PRIVACY POLICY

I.What We Hold

1. 1

   The Court holds the particulars given in an application, in a proposal of another’s name, or in a request to be written to when the season opens. Where a name is proposed, the Court writes to the proposer, at the email address given, to acknowledge the proposal and again when it has been considered, and writes to the person proposed only with the proposer’s leave. It holds correspondence with the Secretary, and the ordinary records of a visit to this site. Where known, the page or advertisement that brought an applicant to the Court is recorded with the application. An application also gives the applicant’s title, which the Court uses only to address the applicant correctly, and their date of birth and a telephone number, which the Court uses to consider the application and to arrange a meeting, and for no other purpose than those and the measurement set out in clause 3.

   An email address given to receive The Gazette is used to send The Gazette and, in a scrambled (hashed) form, is also held by Meta as clause 3 sets out; it is kept with no other particulars. It is sent through Resend on the Court’s behalf. Every issue carries a link that ends it; no further issue is then sent, and the address leaves the advertising list when that list is next replaced. The Gazette is separate from a request to be written to when the season opens, and from an application.

   As each of the first two parts of an application is completed, or when the first is left once an email address has been given, and only while Correspondence is kept in Cookie Preferences, the Court keeps everything given so far: from the first part, the title, the names, the email address, the telephone, the text-message choice, the date of birth, the gender and the nationality; from the second, the address, any other cities named and the applicant’s work. The Court also keeps the question last reached and the time spent on each part. It reads the record of the visitor’s cookie choices only to confirm that Correspondence is kept, and does not store it. It is kept so that the Secretary may write at the applicant’s request, and otherwise once, and, where the applicant has agreed, send one text message, should the application not be sent within two days of the last part completed or left. What is kept remains in the Court’s records, whether or not the application is sent, until the applicant uses the erasing link in the Secretary’s letter or asks the Secretary that it be removed. The text message is sent through Twilio, which receives the number and the message alone. Where a text message is sent, the Court keeps the number, the words agreed to and when, as the record of that consent. The telephone number given for a text message, and the consent given for it, are shared with no one but Twilio, which sends the message. No telephone number is shared with third parties or affiliates for marketing or promotional purposes.

   Where Correspondence is kept in Cookie Preferences, the Court notes in the visitor’s own browser which of its pages have been read, and how often. Once the visitor gives an email address in an application, for The Gazette or in the Antechamber, that note is kept by the Court with what they have given. With an application, an unfinished application, an address for The Gazette or a name left in the Antechamber, the Court keeps where the visit came from: the advertisement or address that first and last brought it, the page it began on, and whether it was made on a telephone, a tablet or a computer.

2. 2

   An applicant offered a place gives their full legal name, as it appears on their government ID. Before the membership papers are signed, DocuSign verifies the applicant’s identity using their government ID. DocuSign carries out that check; the Court receives from it the result, and the applicant’s name, date of birth and address, and nothing else. The Court never keeps images of the ID or the ID’s number. The date of birth confirms that the member is twenty-one or older.

3. 3

   A record of a visit to the site and what was done on it, including whether an application, a proposal or a request to be written to was sent; and, in a scrambled (hashed) form, the email address, name, gender, city, state, postcode, country and date of birth given in an application, and the name and email address given in a request to be written to, and the email address given for The Gazette, held by Meta so that it can measure and improve the Court’s advertising and, as set out in section III, show it to people like the Court’s applicants, and governed by Meta’s own policy, unless a visitor has turned it off, or, in the United Kingdom, the European Union and Switzerland, has not chosen it.

4. 4

   Where a visitor arrives from one of the Court’s advertisements on Meta, the click identifier Meta adds to the address is kept in the visitor’s own browser for ninety days, and only while measurement is on, so that an application made in that time is counted against the advertisement. It is passed to Meta with an application, and to no one else; once an application is counted, the Court keeps it, with Meta’s identifier for the visit and the email address in scrambled (hashed) form, so that a meeting or payment that follows within 180 days is counted against the same advertisement. When an application is counted, the Court’s server notes the visitor’s cookie choices as they then stood: which were chosen, when, and under which version of the cookie notice. That note holds nothing that identifies a person, is not passed to Meta, and is kept only in the server’s own working records.

5. 5

   Under the same choice, a count of visits, the pages seen and whether a form on the site, such as an application, a proposal, a card or The Gazette, was begun or sent, held by Google Analytics with no name, email address or city, and with Google signals and ad personalisation turned off. Its cookies last thirteen months. Google sets out its own use of this information in How Google uses information from sites or apps that use our services.

