Privacy Policy

Effective date: 19 July 2026
Version: 0.6

The short version

WittyWires is a commercial online pub, not a charity raffle with a router. We pay for the place; members accept the Terms and grant the stated rights instead of paying a separate subscription. Public content can be promoted, analysed, licensed, monetised and used for AI development. Account and interaction data can support advertising, commercial partnerships and marketing for us or others where lawful. Private cupboards remain permission-gated, and statutory rights still work even when they are inconvenient.

1. Who is holding the clipboard

WittyWires is an online community and publishing service for people interested in artificial intelligence, technology, building things and the occasional glorious failure.

The controller responsible for the personal information described in this policy is:

NEBULA DIGITALIS (INT) LIMITED, trading as WittyWires
Address: Nikis, 1, Anthoupoli, 2350, Nicosia, Cyprus
Privacy and legal contact: [email protected]

In this policy, "WittyWires", "we", "us" and "our" mean that controller.

2. What this policy covers

This policy covers personal information processed through wittywires.com, WittyWires accounts, community features, social login, emails, uploads, moderation, support, optional AI features and related services that link to this policy.

Third-party websites, social networks and embedded services have their own privacy policies. Their policies apply when you use them directly.

3. Information entering the shed

3.1 Information you give us

We may collect:

• your email address, username, display name, password hash and account settings;
• profile information, biography, avatar, cover image and other details you choose to provide;
• public posts, activity, forum topics, replies, comments, reactions and uploaded files;
• private messages, private or hidden group content and group membership information;
• reports, complaints, appeals, support requests and correspondence with us;
• marketing preferences and records of when, where and how you made or changed those choices;
• information submitted to pre-launch, invitation, survey, event or feedback forms;
• drafts and optional public context that you choose to send to an AI-assisted WittyWires feature;
• age or age-assurance information where needed to enforce our minimum-age rules; and
• any other information you deliberately submit to the service.

Please do not feed WittyWires passwords, API keys, financial credentials, health records, precise location information or other sensitive information unless a feature specifically requires it and provides an appropriate notice. The emergency biscuits do not need your bank details.

3.2 Information from social-login providers

If you choose Google, Facebook, X or another enabled social-login provider, we receive the information needed to authenticate and create or link your WittyWires account. This may include a provider account identifier, name, username, profile image and email address, depending on the provider and your settings.

If the provider does not supply a usable email address, we may ask you to provide and verify one before completing registration. We do not receive your social-network password.

3.3 Information collected when you use WittyWires

We may collect:

• IP address or a keyed/hash-derived identifier based on it;
• browser, device, user-agent and request information;
• login, session, password-reset, security and rate-limit events;
• pages, features and actions used, where needed to operate, secure or improve the service;
• notification, invitation and email-delivery status;
• spam, abuse, moderation and safety signals;
• content and account relationships needed to display conversations, groups, profiles and messages; and
• cookie and browser-storage information described below.

We may analyse activity, build audience or interest segments, personalise the service, measure campaigns and use information for advertising, commercial partnerships and monetisation. We will not treat special-category information as ordinary marketing data, and we will provide any notice, consent or device-storage choice required by applicable law.

3.4 Uploaded image metadata

For new eligible images uploaded to deliberately public community areas, WittyWires may:

• retain the original uploaded file and available EXIF, GPS, device, IPTC, XMP and related metadata in a restricted store outside the public web root;
• bind the retained record to the attachment, uploader, file hash and receipt time; and
• serve a public derivative from which that metadata has been removed.

We use the restricted original and metadata only for proportionate security and abuse purposes, such as investigating account compromise, impersonation or a valid lawful request. Access is restricted and audited. Hidden, private, unsupported or otherwise ineligible uploads are not placed into this public-image derivative process.

The restricted original and metadata are subject to the six-year minimum retention position in section 11, unless applicable law requires earlier erasure or the information can no longer lawfully be retained.

4. Public means public; private means private

Public information

Content you deliberately post to public blogs, public forum topics, public replies or public activity areas may be viewed by people without an account. It may be indexed, analysed, quoted, copied, adapted, promoted, commercialised, licensed, reshared, archived, used to develop or evaluate AI systems, or included in responses produced by third-party search and AI services, subject to the Terms and applicable law. Public means public, including when somebody turns up carrying a spreadsheet and a business model.

