Privacy policy

1. Who is responsible?

Charlie Media ApS is responsible for the company's processing of personal data in connection with Charlie.nu.

Charlie Media ApS
Company registration number (CVR): 46220765
Ortenvej 51B
6800 Varde, Denmark
Email: info@charlie.nu

Please contact us here with privacy questions or requests to exercise your rights.

In addition to the owner, employees and an associated bookkeeper/accountant or auditor have access to Charlie's email and administration in connection with their work. Specific access rights and security procedures still require documentation; it has not been confirmed that everyone has the same access.

2. Visits, logs and backups

Website hosting and email are provided by AzeHosting ApS (AZE Hosting), company registration number 36974796. According to AZE's reply to Charlie, the web server logs IP address, time, visited URL, browser and referring page in connection with website delivery, operation and troubleshooting.

• Access logs: Archived daily in Charlie's own hosting account. The displayed cPanel setting removes the previous month's archived logs at the end of each month. Retention is therefore approximately 1–2 months depending on the log date; no separate fixed number of days has been selected. This concerns archived access logs, not security logs or backups.
• Security logs: Kept for up to 100 days.
• Mail logs: Sender, recipient, subject and IP address are kept for approximately 5 weeks. This concerns mail log information, not deletion of the email itself.
• Web server error log: Rotated according to size; no fixed time period has been specified.
• Website and email backups: Kept for up to 3 months.

AZE's terms describe access to customer data normally by prior agreement and logging of access. See sections 12 and 22 on security and access, and section 17 on processing in AZE's terms (Danish). Charlie's own access and security procedures still require confirmation.

3. Contacting us by email

The new contact form processes your name, email, selected department and message and sends them to the configured departmental recipient. The form remains closed until configuration and privacy information are approved. It uses a necessary session cookie and time-limited form tokens. Abuse prevention stores attempt timestamps under an IP-address hash in separate server storage; these remain personal data. Retention and practical cleanup of this storage must be established before activation; see section 9.

Our email is also provided by AZE Hosting. If you email info@charlie.nu, we receive your email address and the information you send, such as your name, message and attachments. We use this to respond to and handle your enquiry.

You do not need to email us to use the site's ordinary content. Please avoid sending sensitive information unless necessary for your enquiry. Ordinary enquiries are retained while being handled and deleted manually once the enquiry is resolved. Other mail is not automatically deleted by the server.

Messages in Trash and Spam are automatically deleted after they have been in the relevant folder for 30 days. AZE has confirmed that this applies to all mail accounts on the server, including new accounts, and cannot be restricted to charlie.nu.

Deleted messages may remain in backups for up to 3 months. If emails need to be kept longer for other purposes, such as contractual or accounting records, the purpose, legal basis and retention must be described separately. Such longer retention has not been confirmed in this policy.

For customer enquiries about radio advertising, customers may send proposed advertising copy. Extracts from the customer's email may be used as material in that customer's radio advertisement. This is a separate purpose beyond simply answering an enquiry. Deletion of advertising emails and retention as customer material or documentation have not yet been clarified; the rule for deleting resolved ordinary enquiries cannot automatically be applied to these emails.

4. Radio, podcasts and videocasts

• Radio: Streaming uses YesStreaming.
• Podcasts: Charlie reports distribution through Spotify, Apple Podcasts and Deezer. The actual RSS host, audio servers and providers’ processing roles still require confirmation. A Spotify show link is not itself an RSS feed.
• Videocasts: Video content is provided through YouTube.

YouTube Music is being considered as an additional podcast channel and is not enabled in this release. YouTube RSS ingestion creates videos with static podcast artwork on the selected YouTube channel. Configuration requires checks for duplicates and effects on the existing videocast.

The site retrieves content listings through Charlie's server. Your browser may load images from Charlie, media providers and YouTube's image servers as soon as content cards appear. An image provider may therefore receive your IP address before you start playback.

Playing radio or a podcast connects your browser to the audio file or streaming server. The receiving service depends on the selected content and its file address: a podcast also available on Spotify is not necessarily played from Spotify on this website.

Clicking a YouTube video opens an embedded player from youtube-nocookie.com. That address does not mean playback takes place without personal data processing. Media services may receive technical information such as IP addresses, browser information and requests for selected content. Specific data and retention depend on the service. Visits or playback directly on an external platform are also subject to that platform's own privacy information.

5. Cookies and website analytics

Website visitor analytics are disabled in this version. Google Analytics and Google Tag Manager are not loaded. Saving their IDs in SEO Admin does not activate them.

The homepage's own code does not set analytics cookies or use local storage for visitor analytics. This does not guarantee that external media services are free of cookies or data collection. Media providers' audience figures are separate from visitor analytics on Charlie.nu.

The finished installation and embedded content must be checked for cookies and similar technologies before launch. Where consent is required, suitable choices must be available before that technology is used. This policy does not itself provide a consent mechanism.

6. Links, providers and processing in other countries

The site may display ordinary links to social media and app stores. Following a link also brings the relevant service's privacy information into scope.

AZE Hosting processes data for Charlie as its hosting and email provider. The processing agreement is in section 17 of AZE's terms (Danish). AZE has identified the following subcontractors and processing countries:

• Hetzner: Servers and backups in Germany and Finland.
• CloudLinux: Server security software; USA and EU.
• MailChannels: Canada and USA; delivery of outgoing email to Microsoft recipients, such as Outlook and Microsoft 365.

This does not mean all data stays within the EU/EEA. The specific basis, any safeguards for processing outside the EU/EEA and necessary permissions still require clarification. No unconfirmed transfer mechanism is asserted here.

YesStreaming, Spotify, Apple Podcasts and Deezer and relevant media platforms may also receive data when delivering and playing content. Their specific roles, retention and processing countries still require separate clarification.

7. Your rights

Depending on the processing and legal conditions, you may have rights of access, rectification, erasure, restriction and data portability. You may object to processing based on legitimate interests. You may always object to processing for direct marketing.

Where processing relies on consent, you may withdraw it. Withdrawal does not affect the lawfulness of processing before withdrawal.

Contact info@charlie.nu to exercise your rights. We may need to verify your identity. You may also complain to the Danish supervisory authority, Datatilsynet.

8. Scope and changes

This text concerns Charlie.nu. It does not automatically cover all processing in the CharliePlay+ app, other Charlie services or external platforms. The app's privacy information must be clarified separately.

This policy must be updated when website processing changes, for example if analytics or new media services are added.

CharliePlay+ was developed by the owner of Charlie Media ApS. Account registration is not currently active but is planned for a future update. This policy does not describe account registration as an existing feature. Separate app privacy information must be completed and updated before account registration is introduced.

9. Information awaiting confirmation

To be completed before publication: the following information is unconfirmed. This version remains a draft.

• [PENDING: Access and security] Access by the owner, employees and a bookkeeper/accountant or auditor is described in section 1. Specific access rights and security procedures still require documentation. Log and email retention is described in sections 2 and 3.
• [PENDING: Legal basis] The basis for each processing activity, any specific legitimate interests and clarification of any profiling or automated decisions.
• [PENDING: Providers] Specific transfer bases, safeguards and necessary permissions for AZE's processing outside the EU/EEA, and the other media providers' legal identities, roles, privacy information and countries. AZE's reported subcontractors are in section 6.
• [PENDING: Media and app] Technical checks of cookies, storage and any consent needed for embedded content, and completion of the app's separate privacy information. The owner developed the app; account registration is planned but not yet active.
• [PENDING: Advertising emails] When advertising emails and customer copy are deleted, or whether and how long they are retained for reuse or documentation. The practice for ordinary enquiries does not resolve this.