Privacy policy

In short: this website sets no cookies and counts visits without knowing who you are. We keep your email address only if you join the early list or write to us. The full policy follows.

Privacy policy, last updated 14 October 2026. The English version is authoritative.

1. Who is responsible

The controller of the personal data described in this policy is Ville Mikael Alén, Helsinki, Finland, who runs lodemark.eu as Lodemark (company in formation). His postal address is in the legal notice. Email: hello@lodemark.eu.

When Lodemark Oy, the Finnish company being formed for Lodemark, is registered, it takes over as controller of the early list and of messages sent to us. We will update this policy and tell everyone on the early list before that happens.

We have not appointed a data protection officer, because the GDPR does not require one for this processing (Art 37 GDPR).

2. Short version

We keep nothing about your visit that identifies you. Our hosting provider processes connection data to deliver the pages and counts visits without cookies (section 3). The website sets no cookies, loads no advertising or tracking scripts, and has no accounts.
The calculator runs entirely in your browser. What you type is not sent to us or stored anywhere, and the PDF of a result is made in your browser.
If you join the early list, we keep your email address and, if you give it, your company, to tell you when a pilot opens: until you leave the list, and at most 24 months (section 5).
If you write to us by email, we keep your message and your contact details to answer you, for at most 12 months after the last contact (section 6).
To have your data deleted, write to hello@lodemark.eu. We delete it and confirm within one month.
We do not sell personal data, use it for advertising or use it to train AI models.

3. Visiting the website

The website is a set of static pages. We do not store anything about your visit that identifies you, and nothing is saved in your browser (no cookies, no local storage).

The pages are delivered by our hosting provider, Cloudflare, Inc., 101 Townsend Street, San Francisco, United States, which acts as our processor under the Cloudflare Customer Data Processing Addendum. To deliver the pages and to protect the site against attacks, Cloudflare processes connection data such as your IP address, the address of the page you request, your browser type and the time of the request, mostly at its data centres in the European Union, and keeps that data for the short periods set out in its privacy policy (cloudflare.com/privacypolicy). Where Cloudflare transfers such data to the United States, the transfer rests on Cloudflare, Inc.'s certification under the EU-U.S. Data Privacy Framework and, should that certification lapse, on the European Commission's standard contractual clauses included in the Cloudflare Customer Data Processing Addendum; you can ask us for a copy. The legal basis for this processing is our legitimate interest in delivering a working and secure website (Art 6(1)(f) GDPR). We have no access to Cloudflare's connection logs for this site.

Visit counts. We use Cloudflare Web Analytics, a service of the same provider under the same addendum and the same transfer safeguards, to see how often each page is visited, from which websites and countries visitors arrive, and how fast the pages load. A small Cloudflare script on each page reports the page address (without anything after a "?" in it), the page you came from, your browser and device type, and the load times; like every request, it reaches Cloudflare with your IP address. It sets no cookie, stores nothing on your device and does not recognise you from one visit to the next. The reports we see are totals, never individual visitors. The legal basis is our legitimate interest in knowing which pages are useful and fast (Art 6(1)(f) GDPR). You can object at any time (section 8); blocking scripts from static.cloudflareinsights.com in your browser also stops it, and the site works the same without it.

If Cloudflare suspects an automated attack it may show a challenge page and set a short-lived security cookie (cf_clearance) for that purpose only; this is strictly necessary for security and is not used to track you.

4. The calculator

The calculator works only on your device. The numbers and origins you enter, and the result, are never sent to us or to anyone else, and they are gone when you close the page unless you download the result yourself. We therefore process no personal data through the calculator.

5. The early list

If you join the early list with the form on our Contact page, we store your email address, your company if you give it, the language of the page, the date, and the version of this policy that applied, so that we can show when and how you joined.

Purpose: to tell you when a pilot opens and to invite you to one. We send nothing else to that address and share it with no one.
Legal basis: your consent (Art 6(1)(a) GDPR), which you give by sending the form. You may withdraw it at any time by writing to hello@lodemark.eu; that does not affect what was done before.
Kept: until you leave the list, and at most 24 months after you joined, when the entry is deleted automatically. If a pilot follows, its agreement says what happens next.
Where: in a Cloudflare D1 database created in Cloudflare's European Union jurisdiction, so the list is stored in the EU. Cloudflare acts as our processor, as in section 3.
Voluntary: you need not join; without an email address we cannot add you.

To stop automated sign-ups, the form keeps, for at most 24 hours, a one-way code made from the sending IP address and a random value that is replaced every day. The code cannot be turned back into the address, is stored apart from the list, and is used only to limit how often one sender can submit the form. The legal basis is our legitimate interest in keeping the list free of abuse (Art 6(1)(f) GDPR).

6. When you write to us

When you write to hello@lodemark.eu or security@lodemark.eu, we receive your name, your email address, the content of your message and anything you choose to include, such as your company or role.

Purpose: to answer you and, if you ask to join the early list by email, to tell you when a pilot opens.
Legal basis: our legitimate interest in answering messages sent to us (Art 6(1)(f) GDPR), or steps you ask us to take before a possible contract (Art 6(1)(b) GDPR).
Kept: for as long as the conversation is live and at most 12 months after the last contact, then deleted, unless a contract follows.
Who processes it: our email provider, Zoho Corporation B.V., Netherlands (Zoho Mail), stores the messages in its data centres in the European Union and acts as our processor. Zoho states that staff of Zoho group companies outside the EU may access data only in rare cases, for technical support, under the European Commission's standard contractual clauses. We share messages with no one else, except where the law requires it.

If you report a security problem, we keep your report and contact details for 24 months, to fix the problem and to follow up with you.

If we contacted you first, the privacy notice for research and outreach contacts applies to that contact and sets its own periods.

7. Pilots and customers

This policy covers the website, the early list and email only. Before a pilot customer shares any data or documents with us, it signs its own agreement and a data processing agreement, which describe that processing.

8. Your rights

Under the GDPR you may ask for access to your personal data, and for its rectification, erasure, restriction or portability; you may object to processing based on legitimate interest; and where processing rests on your consent, you may withdraw it at any time. Write to hello@lodemark.eu; we answer within one month.

Deletion: write to hello@lodemark.eu from the address concerned, or name it in your message. We delete your early list entry and your messages, and confirm within one month.

You may also complain to the Finnish Data Protection Ombudsman (Tietosuojavaltuutetun toimisto, tietosuoja.fi) or to the supervisory authority of your own country.

9. Automated decisions

This website makes no automated decisions about you. The calculator only computes a share from the numbers you enter, on your own device.

10. Children

The website is aimed at businesses. We do not knowingly collect personal data from children.

11. Changes

We update this policy when our processing changes, and the date at the top shows the current version. If a change affects the early list, we tell the people on it first.

12. Language

This policy is written in English. Any translation is for convenience only, and where they differ the English text prevails.