6. 6

   Under the same choice, a record of how the site’s pages are used, held by Microsoft Clarity: where visitors click and scroll, and a record of a visit’s movements on the page, with everything typed into a form masked. It holds no name, email address or other particular, and its cookies last up to a year. Microsoft sets out its own use of this information in the Microsoft Privacy Statement.

7. 7

   The Court photographs and films its engagements, and its photographs and recordings may show members and guests. The Court owns them and uses them as set out in clause 2.5 of the Terms of Membership, summarised in the Terms of Use, including in its publications and its promotion.

8. 8

   A member’s record. For each member, the Court keeps their replies to its invitations, the engagements they attended, the arrangements they asked for, and what they paid the Court. A question put to the Secretary in the members’ rooms is kept with the member’s record, with the time and the page it was asked from, and with the answer. Only the member and the Court see it.

The Court admits no one under twenty-one, as a member or as a guest, and does not knowingly collect the particulars of anyone younger.

II.Why We Hold It

Particulars are held to consider an application, to keep the calendar and its invitations, to answer correspondence, to send The Gazette to those who ask for it, to arrange the engagements a member attends, to keep the season’s record of attendance, to shape the Court’s advertising on Meta where Measurement was kept in Cookie Preferences when an application was sent, as set out in section III, and to keep the Court’s accounts. They are not held for any other purpose. Photographs and recordings of the Court’s engagements are held as set out in section I.

III.Disclosure

The Court does not sell particulars, and does not share a member’s particulars with third parties for advertising. It passes Meta, in a scrambled (hashed) form, the email address, name, gender, city, state, postcode, country and date of birth given in an application, and the name and email address given in a request to be written to, and the email address given for The Gazette, for the measurement and improvement of its advertising, and gives Google Analytics a count of visits with nothing that identifies a person, as set out in section I. Under the same choice, and only then, the Court’s own server sends Meta the same record of an application, so that it is counted once: the same particulars, hashed in the visitor’s browser before they reach the Court, with the address and browser the visit came from, Meta’s own identifiers for the visit, and, where the visit began with one of the Court’s advertisements, its click identifier. Where the Committee has asked to meet an applicant, and only where Measurement was kept in Cookie Preferences when the application was sent, the Court gives Meta the same particulars, hashed in the same way, once a day, in a list from which Meta shows the Court’s advertisements to people like those on it. The list is replaced whole each day, and an applicant is taken off it once offered a place. An applicant who did not keep Measurement is never on it. An applicant may ask the Secretary to be taken off it, and is taken off within a day. Nothing about a person whose name is put forward is passed to Meta or Google. The Court’s photographs and recordings of its engagements are used as set out in section I. Otherwise, disclosure is limited to those who administer the Court and to any obligation at law.

IV.Names Put Forward

1. 1

   A member may put another person’s name before the Court. Where that happens, the Court holds the particulars given about that person and may write to them about it. Nobody’s name is published, sold, or passed to anyone outside those who administer the Court.

2. 2

   A person whose name has been put forward may ask what is held about them, and may ask that it be removed. Such requests are made to the Secretary.

3. 3

   A member who puts a name forward confirms that the particulars given are accurate.

V.Retention

Particulars of an unsuccessful application remain in the Court’s records until their owner asks that they be removed. What is kept of an unfinished application remains in the Court’s records until the applicant uses the erasing link in the Secretary’s letter or asks the Secretary that it be removed. A name and email address left in the Antechamber is kept until its owner asks that it be removed. An address given for The Gazette is kept. When its owner ends it, no further issue is sent, the address is kept marked as ended so that it is never written to again, and it leaves the advertising list when that list is next replaced. The links in The Gazette pass through the Court’s own address, so that the Court knows which reader followed which engagement. Member records are kept by the Court without limit of time. Photographs and recordings of the Court’s engagements are kept by the Court without limit of time.

VI.Your Rights

A member, an applicant, a reader of The Gazette, or a person whose name has been put forward may ask what is held, ask that it be corrected, or ask that it be removed. The Court removes what it holds unless the law requires it to be kept, or it is needed to settle a sum owed or a matter in dispute. The Court’s photographs and recordings of its engagements are not withdrawn on request. Such requests are made to the Secretary in writing, at secretary@themansacourt.com, or by post to The Mansa Court LLC, 54 State Street, Suite 804 #18002, Albany, New York 12207.