Privacy policy
Last updated: 14 August 2026
This privacy policy explains how personal information is used by the Crossword Centre Clue Writing Competition (CCCWC) at clue.vellender.com.
1. Who is responsible for your information?
The data controller is Adam Vellender, who operates CCCWC. For privacy questions, data protection requests or complaints, please email cc@vellender.com.
2. What information is collected?
Depending on how you use the site, CCCWC may process:
- Account information: your email address, name, optional pseudonym, country, account status and account timestamps. Passwords are not stored in readable form; only a password hash is stored.
- Competition information: clues, explanations, withdrawals, points, merits, voting comments, private pinning choices and personalised clue-number assignments.
- Email information: your email preferences, records that scheduled competition emails were sent, and short-lived verification, password-reset and unsubscribe information.
- Administrative and security information: limited audit records of administrative actions and technical information needed to secure and operate the site. Your IP address may be processed for rate limiting and may also appear in ordinary web-server or reverse-proxy logs.
- Cookies: strictly necessary cookies used for login sessions, security and, if you select “Remember me”, keeping you logged in.
CCCWC does not use advertising cookies, behavioural advertising or third-party analytics. Please do not deliberately include sensitive personal information about yourself or anyone else in clues, explanations or comments unless it is genuinely necessary.
3. Why is this information used, and what is the lawful basis?
| Purpose | Lawful basis |
|---|---|
| Creating and administering accounts; providing password resets; accepting entries and votes; preventing self-voting; calculating and publishing results; maintaining the competition archive. | Legitimate interests in operating a fair, reliable clue-writing competition and providing the service that users have chosen to use. |
| Publishing entrants' names and optional pseudonyms for positions 1–10 (including ties), together with clues, results, merits and anonymous voting comments. | Legitimate interests in publishing and preserving the results of the competition. This is an expected part of entering CCCWC. |
| Protecting accounts and the site, rate limiting, troubleshooting, moderation, auditing administrative actions and investigating abuse. | Legitimate interests in security, integrity and administration of the service. |
| Sending optional new-competition and seven-day reminder emails that you have selected in your profile, including verifying your email address before those optional messages are enabled. | Your consent. These options are off by default and you may withdraw consent at any time in your profile or by using the unsubscribe link in an email. |
| Sending essential account emails such as password-reset messages. | Legitimate interests in providing and securing your account. |
| Complying with legal obligations and responding to valid legal requests. | Legal obligation, where applicable. |
4. What is public?
During voting, entries are presented without the entrant's identity. After results are published, the names (and pseudonyms, if supplied) of entrants placed 1–10 are published alongside their entries. If there is a tie for 10th place, everyone in that tied position is treated as being in the top ten. Lower-placed entries remain publicly anonymous.
Voting comments are published anonymously after the results are released. Points, merits and aggregate results are also published. Private pinning choices are never published.
5. Who is information shared with?
Personal information is shared only where reasonably needed to run CCCWC. This may include hosting, infrastructure and operational service providers used to host the website and database, deliver outgoing email, and provide private administrative notifications. These providers may process account contact details and relevant competition or email content only to the extent needed to provide those services.
Private administrative notifications are not visible to ordinary CCCWC users and are restricted to the administrator(s) responsible for operating the competition.
Information may also be disclosed if required by law, or where necessary to establish, exercise or defend legal claims.
6. International transfers
Some hosting, infrastructure or operational service providers may process personal information outside the United Kingdom. Where personal information is transferred internationally, appropriate safeguards are used where required, such as UK adequacy regulations or approved contractual protections.
If you would like more information about the safeguards applying to a particular transfer, contact cc@vellender.com.
7. How long is information kept?
Information is kept only for as long as it is reasonably needed for the purposes described above. In particular:
- Account and profile information is normally kept while your account remains active and is reviewed if the account is closed or you ask for deletion.
- Competition entries, voting data and published results may be retained as part of the historical competition archive for as long as that archive is maintained. Where appropriate, identifying information can be removed or anonymised without deleting the historical competition record.
- Email-verification links (when you request optional competition emails) and password-reset links expire after a short period and cannot be used after expiry or use. Only hashed token values are stored in the database.
- Email preference and delivery records are retained for as long as reasonably necessary to operate the email service, respect opt-outs and demonstrate what messages were sent.
- Security, server and administrative logs are retained only for as long as reasonably necessary for security, troubleshooting and accountability.
- Copies held by private administrative-notification services are retained only while reasonably useful for administration and troubleshooting and should be periodically removed when no longer needed.
Backups may retain deleted information for a limited additional period until those backups are overwritten.
8. Cookies
CCCWC uses only cookies that are needed to provide the service. These include the session cookie used to keep you securely logged in and, if you choose “Remember me”, a longer-lived login cookie. These cookies are not used for advertising or cross-site tracking. Because they are strictly necessary for the service and security functions you request, they do not require an advertising-style cookie consent banner.
9. Your choices and data protection rights
Depending on the circumstances and the lawful basis involved, UK data protection law gives you rights including access to your personal information, correction of inaccurate information, erasure, restriction of processing, objection to certain processing and data portability.
Your right to object: where CCCWC relies on legitimate interests, you may object to that processing. Your objection will be considered in light of the reasons for the processing and your rights and interests.
Where processing is based on consent, particularly optional competition and reminder emails, you can withdraw that consent at any time. You can change email preferences from your Profile page or use the unsubscribe link included in optional emails. Withdrawal does not affect processing that was lawful before consent was withdrawn.
To exercise a data protection right, request account closure, or ask a question about how your information is handled, email cc@vellender.com. You may be asked for enough information to confirm your identity before a request is acted upon.
10. Required and optional information
An email address, name, country and password are required to create an account because they are needed to administer the competition and account. A pseudonym is optional. Optional competition/reminder emails are also entirely optional and are switched off unless you choose them. Your account does not need an email-verified address to enter clues or vote; verification is requested only if you choose to receive those optional emails.
11. Automated decision-making
CCCWC does not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects. Competition ranking is a mechanical calculation from submitted points and merits according to the published competition rules.
12. Complaints
If you are concerned about the handling of your personal information, please first contact cc@vellender.com so the concern can be investigated. Data protection complaints will be acknowledged within 30 days and handled without undue delay.
You also have the right to complain to the UK's independent data protection regulator, the Information Commissioner's Office (ICO).
13. Changes to this policy
This policy may be updated if CCCWC changes how personal information is used or if legal requirements change. Material changes will be brought to registered users' attention where appropriate before materially different processing begins.