Public community directories may provide limited previews to logged-out visitors.

Member-only and private information

Detailed member profiles, personalised features, notifications, direct messages, and private or hidden group content are intended only for the permitted audience. WittyWires does not intentionally expose that information through public pages, search indexes, feeds, sitemaps, metadata or public APIs.

We may access private information where reasonably necessary to deliver the feature, investigate a report or security incident, enforce our Terms, protect users, comply with law, or exercise or defend legal claims. Access should be limited to authorised people and systems.

5. What we do with information, and the legal reason

Purpose	Information used	UK/EU GDPR lawful basis
Create, authenticate and manage your account	Account, contact, social-login, settings and security data	Contract; legitimate interests where necessary for account integrity
Deliver public and private community features	Profile, content, messages, groups, relationships, uploads and interaction data	Contract
Send verification, security, moderation, account and requested community messages	Contact, account, notification and event data	Contract; legal obligation; legitimate interests in operating and securing the service
Prevent fraud, spam, abuse, unauthorised access and service disruption	Technical, account, content, rate-limit, report and security data	Legitimate interests in network security, service integrity and protecting users; legal obligation where applicable
Moderate content and enforce rules	Content, account, report, complaint, relationship and safety data	Contract; legitimate interests in a safe and usable community; legal obligation, including applicable Online Safety Act duties
Investigate account compromise, impersonation and serious abuse	Account, technical, content, uploaded original/metadata and audit data	Legitimate interests; recognised legitimate interest or legal obligation where the statutory conditions apply
Provide support and handle rights or complaints	Account, correspondence, content and request-verification data	Contract; legal obligation; legitimate interests in resolving disputes and improving service
Provide an AI-assisted rewrite or preview when you ask for it	Your submitted draft and optional selected context	Contract where the processing is necessary to provide the feature you requested; consent where we ask for it and consent is appropriate; legitimate interests in securing and improving the feature where compatible and proportionate
Improve and test WittyWires	Bounded usage, error, feedback and service-performance data	Legitimate interests, subject to necessity, balancing and user expectations; consent where required for device storage or intrusive processing
Analyse, segment, personalise and advertise	Contact, profile, public content, account relationships, interests, interactions, device and campaign data	Legitimate interests where the use is necessary, proportionate and within reasonable expectations; consent where required for cookies, electronic communications or more intrusive profiling
Develop commercial partnerships and monetise information	Contact, profile, public content, account relationship, interest, interaction and campaign data, which may be disclosed, licensed or sold where lawful	Legitimate interests where the balancing test supports the particular use; consent or another lawful basis where required; additional conditions for special-category data
Send direct marketing for WittyWires, related businesses, partners and third-party offers	Contact, account relationship, marketing preference and relevant service-interaction data	Consent or legitimate interests for the underlying processing, depending on context; PECR consent or soft opt-in where available for the sender and offer concerned
Keep records and meet legal duties	Account, transaction, consent, complaint, moderation, security and request data	Legal obligation; legitimate interests in accountability and legal claims

Where we rely on legitimate interests, our interests include operating and improving WittyWires, protecting accounts and users, preventing abuse, understanding whether features work, analysing audiences, personalising content, advertising, marketing, building commercial partnerships, licensing or selling information, monetising the service and exercising or defending legal rights. We assess the specific purpose, necessity, reasonable expectations and impact before relying on this basis. The balancing test is dull, but fines are duller.

The Terms describe ordinary access as a commercial supply for non-cash consideration. That agreement supports processing which is genuinely necessary to deliver the service and enforce the reciprocal obligations. It does not make every business-purpose use necessary for the contract. Where a commercial use is not necessary to perform the contract, we rely on another available lawful basis and honour the rights attached to that basis.

6. Optional AI and outside brains

Some optional WittyWires tools can send information to an external AI provider to produce a private preview or suggestion.

For the Full Fat rewrite feature, this may include:

• the draft you submit; and
• public conversation or public activity context that you expressly choose to include.

