Privacy Policy

Unit 09-1
Who is responsible, and what this covers

This policy is issued by Haubergson Invest s.r.o., Litevská 1174/8, Vršovice, 100 00 Praha 10, Czech Republic, company registration 02059312, contactable at info@mutelocus.online. Haubergson Invest s.r.o. publishes the website mutelocus.online and decides what happens to the small amount of personal information the site involves.

It covers mutelocus.online and nothing else. The course links to other websites — the affiliate link to the game used as the worked example, and the Australian government sites named in the steps. Once you follow any of those links you are on somebody else's website, governed by their own privacy notice, not this one.

Personal information is handled in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. The principles themselves are published by the Office of the Australian Information Commissioner at oaic.gov.au/privacy/australian-privacy-principles, and the sections below walk through all thirteen of them in order, saying what each one means on this particular site.

Unit 09-2
The thirteen principles, one at a time

APP 1 — Open and transparent management

This policy is the whole of our practice, written in plain language, reachable from the footer of every page and from the navigation. Nothing is held back for an internal document. If something here is unclear, write to info@mutelocus.online and we will explain it or rewrite it.

APP 2 — Anonymity and pseudonymity

You can read every page of this course without identifying yourself in any way. There is no sign-in, no account and no profile. If you email us, you may do so from a pseudonymous address and we will answer it — the single exception is a request for access to or correction of personal information, where we need enough information to be sure we are dealing with the right person before we release anything.

APP 3 — Collection of solicited personal information

We ask for nothing. There is no form, no newsletter box, no quiz, no telephone field and no progress tracking anywhere on this site. The only personal information that reaches us does so in two ways:

• Server access logs, kept by our hosting provider as a normal part of serving a website. A log entry contains your IP address, the date and time, the URL requested, the referring page if your browser sends one, and your browser's user-agent string.
• Email you send us, which contains your email address, any name you choose to give, the content of your message and any attachment.

Nothing else is collected. There are no cookies, no web storage, no analytics, no advertising tags, no web fonts, no profiling and no cross-site tracking, and the site requests nothing from any other server when a page loads.

APP 4 — Dealing with unsolicited personal information

Sometimes an email contains information we did not need in order to reply — details about other people, documents attached for context, an account number. Where it is lawful and reasonable to do so, we delete that material rather than keep it. If we cannot lawfully destroy it, it is treated under the rest of this policy exactly as if we had asked for it.

APP 5 — Notification of collection

This section is the notification. Access logs are created by the server when you request a page; you are told here because there is no other moment at which we could tell you. If you email us, the fact that we hold your message and reply from it should be obvious, and this policy records how long we keep it and why.

APP 6 — Use and disclosure

Access logs are used to keep the site available, to investigate abuse such as attempts to break in or flood the server, and to diagnose faults. Email is used to reply to you and to keep a record of the exchange. Neither is used for anything else. We do not sell, rent, trade or share personal information for marketing, we do not build profiles, and we disclose information to an authority only where Australian law requires it of us.

APP 7 — Direct marketing

We do not do direct marketing at all. There is no mailing list to join, no course reminder, no re-engagement email and no newsletter. If you write to us, you get a reply to what you wrote and nothing after it.

APP 8 — Cross-border disclosure

Two recipients handle personal information for us and there are no others: our hosting provider, which holds the access logs, and our email service provider, which holds the mailbox. Both may store or process data outside Australia; we are not naming a country here because we will not state a location we cannot keep accurate. Haubergson Invest s.r.o. is itself established in the Czech Republic, so correspondence sent to us is read there.

APP 9 — Government related identifiers

No government-related identifier is adopted, used or disclosed by this site. We never ask for one, and there is nowhere on the site to enter one.

APP 10 — Quality of personal information

The only personal information we could hold about you is what you wrote to us and what your browser sent to the log. If something we hold about you is wrong, tell us and we will correct it.

APP 11 — Security

The site is served over HTTPS. There is no database, no content management system and no stored form submissions, because there are no forms — which removes most of the ways a small site loses data. The hosting account and the mailbox are protected by access controls and are reachable only by people working for Haubergson Invest s.r.o. We hold no certification and claim no security standard beyond this plain description of what exists.

APP 12 — Access

You may ask what personal information we hold about you. Email info@mutelocus.online with "Privacy request" in the subject line. There is no charge for making the request, and we reply within 30 days. In practice the answer is usually either the email thread you already have or, if you can identify the relevant log entries, the log lines themselves before they are deleted.

APP 13 — Correction

You may ask us to correct personal information we hold. Use the same address and the same subject line. We reply within 30 days, and if we decline to make a correction we will tell you why in writing.

Unit 09-3
How long we keep things

Access logs are kept for 30 days and then deleted. Email is kept for 24 months after the last message in the conversation, and then deleted, unless it is needed in connection with a legal claim, in which case it is kept until that matter ends.

Unit 09-4
Affiliate links

Some links on this site are paid affiliate links to the game used as the worked example in the course. When you follow one, you leave mutelocus.online. From that point the destination — the game's own site, and the affiliate network that operates the link — may set cookies or use similar technology on their own domains to record that the referral came from us, under their own privacy policies rather than this one.

What comes back to Haubergson Invest s.r.o. is a commission report from the network: counts and amounts. We use those reports only to reconcile what we are paid. We do not ask the network for information that would identify a reader, and we have no way of connecting a commission to a person who read this site.

Unit 09-5
Complaints

If you think we have mishandled your personal information, write to info@mutelocus.online with "Complaint" in the subject line. We will answer within 30 days. If you are not satisfied with the answer, you can complain to the Office of the Australian Information Commissioner, which explains the process at oaic.gov.au/privacy/privacy-complaints.

Unit 09-6
Data breaches

If we have reason to believe personal information we hold has been accessed or disclosed without authorisation, or lost, we assess it promptly. Where serious harm to anyone is likely, we notify the affected people and the Office of the Australian Information Commissioner in line with the Notifiable Data Breaches scheme.

Unit 09-7
Children

This course is written for adults and is not directed at people under 16. We do not knowingly collect personal information from children, and since the site has no forms, no accounts and no cookies, there is nothing here designed to identify anyone of any age.

Unit 09-8
Readers in the EU, the EEA and the UK

Haubergson Invest s.r.o. is established in the Czech Republic, so the General Data Protection Regulation applies to our handling of personal information as well.

Our legal basis for keeping server access logs is legitimate interests: keeping the site available and secure, which cannot be done without them. Our legal basis for handling email is that it is necessary to respond to the enquiry you have made of us. We rely on consent for nothing, because there are no cookies, no tracking and no marketing to consent to.

Where the GDPR applies to you, you have the rights of access, rectification, erasure, restriction of processing, data portability and objection, including objection to processing based on legitimate interests. Exercise them by emailing info@mutelocus.online. You may also lodge a complaint with the Czech supervisory authority, the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), at uoou.gov.cz.

Unit 09-9
Changes to this policy

When this policy changes, the effective date at the top is updated. Where a change is material — a new recipient, a new category of information, a different retention period — a short note saying so is displayed at the top of this page for 30 days from the date of the change.

Unit 09-10
How to reach us

Email info@mutelocus.online, or write to Haubergson Invest s.r.o., Litevská 1174/8, Vršovice, 100 00 Praha 10, Czech Republic. Company registration 02059312.