Privacy Policy

1. Who we are

Exact Time Now (the “Site”) is a free world-clock and time-zone reference operated by Marcin Lewandowski trading as Depthia, a sole trader registered in the United Kingdom. We are the “data controller” for the personal data described in this notice under the UK GDPR and the Data Protection Act 2018.

• Trading name: Depthia
• Controller: Marcin Lewandowski (sole trader, UK)
• ICO registration: ZC164548
• Email: info@marcinlewandowski.com
• Postal address: available on request via the email above. Our registered address is held on the UK ICO public register linked above.

We have not appointed a Data Protection Officer because our scale and nature of processing do not require one under UK GDPR Art. 37.

2. What data we collect

You do not need an account to use the Site. We do not collect names, postal addresses, phone numbers, or payment details. The personal data we do receive falls into three categories:

• Technical data (automatic): IP address, browser and operating-system identifiers, referrer URL, language preference, country / approximate region derived from the IP, and the pages you view.
• Analytics & advertising data (consented): cookies and similar identifiers set by Google Analytics 4, Google AdSense, Microsoft Clarity, and PostHog, plus the events those tools record about how the Site is used.
• Contact data (voluntary): if you email us, the content of your message and your email address.

3. How we use it and why (legal basis)

UK GDPR Article 6 requires us to identify a lawful basis for each processing purpose.

• Operating the Site & security — server logs, fraud detection, abuse prevention. Legal basis: legitimate interest (Art. 6(1)(f)).
• Analytics — understanding which pages and features people use, fixing bugs. Legal basis: consent (Art. 6(1)(a)), collected via the cookie banner.
• Advertising — serving Google AdSense ads and, if you consent, personalising them. Legal basis: consent (Art. 6(1)(a)). Without consent we may still serve non-personalised ads under legitimate interest.
• Responding to your email — to reply to you. Legal basis: legitimate interest.
• Complying with legal obligations — e.g. responding to lawful requests from regulators or courts. Legal basis: legal obligation (Art. 6(1)(c)).

We do not perform automated decision-making or profiling that produces legal or similarly significant effects on you.

4. Cookies and similar technologies

Strictly necessary storage (such as your language preference and consent choice) is always active. Everything else — analytics and advertising — runs only after you accept it via the cookie banner. You can change your choice at any time using the Cookie preferences link in the footer.

5. Third-party processors

We share personal data with the following processors who act on our instructions and are bound by data processing agreements.

• Google Ireland Ltd / Google LLC — Google Analytics 4 and Google AdSense (advertising, measurement). Google may transfer data to the United States under the EU–US Data Privacy Framework and the UK Extension. See Google’s partner-site disclosures. You can opt out of personalised advertising at adssettings.google.com.
• Microsoft Corporation — Microsoft Clarity session-replay and heatmap analytics. Data is transferred to Microsoft under Standard Contractual Clauses / the UK IDTA.
• PostHog Inc. — product analytics, hosted at eu.i.posthog.com in the European Union. Requests are proxied through our domain at /ingest to reduce third-party network load.
• Vercel Inc. — site hosting and request metrics (cookieless).
• Open-Meteo, Nager.Date, sunrisesunset.io — read-only public APIs for weather, holidays, and astronomy data. No personal data is shared with them; calls from your browser expose only your IP and the city coordinates being looked up.

6. International transfers

Where personal data leaves the UK or European Economic Area, we rely on the following safeguards under UK GDPR Chapter V:

• United States (Google, Microsoft, Vercel) — EU–US Data Privacy Framework, the UK Extension, and the UK International Data Transfer Agreement (IDTA) / Standard Contractual Clauses.
• European Union (PostHog EU host) — adequacy decision; no additional transfer mechanism required.

7. How long we keep your data

• Server access logs: 30 days, then deleted.
• Google Analytics 4: event data 14 months; aggregated reports retained longer.
• Microsoft Clarity: up to 13 months per Microsoft’s default retention.
• PostHog: up to 12 months unless you tell us to delete sooner.
• Google AdSense: per Google’s policies.
• Emails you send us: kept for as long as needed to handle your request, then deleted within 2 years.

8. Your rights under UK GDPR

You have the right to:

• Request access to the personal data we hold about you (Art. 15).
• Ask us to correct inaccurate data (Art. 16).
• Ask us to erase your data (Art. 17).
• Ask us to restrict processing (Art. 18).
• Object to processing based on legitimate interest (Art. 21).
• Receive your data in a portable format (Art. 20).
• Withdraw your consent at any time, without affecting prior processing (Art. 7(3)). For cookies, use the Cookie preferences link in the footer.

To exercise any of these rights, email info@marcinlewandowski.com with “Privacy request” in the subject line. We will respond within one month, as required by Art. 12(3).

9. Complaining to the ICO

You have the right to lodge a complaint with the UK Information Commissioner’s Office at any time. You can do so at ico.org.uk/make-a-complaint or by calling the ICO on 0303 123 1113. We would, of course, appreciate the chance to address your concern first — please do reach out by email before raising it with the regulator.

10. Children’s privacy

The Site is not directed at children under 13 (the UK GDPR age of consent). We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Changes to this policy

We will update this page if our practices change. Material changes will be flagged at the top of this page and reflected in the “Last updated” date above.