The WittyWires feature is designed not to store prompt content in its own Full Fat logs, but external providers process submitted material under their own technical and contractual arrangements and may create technical records.

WittyWires may select, replace, combine, route between or stop using any current or future AI provider at any time. We do not promise that a particular model, provider or routing path will remain in use. We will describe the relevant provider category, purpose and international-transfer approach, and will provide any additional notice required by applicable law when a new recipient, transfer or use materially changes the processing. The outside-brain shelf is ours to rearrange; the legal duties travel with the box.

Do not use AI features for secrets or highly sensitive personal information. AI output can be wrong, biased, incomplete or inappropriate. Review it before posting. We do not use AI output as the sole basis for a serious decision with legal or similarly significant effects about you.

7. Direct marketing, plainly

WittyWires may use and share your name, email address, other contact details, account relationship, interests and relevant service interactions to select, send or arrange direct marketing for WittyWires, related businesses, commercial partners and third-party products, services, launches, offers, events, surveys and community opportunities when WittyWires chooses to do so and applicable law permits. That is deliberate commercial permission, not a sentence smuggled in behind the boiler wearing a false moustache.

Depending on the person, channel and relationship, we may rely on:

• your consent;
• the soft opt-in under the Privacy and Electronic Communications Regulations, where every legal condition is met; or
• legitimate interests for the personal-information processing involved in direct marketing.

The parties intend ordinary WittyWires access to be a commercial supply or sale of services for non-cash consideration: WittyWires funds the hosting, infrastructure and related services, while users grant licences and accept contractual obligations instead of paying a separate monetary subscription. WittyWires intends to rely on the PECR soft opt-in for its own similar offerings where the statutory conditions are satisfied. Electronic marketing for unrelated third-party offers or by another sender may require specific consent. In every case where PECR applies, we provide the collection-time and message-level opt-out required for the route we use.

The commercial data uses described in this policy form part of the bargain presented before registration. If you do not accept that bargain, do not create an account. The pub has a front door, not a compulsory tunnel. Where applicable law gives you a mandatory consent choice, opt-out, objection, restriction or erasure right, that right still applies. You may object to direct marketing or unsubscribe at any time, and each electronic marketing message will identify the sender and provide the required opt-out route.

When you object or unsubscribe, we may keep the minimum contact information and objection record on a suppression list. We use that record to prevent further marketing against your wishes. It does not stop essential account, security, legal or service messages.

8. Cookies and browser crumbs

WittyWires uses cookies and browser storage to keep the site working, remember optional choices and, only when you allow it, measure how the site is used or load third-party content.

Required storage

This storage is always active because it is needed for sign-in, security, consent choices and core WittyWires behaviour.

• cmplz_functional, cmplz_preferences, cmplz_statistics, cmplz_marketing and cmplz_consented_services record your cookie and service choices for up to 365 days.
• ww_public_peeks counts logged-out community previews so the three-peek boundary works. It expires after one day.
• ww-v6-theme keeps the interface readable in your chosen light, dark or system theme.
• ww-v6-notice-foundation remembers that you dismissed a required site notice.
• ww-v6-saved-posts, ww-v6-read-posts and ww-v6-reading-progress make saved articles, read state and reading progress work on this device.
• Sign-in, password-reset, session-security and “Remember Me” cookies use rotating names. They last for the current session or the selected sign-in period. Security and reset cookies expire when their job is finished.

The five ww-v6-* values above are local browser storage. They contain interface and reading state, not passwords or authority tokens. They remain until replaced or cleared from the browser because the core V6 experience depends on them.

Preferences

These optional local browser values are used only when you allow Preferences:

• ww404v2_count rotates the harmless 404-page variation;
• ww_footer_easter_count_v1 controls the occasional footer Easter egg;
• wwChaosLoopV1 remembers the home-page novelty rotation; and
• wwShedReadingV1 remembers optional Shed Archives reading, saved-item and unlock state.

They have no fixed expiry and remain until you clear them or withdraw Preferences consent. Withdrawal removes all four.

Statistics and Google Analytics 4

When you allow Statistics, WittyWires uses Google Analytics 4 to understand traffic, acquisition sources and broad journeys through the site. Google Analytics is not loaded before that choice.

