account page; you are then left out of the next monthly snapshot. Your profile is never shown individually, never sold and never used for advertising. It is included in your data export and erased when you delete your account.
Newsletter
We store your email address, the subscription status and the scope you follow: a role, a family of roles, or all of European finance. The scope only decides which items come first in the Friday email. You can change it from the "Your role" panel and unsubscribe with the link in every email.
Phone notifications
When you turn on notifications, your browser gives us a subscription: an address at your browser's push service and two encryption keys. We store it with the scope you follow and the date of the last notification. We store no account, no IP address and no device details with it. It is used only to send at most one notification a day about items that touch your scope.
The messages are delivered by the push service of your browser's maker: Apple, Google or Mozilla. We delete the subscription when you turn notifications off, when the push service says it no longer exists, after 5 failed deliveries in a row, or 180 days after the last notification.
How long we keep it
| Data | Kept for |
|---|---|
| Sessions (sign-in) | 30 days at most; 7 days without use; deleted at sign-out |
| Sign-in and confirmation links | 15 minutes, single use |
| Rate-limit keys (a keyed hash of your IP address) | 48 hours |
| Account and member profile | Until you delete your account; the account row is removed 7 days after deletion, with every personal field erased at once |
| Newsletter subscription and its scope | Until you unsubscribe |
| Phone notification subscription and its scope | Until you turn notifications off, the push service reports it gone, 5 deliveries in a row fail, or 180 days after the last notification |
| Questions, corrections and tips | Rejected: 30 days; held: 90 days; used: 365 days |
| Notices of illegal content | As for questions; the optional notifier contact is encrypted and erased 90 days after the decision |
| Contribution quota keys (salaries section) | Until 31 January of the following year |
| Salary contributions (salaries section) | Indefinitely, as pseudonymous statistics |
| Encrypted backups | 30 days |
Who processes it for us
| Processor | What it does | Where | Transfer safeguard |
|---|---|---|---|
| Cloudflare | Hosting, database (EU jurisdiction), security, anti-spam check (Turnstile), visit counts | EU and US | EU-US Data Privacy Framework |
| Resend | Sending emails (sign-in links, confirmations, the newsletter) | US | Standard contractual clauses |
| Anthropic | Automated pre-screening of questions, corrections, tips and notices | US | EU-US Data Privacy Framework or standard contractual clauses |
| Google (Gmail) | The mailbox that receives emails sent to the addresses of the site | US | EU-US Data Privacy Framework |
Automated moderation
Questions, corrections, tips and notices are pre-screened by an AI model (Anthropic) against our published moderation rules. It can allow, hold or reject a text; every hold or rejection comes with the reasons and how to send the text again. No decision with legal or similarly significant effects on you is taken only by automated means: decisions on notices of illegal content are taken by a person.
Salary contributions are pseudonymous
When the salaries section opens, members can add their salary. A contribution stores only role, level, city, employer type, pay and the month, with no account reference, no IP address and no exact time. It is pseudonymous, not anonymous: The application never links a contribution to an account. Linking would require both a secret key held only by the Worker and a copy of the database: the residual risk is an operator who holds both. Database backups are encrypted with a key held offline.
Your rights
You can ask to access, correct, delete or export your data, to restrict its processing, and you can object to processing based on legitimate interest. Where processing is based on consent you can withdraw it at any time, without affecting what was done before. Members can export their data and delete their account themselves from the account page; deletion is immediate.
Write to support@europeanfinanceobservatory.com; we reply within one month. You also have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (UODO, uodo.gov.pl), or with the authority of the country where you live or work.
What the site stores in your browser
These values stay in your browser's local storage and are never sent to us. You can clear them at any time in your browser settings.
| Key | What it holds |
|---|---|
| efo.lens.v1 | The role you chose, so every page puts it first |
| efo.theme | Light or dark theme, if you changed it |
| efo.follow.v1 | The scope you follow and whether you subscribed to the email or notifications |
| efo.app-card.dismissed | That you closed the "on your phone" card |
| efo.recent.v1 | Your recent searches |
| efo.calc.v1 | Your calculator inputs, when the calculator opens |
Cookies
| Cookie | Purpose |
|---|---|
| __Host-efo_session | Keeps you signed in. Set only after you sign in; HttpOnly, Secure, 30 days at most |
| Cloudflare bot management and Turnstile cookies | Protect forms and the site from automated abuse |
There is no cookie banner because the site sets only strictly necessary cookies: nothing for advertising or tracking. Visits are counted with Cloudflare Web Analytics, which uses no cookies.