Important clarification — we collect no personal data.
This is a fully static personal blog. We do not use cookies, analytics, trackers, forms, logins, or any other technology that collects or stores personal data. The only data processed are transient server logs handled automatically by our hosting provider (Cloudflare Pages) for delivery and security purposes only.
This Privacy Policy explains how Frith Hilton (“we,” “us,” or “our”) processes the personal data of visitors (“you” or “user”) to our personal blog website, https://www.frithhilton.name.ng (the “Website”). We are committed to protecting your privacy in compliance with the European Union’s General Data Protection Regulation (GDPR).
1. Who We Are (Data Controller)
The data controller responsible for the processing of personal data collected through this Website is:
- Name: Howard Frith Hilton
- Website Address: https://www.frithhilton.name.ng
- Contact Email: privacy@frithhilton.name.ng
2. Data Processing and Purpose
2.1 We Process and Purpose (Art. 13)
Since this is a personal blog with static content, we collect very limited data directly. However, data is collected through automated means by our hosting provider.
| Category of Data | Purpose of Processing | Legal Basis for Processing (GDPR Art. 6) | Retention Period |
|---|---|---|---|
| Server/Usage Data (IP address, browser type, pages visited, device info, request time) | Service Delivery, Security, and DDoS Protection (Collected by Cloudflare Pages to deliver content and ensure network security) | Legitimate Interest (Art. 6(1)(f)) – Ensuring the stability, quality, and security of the Website and network | Raw logs: Processed transiently and deleted within hours to 7 days (default for enabled Logpush retention; otherwise, not retained long-term). Aggregated/anonymized analytics: Indefinitely for service improvement, but de-identified. Data is deleted or pseudonymized once no longer needed for security/delivery. Users can request deletion if identifiable. |
| Contact Data (Email address, name – if you use a contact form or send a direct email) | To respond to your inquiries, comments, or requests for permission to use content | Consent (Art. 6(1)(a)) – When you explicitly submit a form or email us | Until the query is resolved (typically 30–90 days for active support), plus up to 6 years for legal record-keeping if related to contracts/disputes. Deleted immediately upon user request or when no longer necessary. |
2.1 Cloudflare as Data Processor
This Website is hosted on Cloudflare Pages. Cloudflare acts as a data processor on our behalf and processes end-user data only according to our instructions and the Cloudflare Data Processing Addendum (DPA). You can view Cloudflare’s privacy practices here
3. Cookies and Tracking Technologies
3.1 Essential Cookies (Necessary)
We may use temporary or permanent cookies that are strictly necessary for the technical operation of the Website (e.g., maintaining security, managing dark mode preference). These are essential for the service and do not require your consent.
3.2 Analytical/Performance Cookies (Requires Consent)
We may use third-party services, such as Google Analytics (or similar tools), to collect Usage Data. These services place cookies on your device to analyze how you use the Website.
- Requirement: Since these cookies are not strictly necessary for the service, we will only deploy them if you provide explicit consent via our Consent Management Platform (CMP).
- Opt-Out: You have the right to decline these cookies via our CMP, or you can adjust your browser settings to refuse cookies entirely.
4. Third-Party Data Sharing (Recipients)
We do not sell your personal data. Your data may be shared with the following third parties who act as Data Processors on our behalf, solely for the purposes outlined in Section 2:
-
Hosting Provider: Cloudflare Pages – Processes your IP address to deliver the Website content.
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Third-Party Links (Book Sales): The Website contains links to external platforms where books can be purchased or read (e.g., Paystack, Amazon, external publishers). When you click these links, you leave our Website. We are not responsible for the data processing practices of these third parties. Please consult their respective privacy policies.
5. International Data Transfers (Art. 44)
The data collected through this Website is processed and stored using Cloudflare Pages, a global content delivery network (CDN). While Cloudflare maintains data centers worldwide (including within the European Economic Area (EEA)), data may be replicated, cached, or processed across borders to ensure performance, security, and availability. This can involve transfers to servers outside the EEA, including to the United States (where Cloudflare is headquartered).
To protect your personal data during any international transfers, we rely on Cloudflare’s robust safeguards as our data processor, including:
- EU-U.S. Data Privacy Framework (DPF): Cloudflare is certified under the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, providing an adequate level of protection for transfers to the U.S. as recognized by the European Commission.
- Standard Contractual Clauses (SCCs): For transfers not covered by the DPF, Cloudflare uses the European Commission’s SCCs, supplemented by additional technical and organizational measures (e.g., encryption in transit and at rest) to ensure GDPR-equivalent protection.
- Data Localization Suite: Where required, we can configure services to restrict data processing to specific regions (e.g., EEA-only for sensitive workloads), though this is not enabled by default for Cloudflare Pages.
Cloudflare acts as our data processor under a Data Processing Addendum (DPA), and we instruct them to process data only as necessary for service delivery. For more details, refer to Cloudflare’s GDPR and Privacy Policy.
6. Your Rights Under GDPR (Art. 12-22)
Under the GDPR, you have the following rights concerning your personal data:
| Right | Description |
|---|---|
| Right to be Informed (Art. 12) | The right to be informed about how your data is processed (fulfilled by this Policy). |
| Right of Access (Art. 15) | The right to request a copy of the personal data we hold about you. |
| Right to Rectification (Art. 16) | The right to have inaccurate or incomplete personal data corrected. |
| Right to Erasure (‘Right to be Forgotten’) (Art. 17) | The right to request that we delete your personal data under certain conditions (e.g., the data is no longer necessary). |
| Right to Restriction of Processing (Art. 18) | The right to limit the way we use your data. |
| Right to Data Portability (Art. 20) | The right to receive your personal data in a structured, commonly used, and machine-readable format. |
| Right to Object (Art. 21) | The right to object to the processing of your data based on legitimate interest or for direct marketing purposes. |
| Right to Withdraw Consent (Art. 7) | Where processing is based on consent, you have the right to withdraw that consent at any time. |
6.1 Exercising Your Rights
To exercise any of these rights, please contact us at privacy@frithhilton.name.ng. We will respond to your request within one calendar month.
6.2 Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or the place of the alleged infringement, if you believe that the processing of your personal data infringes the GDPR.
7. Security Measures (Art. 32)
We take the security of your data seriously. We have implemented appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. This includes using SSL encryption for data transmission and secure server hosting.
8. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version will always be posted on this page, indicated by the “Effective Date” at the top. We encourage you to review this Policy periodically.
Last updated: Tuesday, December 2, 2025