Privacy Policy

Effective Date: 12 January 2026
Version: 1.0
Controller: Nice Name Publishing

1. Controller Information

Nice Name Publishing is the data controller for the personal data processed through this website.

Contact Details:

• Website: https://www.continuityid.com
• For privacy-related inquiries, please use our contact information available on the website

2. What We Collect

2.1 Information You Provide

When you interact with our website, we may collect:

• Contact information when you reach out to us
• Feedback or comments you provide
• Any information you voluntarily submit

2.2 Information Processed Automatically

When you visit our website, our hosting environment automatically processes:

• Technical Data: IP address, browser type and version, operating system, referring website
• Operational Data: requested pages, timestamps and response information, recorded by our hosting platform (Microsoft Azure) for hosting, security and availability purposes

We do not operate third-party behavioural-analytics or advertising measurement.

2.3 Cookies and Similar Technologies

ContinuityID does not use advertising cookies or third-party behavioural-analytics cookies. We do not ask you to accept optional analytics cookies, because we do not operate them.

• No optional analytics-consent banner is presented, because no behavioural analytics run.
• First-party operational instrumentation (see section 4) records aggregate engagement events to our own endpoint to help us improve the site. It does not use third-party analytics or advertising cookies.

2.4 ContinuityID Generation Service

ContinuityIDs are generated inside your own browser. When you generate a ContinuityID on our site:

• No key material is transmitted: your cryptographic keypair is created on your own device; your private key is never sent to, received by, or stored on our servers, and we cannot reconstruct it
• No server-side generation: generating a ContinuityID does not send a request to our API; the downloadable package is assembled on your device
• Security Monitoring: where our API is accessed (for example, a page requesting the public counter), we temporarily log IP addresses, browser information, and request patterns solely for abuse prevention and security purposes (automatically deleted after 30 days)
• Bot Detection: our pages use automated bot-detection techniques; this data is discarded immediately after validation
• Zero-Custody Principle: we do NOT store your ContinuityID, private keys, DID documents, or any identity data — we never receive them. Your identity is yours alone.

3. Purposes and Legal Basis

We process your personal data for the following purposes:

4. Cookies, Analytics and Consent

4.1 No behavioural analytics; no optional analytics consent

ContinuityID does not operate Google Analytics, Google Tag Manager or any other third-party behavioural-analytics or advertising measurement on this website. Because we do not operate these, we do not present an optional analytics-consent choice, and we do not set analytics or advertising cookies.

4.2 What we do operate

• Hosting and operational telemetry (Microsoft Azure): the Azure Static Web Apps platform and our Azure Functions process standard server-side request information (for example page requests and data transfer) for hosting, security, availability and capacity purposes. This is server-side logging, not browser-based behavioural tracking.
• First-party operational instrumentation: a small first-party script records aggregate engagement events (for example page views and whether a page was scrolled or viewed for at least a minute) to our own Azure endpoint, so we can tell whether the site works. It does not use third-party analytics or advertising cookies.
• Search indexing: we publish robots.txt and sitemap.xml so that search engines (including Google Search) can index the site. Search indexing does not depend on analytics or cookies.

4.3 Cookie types

• Essential: only those required for the website to function.
• Analytics / advertising: not used.

5. Data Sharing and Recipients

5.1 Third-Party Services

We do not share data with third-party advertising or behavioural-analytics providers. We use the following infrastructure processor:

• Microsoft Azure: for website hosting, serverless functions and hosting/operational telemetry

5.2 Legal Disclosures

We may disclose your personal data if required to:

• Comply with legal obligations
• Protect our rights or property
• Prevent fraud or security threats
• Respond to lawful requests from public authorities

6. International Transfers

Data may be transferred to and processed in countries outside the UK/EEA:

• United States: Microsoft Azure operates globally with appropriate safeguards
• Safeguards: We ensure adequate protection through Standard Contractual Clauses and adequacy decisions
• Your Rights: You can request information about safeguards and obtain copies of relevant documents

7. Data Retention

We retain personal data for the following periods:

• Hosting and operational telemetry: retained by the hosting platform for a limited operational period (for example Azure platform metrics are retained for a limited rolling window)
• First-party engagement events: retained for a limited period for site operation and improvement
• Contact Inquiries: 2 years or until resolved
• Technical Logs: 12 months for security purposes
• Security Monitoring Data: 30 days for abuse prevention, then automatically purged
• ContinuityID Data: Not retained — zero-custody model means we never store your identity
• Rate Limiting Records: 1 hour maximum, then automatically purged

Data is automatically deleted after retention periods unless legal obligations require longer storage.

8. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

8.1 Access and Portability

• Right of Access: Request copies of your personal data
• Data Portability: Receive your data in a machine-readable format

8.2 Correction and Erasure

• Rectification: Request correction of inaccurate personal data
• Erasure: Request deletion of your personal data (subject to legal obligations)

8.3 Processing Restrictions

• Restriction: Limit how we process your data in certain circumstances
• Objection: Object to processing based on legitimate interests
• Automated Decision-Making: We do not use automated decision-making or profiling

8.4 Exercising Your Rights

To exercise any of these rights, please contact us using the information provided above. We will respond within one month of receiving your request.

9. Complaints and Supervisory Authority

9.1 Complaints Process

If you're concerned about how we handle your personal data:

1. Contact us directly using the information above
2. We will investigate and respond within 30 days
3. If unsatisfied, you can escalate to the ICO

9.2 ICO Contact Information

Information Commissioner's Office (ICO)

• Website: https://ico.org.uk
• Telephone: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

10. Children's Privacy

This website is not directed at children under 16. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child under 16, please contact us immediately for removal.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption: Data in transit and at rest
• Access Controls: Limited access on a need-to-know basis
• Regular Updates: Security patches and monitoring
• Azure Security: Microsoft Azure's enterprise-grade security infrastructure

12. Changes to This Policy

12.1 Updates

We may update this privacy policy to reflect:

• Changes in law or regulation
• Updates to our data processing activities
• Improvements to our privacy practices

12.2 Notification

• Minor Changes: Updated effective date on this page
• Material Changes: Prominent notice on website and/or direct notification
• Historical Versions: Available upon request

13. Contact Information

For questions about this privacy policy or our data processing:

• Website: https://www.continuityid.com
• Subject Line: "Privacy Policy Inquiry - ContinuityID"
• Response Time: We aim to respond within 5 business days

Legal Disclaimer: This privacy policy is provided for informational purposes and does not constitute legal advice. For specific privacy law questions, consult qualified legal counsel.

Last Updated: 12 January 2026
Policy Version: 1.0
Next Review: July 2026