Who we are
Counterpick Coach is run by FALLINGHIPPO LIMITED, a company registered in England and Wales, company number 17415391, registered office 71-75 Shelton Street, London, England, WC2H 9JQ. We decide how the personal data described here is used, which makes us the "controller" under UK data protection law. We're registered with the ICO as a data controller, reference ZC264249.
For anything about privacy, email legal@counterpickcoach.com. We're a small company and don't have a data protection officer; a director handles privacy requests.
What we collect and why
We only handle personal data in the three situations below. UK data protection law says we need a lawful reason (a "lawful basis") for each, so we've listed ours.
| When | What | Why | Lawful basis |
|---|---|---|---|
| Every visit | Your IP address, browser and device details (the "user agent"), the page you asked for, the page that linked you here, and the time. Handled by Cloudflare, our host. | To send you the page, and to protect the site from attacks and abuse. | Legitimate interests: running a website that works and is safe. |
| Visit counting (unless you switch it off) | The page address, the site that linked you here, your country, browser, operating system and device type, and how quickly the page loaded. Collected by Cloudflare Web Analytics. We only ever see totals. | To see which games and pages people use and what's slow, so we know what to fix and build next. | Legitimate interests: improving the site. You can object at any time by switching it off. |
| If you email us | Your email address, name if you give it, and what you write. | To reply, fix mistakes you report, and deal with requests and complaints. | Legitimate interests: answering you. For privacy requests and complaints, also legal obligation: the law requires us to respond. |
We don't collect anything else. We don't ask for your age, we don't track where you are beyond the country, we don't follow you across other websites, and we don't make automated decisions about you. We don't sell or share data for advertising.
When we rely on legitimate interests, we've weighed our interests against yours, with extra care because many people using the site are under 18. Our assessment is available if you ask.
Storage on your device and analytics
This section takes the place of a cookie policy. The law on cookies also covers anything else a website stores on, or reads from, your device.
What we store
We don't set any cookies of our own. We use your browser's local storage to remember your choices. Local storage stays on your device: it isn't sent to us and we can't read it.
| Name | Set by | What it does | How long |
|---|---|---|---|
cpc-state-v4 | Us (local storage) | Remembers your settings in the Overwatch tool: your role, rank band and starred heroes. Each match starts empty, so teams, bans and the map aren't kept. | Until you clear it |
cpc-hub-platform | Us (local storage) | Remembers the platform you filtered by on the home page. | Until you clear it |
cpc-r6x-state-v2 | Us (local storage) | Remembers your setup on the Siege page: your side (attack or defence) and your rank band. Each round starts empty, so the map, sites, teams and bans aren't kept. An older version of this key (cpc-r6x-state-v1) is read once for your side and rank band, then removed. | Until you clear it |
cpc-analytics-optout | Us (local storage) | Only there if you switch visit counting off. Remembers that choice. | Until you switch counting back on or clear your browser data |
__cf_bm | Cloudflare (cookie) | Helps Cloudflare tell people from bots. Only set if bot protection is switched on for the site. Its contents are encrypted. | 30 minutes after your last request |
cf_clearance | Cloudflare (cookie) | Records that you passed a security check, so you don't get asked again. Only set if Cloudflare shows you a check. | 30 minutes |
cf_chl_rc_i, cf_chl_rc_ni, cf_chl_rc_m | Cloudflare (cookies) | Used by Cloudflare's security checks to find faults in them. Only set during a check. | Short-lived (Cloudflare doesn't publish an exact time) |
The Cloudflare cookies are "strictly necessary": the law allows them without asking, because they protect the site and the people using it. Our local storage keys are allowed because they only change how the site works for you, and you can clear them whenever you like. Each game page keeps its own cpc- key, listed above once that page is live.
Visit counting
We use Cloudflare Web Analytics to count visits. On each page, a small script from static.cloudflareinsights.com reads how the page loaded and sends a report to Cloudflare. Your settings shows whether it's running. Cloudflare says it doesn't use cookies or local storage for this, and doesn't use your IP address or browser details to fingerprint or track you. It doesn't record anything you type or the part of a web address after a "?".
The law allows this kind of counting without asking first, as long as it's only used to improve the site, you're told about it, and you can easily say no. So:
- You can switch it off on the Your settings page. From the next page you open, this browser won't load the counter. Your choice is saved on your device (in
cpc-analytics-optout), so you'll need to set it again on another browser or device, or after clearing your browser data. - If your browser sends a Global Privacy Control signal, we treat that as switching it off.