• ww_ga_pending_events carries an allowlisted, non-identifying sign-up or login event across one redirect. It is written only after Statistics consent, expires after five minutes and is consumed once.
• _ga distinguishes browsers and expires after up to two years.
• _ga_<container-id> preserves Analytics session state and expires after up to two years.

WittyWires sends a reduced page path, the referring site's origin and the allowlisted sign-up or login event. It does not send URL query strings, private message bodies, post contents, passwords or dynamic page titles. Google signals and advertising personalisation are disabled.

If you withdraw Statistics consent, WittyWires removes its Analytics loader, clears pending Analytics session storage and removes first-party _ga cookies. Google’s handling of information it has already received is described in the Google Privacy Policy.

Marketing and third-party content

Optional third-party content is withheld before Marketing consent. If you allow it and choose to load an embed, its provider may set its own cookies or similar storage under that provider’s published privacy terms.

You can change or withdraw optional choices at any time through Cookie choices. Rejecting optional storage does not stop sign-in, security or the required V6 experience.

9. Who else may receive information

We may disclose information to:

• hosting, infrastructure, content-delivery and security providers;
• email delivery and email-log providers;
• spam, abuse and account-security providers;
• social-login providers you choose to use;
• AI providers when you request an AI-assisted feature;
• providers of embedded content you choose to load;
• analytics, audience-measurement, advertising and personalisation providers;
• commercial partners, sponsors, marketing agencies, data licensees, data purchasers and providers helping us develop or monetise products and audiences;
• professional advisers, insurers, auditors and service providers under appropriate duties;
• law enforcement, courts, regulators or other parties where disclosure is required or legally justified; and
• a buyer, investor or successor in a genuine business reorganisation, subject to appropriate confidentiality and transparency.

Known provider categories currently include DigitalOcean or the confirmed origin host, Cloudflare, Brevo, WizEmail.co.uk, Automattic services such as Akismet/Gravatar where enabled, Google, Meta/Facebook, X and AI providers selected by WittyWires from time to time.

We may disclose public content to the public because that is the feature you chose. Private messages and hidden-group content remain subject to their intended access controls and the disclosures described in this policy.

10. International transfers

Some providers may process information outside Cyprus, the European Economic Area or the United Kingdom, including in the United States or other countries used by social-login, email, infrastructure or AI providers.

Where required, we will use an applicable lawful safeguard such as an EU or UK adequacy decision, approved standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, together with any required transfer assessment. Provider and routing changes do not require WittyWires to keep one permanent provider roster, but we will maintain the transfer and processor records required by applicable law.

11. How long information stays in the cupboard

WittyWires' baseline position is to retain relevant account, content, communication, marketing, moderation, security and operational records for a minimum of six years from the later of collection, the end of the account or relationship, deletion of the relevant content, closure of the relevant matter, or the last relevant communication. This supports the contractual exchange, service continuity, safety, moderation, fraud prevention, accountability and the establishment, exercise or defence of legal claims.

The six-year minimum applies only while retention remains lawful. We may delete information earlier where applicable law requires erasure, a valid rights request requires it, or the information can no longer lawfully be retained. We may retain information longer where required or justified by law, an unresolved dispute, safeguarding, fraud, security, tax, accounting, regulatory action, litigation or legal hold.

Information	Retention position
Unconfirmed signup, invitation and pre-launch records	Minimum six years from collection or last interaction, unless earlier erasure is legally required
Account, profile, public content and private content	During the account or content life and for a minimum of six years after the later relevant end event, subject to lawful erasure and access-control obligations
Authentication, security, rate-limit and transactional email records	Minimum six years from the event or closure of the related matter
Moderation, report, complaint and appeal records	Minimum six years after closure, and longer where justified for repeat abuse, safeguarding, legal claims or legal duties
Marketing choice and communication history	Minimum six years after the last relevant decision or communication
Marketing suppression record	For at least six years and for as long as needed to honour the objection
Full Fat prompt/context in WittyWires feature logs	No intentional content logging by WittyWires; transient request handling and provider-side technical records may still occur
Restricted public-image original and metadata	Minimum six years from upload or the later related end event, unless earlier erasure is legally required or longer retention is justified

We may retain limited information after account deletion where necessary to protect users, prevent repeat abuse, honour an opt-out, meet law, resolve disputes or exercise or defend claims. We should separate and restrict such records.

