PLACEHOLDER — FOR LEGAL REVIEW

Onward is a UK Charge Point Operator. This website and the Onward portal are run for Onward.

The company's legal name, company number, registered address and data protection registration are to be added after legal review.

PLACEHOLDER — FOR LEGAL REVIEW

From visitors to the website:

• The visitor's answer to the cookie bar, Accept or Decline. It stays in the visitor's own browser.
• Only when the visitor accepts: a record of each page view. It holds the page's address, the site the visitor came from, the campaign source named in the link, a coarse device type and how long the page was in view.
• With each page view, a visitor code: a one-way hash of the visitor's IP address and browser details, mixed with a value that changes every day. The IP address and the browser details themselves are not stored.
• Nothing is counted for a browser that sends Do Not Track or Global Privacy Control, whatever the cookie bar says.

From portal users, who join only with an access code from the Onward team:

• Email address, name and account type.
• The password, stored only as a scrypt hash.
• For two-step sign-in, the authenticator secret, stored encrypted, and the recovery codes, stored as hashes.
• For each signed-in session, the IP address and the browser's user agent.
• For a password reset, the IP address the request came from.
• An activity log of sign-ins, account changes and content changes, with the IP address of each.
• The posts, images and files portal users upload, and the emails the portal sends them: welcome emails, invitations, notices and password reset codes.

PLACEHOLDER — FOR LEGAL REVIEW

• The public website sets no cookies, before or after the cookie bar is answered.
• The cookie bar keeps the visitor's answer in the browser's local storage, under the name onward-cookie-choice. The page view record above runs only when that answer is "accepted".
• The accessibility settings keep the visitor's choices (less motion, text size, contrast, underlined links, text spacing) in the browser's local storage, under the name onward-a11y, and for a moment in its session storage, under onward-a11y-return, while a page reloads to apply one. Neither is sent anywhere.
• Signing in to the portal sets two cookies. The session cookie, __Host-onward_sid, keeps the user signed in for up to 14 days; the portal cannot work without it. The second, __Host-onward_in, holds only the value 1 and tells the sign-in page that a session may exist.
• A press article can embed a video or a post from YouTube (through youtube-nocookie.com), Vimeo, LinkedIn or X. The embed loads from that service when a reader opens the article, whatever the cookie bar says.
• The cookie bar says the site uses cookies for analytics and performance. The analytics sets no cookie, so the bar's words need the same review.

PLACEHOLDER — FOR LEGAL REVIEW

• Page views show the Onward team, in the portal, how many people read each page and where they came from. They are added up into daily totals per page.
• Portal account data signs users in and keeps accounts safe: limits on repeated attempts, a lock after too many wrong codes, and the activity log. The email address also receives the portal's own emails.
• When an Anthropic API key is set, a portal user can ask for suggested alt text for an image or suggested wording for a post.

The lawful basis for each use is to be set after legal review.

PLACEHOLDER — FOR LEGAL REVIEW

• Vercel, which hosts the website and runs its server.
• The database service that stores the data below. The provider is set outside the code.
• Anthropic, only when an Anthropic API key is set and a portal user asks for a suggestion. The request sends that image, as a 960 pixel copy, or that post's text.
• An email service, when the portal sends email over SMTP. The recipient's address and the message go to the provider named in the server's settings.
• YouTube, Vimeo, LinkedIn and X, for an article that embeds one of their videos or posts.

The portal also reads Onward's own search figures from Google Search Console. That sends no visitor data. The site loads no advertising code and no third-party analytics.

PLACEHOLDER — FOR LEGAL REVIEW

• The cookie bar answer stays in the visitor's browser until the visitor clears it.
• The daily value behind the visitor code is deleted after 2 days. After that, nobody can link a stored visitor code to an IP address.
• Single page views are deleted after 35 days, once they are in the daily totals.
• The daily totals per page hold no visitor code. No end date is set for them.
• A portal session is deleted when it expires, about 14 days after sign-in.
• A password reset code is deleted once it is used or expires.
• Counts of failed sign-ins are deleted after a day, unless they still hold an account locked.
• No end date is set for portal accounts, the activity log or sent emails. An admin can turn an account off; nothing in the code deletes one.

PLACEHOLDER — FOR LEGAL REVIEW

• The website and its server run on Vercel. The region is to be confirmed.
• Page views, portal accounts, the activity log, and every uploaded image and file are stored in one PostgreSQL database. Its provider and region are to be confirmed.
• The cookie bar answer stays in the visitor's own browser.

Whether any of this leaves the UK, and on what terms, is to be set after legal review.

PLACEHOLDER — FOR LEGAL REVIEW

The rights that apply, and how to use them, are to be written after legal review.

• The portal has no way for a user to download or delete their own account. An admin can turn an account off.
• A visitor can take back analytics consent by clearing the site's storage in the browser; the cookie bar then asks again. The site has no link to change the answer.

PLACEHOLDER — FOR LEGAL REVIEW

The contact for privacy questions, and the route for a complaint, are to be added after legal review.

The site's enquiries address today is pdonnelly@onwardev.co.uk.