- If your browser blocks local storage, we don't load the counter, because we couldn't remember a choice to switch it off.
- Ad blockers often block the counter as well. That's fine.
Clearing your saved settings
The "Clear my saved settings" button on Your settings removes everything we've stored in your browser except your visit-counting choice. You can also clear it all in your browser's settings for this site.
Cloudflare, who runs the site for us
Cloudflare, Inc. (101 Townsend Street, San Francisco, CA 94107, USA) hosts the site, delivers it from its network, protects it from attacks, provides the visit counting and forwards emails sent to our @counterpickcoach.com addresses. It acts for us under a data processing agreement, which means it may only use the data to provide its services to us and must keep it secure.
Cloudflare also uses some information about traffic on its network for its own security purposes, such as spotting attacks across many sites. For that, Cloudflare is responsible itself: see Cloudflare's privacy policy.
Emails you send us are forwarded by Cloudflare to the company's email inbox. Cloudflare keeps a log of the sender, recipient and subject line for up to 31 days and says it doesn't store the content of emails.
We don't share personal data with anyone else, unless the law requires us to (for example a court order).
Data sent outside the UK
Cloudflare is a US company and processes data on servers around the world, including in the US. Transfers to Cloudflare in the US are covered by the UK's "data bridge" with the US (the UK Extension to the EU–US Data Privacy Framework), which Cloudflare has signed up to. If that stops applying, Cloudflare's agreement with us falls back on the UK's approved contract terms for international transfers. You can ask us for more detail.
How long things are kept
| What | How long |
|---|---|
| Visit counting data | Cloudflare keeps full detail for 7 days, then keeps a sample of about 10% for up to 6 months. |
| Security records (blocked or challenged requests) | Up to 31 days in our Cloudflare dashboard. Cloudflare keeps its own security records for as long as it needs them, as set out in its privacy policy. |
| Email forwarding log | Up to 31 days at Cloudflare. |
| Emails you send us | 2 years after our last reply, then deleted. |
| Privacy requests and complaints | 3 years after they're closed, so we can show how we handled them. |
| Requests to remove content (from rights holders) | 6 years after they're closed. |
| Your saved settings | On your device until you clear them. |
Your rights
You have the right to:
- see the personal data we hold about you (a "subject access request");
- have it corrected if it's wrong;
- have it deleted;
- ask us to limit how we use it;
- get a copy of data you gave us in a form you can move elsewhere, where this applies.
You also have the right to object to any use of your data based on legitimate interests. For visit counting, the quickest way is the switch on Your settings. For anything else, email us and we'll stop unless we have a strong legal reason to carry on, which we'll explain.
To use any of these rights, email legal@counterpickcoach.com. It's free. We'll reply within one month, and tell you if we need longer for a complicated request. We may ask for information to confirm who you are. Please note we usually can't link visits to a person: we don't know who you are from analytics, so we may not hold anything about you at all. If so, we'll tell you.
How to complain
To us
If you're unhappy with how we've handled your personal data, you can complain to us. Email legal@counterpickcoach.com with "Privacy complaint" in the subject, or write to FALLINGHIPPO LIMITED, 71-75 Shelton Street, London, England, WC2H 9JQ. You don't have to use any particular words. We'll confirm we've received it within 30 days, look into it straight away, keep you updated and tell you the outcome.
To the regulator
You can also complain to the Information Commission, the UK's data protection regulator. It calls itself the Information Commission's Office, or ICO. You don't have to complain to us first, though the ICO suggests it.
- Online: ico.org.uk/make-a-complaint
- Phone: 0303 123 1113
- Post: Information Commission's Office, 4th Floor, No.3 Circle Square, 5 Hawkshaw Street, Manchester, M1 7BL
If you're under 18
Lots of people who use Counterpick Coach are teenagers, so we've built it to be private by default:
- you never have to tell us your name, age, email or where you live;
- there are no accounts, no chat, no comments and no messages from other users;
- there are no ads and nothing to buy;
- your saved choices stay on your own phone or computer;
- the visit counter only gives us totals, like "200 people opened the Overwatch tool today". It can't tell us it was you.
You have the same rights as adults, listed above. If you want to use them, or something here worries you, you can email us yourself, or ask a parent, carer or teacher to help. If you email us, please don't send more personal information than you need to.
Changes to this notice
We'll update this notice when the site changes, for example if a new game page saves something new. The date at the top shows when it last changed. If we ever want to use data in a new way that you wouldn't expect, we'll say so clearly on the site before we start.