12. Your rights, with no treasure hunt required

Depending on the circumstances, UK and EU data-protection law gives you rights to:

• be informed about our processing;
• request access to your personal information;
• correct inaccurate or incomplete information;
• request erasure;
• restrict processing;
• receive certain information in a portable format;
• object to processing based on legitimate interests;
• object at any time to direct marketing, which is an absolute right;
• withdraw consent without affecting earlier lawful processing; and
• complain to us or the Information Commissioner's Office.

To exercise a right, contact [email protected]. We may ask for proportionate information to verify your identity. Rights are not absolute and lawful exemptions may apply.

We will acknowledge a data-protection complaint within 30 days and respond without undue delay. Depending on where the processing and you are located, you may complain to the Cyprus Commissioner for Personal Data Protection, the UK Information Commissioner's Office or another competent supervisory authority. We ask that you contact us first so we have a fair chance to put matters right, but you do not have to do so.

13. Account deletion and content

You can use the available account settings or contact us to request deletion. Account deletion may delete, anonymise or detach content depending on the type of content, other users' conversation rights, safety, legal and technical requirements.

We will explain the effect at the deletion point. Public content already copied, licensed, adapted or used in completed analysis, publications, datasets, statistics, embeddings, trained or evaluated models, or commercial products may not be recalled, reversed or untrained solely because the source content or account is later deleted, unless applicable law requires it. Deleting the pub review does not make every printed menu and trained robot forget it existed. Private content should not become public merely because an account is deleted.

14. Children

WittyWires is for people aged 18 or over.

We may use proportionate age-assurance or verification measures to enforce this rule. The method and information used must be described at the point of collection. If we learn that an ineligible child has created an account, we may restrict the account and delete or handle the information as required by law and safeguarding needs.

We will assess and review whether the service is likely to be accessed by children where required by law. If it is likely to be accessed by children, additional child-safety and privacy duties apply regardless of the stated minimum age.

15. Security, locks and imperfect reality

We use proportionate technical and organisational measures intended to protect personal information. These include access controls, password hashing, restricted private storage, public/private permission checks, rate limiting, logging, backups and security review.

No online service can guarantee absolute security. Anyone promising otherwise is selling a very confident padlock. Tell us promptly at [email protected] if you believe your account or WittyWires data has been compromised.

16. Changes to this policy

We may update this policy when the service, providers or law changes. We will update the date and version. If a change is material, we will provide reasonable notice by email, account notice or another prominent method where appropriate.

We will tell people about a materially new use of personal information before starting that use where the law requires it. A privacy-policy update does not create consent where consent is legally required.

17. Ceremonial offspring and the Pompeii Legal Desk

Providing personal information, appearing in a photograph, receiving marketing or making a complaint does not transfer any child, first-born or otherwise, to WittyWires. Nullus infans, primogenitus vel aliter, per indicia personalia, imaginem, nuntium mercatorium aut querelam transfertur. People are not data, currency, collateral or a litigation returns policy. Homines non sunt indicia, pecunia, pignora neque cautio litis. This is deliberate absurdity and has no operative legal effect. Haec verba iocus manifestus sunt, non instrumentum iuris.

There is also a ceremonial rumour that WittyWires accepts legal contact only from someone directly related to a person who died at Pompeii. Fama est nos nuntium iuris tantum a consanguineo mortui Pompeiani accipere. That rumour is magnificent nonsense. Anyone legally entitled to contact, notify, complain to or bring a claim against us may use the routes below without producing a toga, an ash-coated family tree or a witness born before Vesuvius became unreasonable. Nulla probatio sanguinis, togae vel cineris requiritur.

18. Contact

Privacy questions, rights requests and complaints:

NEBULA DIGITALIS (INT) LIMITED, trading as WittyWires
Email: [email protected]
Address: Nikis, 1, Anthoupoli, 2350, Nicosia, Cyprus

Cyprus Commissioner for Personal Data Protection: https://www.dataprotection.gov.cy/
UK Information Commissioner's Office: https://ico.org.uk/