Last updated: September 19, 2026.

1. Who is behind this site

deyirviel.com is the personal portfolio site of Yirviel Somé (the “site owner”), a financial analyst based in Casablanca, Morocco. This policy explains, in plain language, what personal data the site collects and what happens to it.

For the purposes of data-protection law — Law 09-08 (Morocco) and, where applicable, the EU General Data Protection Regulation (GDPR) — the data controller is the site owner: Yirviel Somé, Casablanca, Morocco. You can reach the controller at [email protected]. The site is operated by an individual, not a company, and has no data protection officer.

2. What personal data is collected

Data you submit. The main personal data collected through the Site is your email address, and only if you subscribe to the newsletter (the subscribe field in the footer of every page, or the Feed & Subscription page). No name, address, or other data is required to subscribe.

Data you send directly. If you email the site owner (for example, using a mailto: link or the address above), the content of your message, your email address, and any information you choose to include are received and stored in the site owner’s email account.

Data stored on your own device. The Site uses your browser’s localStorage to remember your light/dark theme preference and the horizontal scroll position of the navigation menu. This data stays in your browser on your device; the Site’s own code does not transmit it to the site owner.

Data collected automatically. The Site itself runs no analytics and sets no cookies. However, the Site is hosted and delivered through third-party infrastructure, and your browser contacts third-party services used to render certain pages (see section 5). As with any host or CDN, those providers may keep short-lived server logs that typically include your IP address, browser type, device type, and requested URL. The Site’s own pages that embed a PDF also load a reader library from a third-party CDN, and pages with formulas load a math-rendering library from another CDN; those requests likewise reach those providers.

Special categories. The Site does not ask for, and does not seek, special-category data (such as health, religious, or political information). Please do not send such data.

3. Why data is collected and how it is used

  • Email address (newsletter): to send the BVC disclosure digest and related site announcements. The digest contains a summary of new regulatory disclosures published by the AMMC for Casablanca Stock Exchange companies; it is sent per batch of new disclosures, not on a fixed schedule. Every email includes a one-click unsubscribe. Signing up triggers a confirmation email (double opt-in) that you must confirm before any mailings begin.
  • Email correspondence: to read, answer, and keep a record of your message.
  • Theme and menu preference (localStorage): so the Site renders the way you chose on your next visit.
  • Security and operation: server logs from the host/CDN are used to deliver the Site, prevent abuse, and diagnose faults.
  • The Site does not sell, rent, or trade personal data, and does not use it for advertising or profiling.

Legal bases.

  • Newsletter email: your consent, given when you tick the consent box and confirm the double opt-in email. You can withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
  • Email correspondence: the site owner’s legitimate interest in answering people who contact them.
  • localStorage: strictly necessary for the preference to work; it is not used to identify you.
  • Server logs: the legitimate interests of the site owner and its providers in operating, securing, and improving the service.

4. Cookies, localStorage, and tracking

The Site sets no cookies and uses no analytics, advertising, or cross-site tracking. No consent banner is shown because no cookie is placed. The only client-side storage is the localStorage entries described above, which remain on your device and can be cleared at any time through your browser settings. Because localStorage is not a cookie and is not used to track you across sites, it is not shared with anyone.

5. Sharing with third parties

  • Buttondown (buttondown.com) — the newsletter provider and the only processor of subscriber data. When you subscribe, your email address is transferred to Buttondown’s servers (based in the United States), which store it and deliver the emails. Buttondown acts as a data processor on the site owner’s behalf under a data-processing agreement, with standard contractual clauses as the safeguard for the cross-border transfer. Because transfers of personal data outside Morocco require prior authorization under Article 31 of Law 09-08, the site owner is obtaining that authorization together with the CNDP declaration referenced in section 11; this section will be updated with the authorization reference once granted. For EU-based subscribers, the transfer relies on Buttondown’s standard contractual clauses under GDPR Chapter V.
  • Cloudflare, Inc. — the Site is hosted on Cloudflare Pages, and pages that embed a PDF load the pdf.js reader from Cloudflare’s cdnjs CDN. As with any host or CDN, Cloudflare’s servers may record standard request data (IP address, browser type, device, requested URL) for a limited period, under Cloudflare’s own privacy policy and data-processing terms.
  • jsDelivr (cdn.jsdelivr.net) — serves the MathJax math-rendering library on blog or project pages that contain mathematical formulas. The request reveals your IP address and browser information to that CDN.
  • Email and social platforms — if you follow links to LinkedIn, GitHub, or a publisher’s site, you leave the Site and become subject to that platform’s terms and privacy policy.
  • Legal and safety. Data may be disclosed where required by law, regulation, or valid legal process, or where necessary to protect the rights, safety, or property of the site owner or others.
  • No analytics provider is in use. The Site does not load Google Analytics, Plausible, or any similar tracking service, and it does not share data with advertising networks.

6. International transfers

The site owner is based in Morocco. Subscriber data is stored by Buttondown in the United States, and the Site is delivered through Cloudflare’s global network. Where personal data is transferred outside Morocco, the site owner relies on the safeguards described in section 5, including standard contractual clauses and the Article 31 authorization application under Law 09-08. Where the GDPR applies, such transfers rely on the European Commission’s standard contractual clauses or another lawful transfer mechanism.

7. How long data is kept

  • Email addresses are retained by Buttondown until you unsubscribe or request deletion. Unsubscribing removes you from the active mailing list; a minimal record may be kept on a suppression list to ensure you are not re-added, and to evidence your choice.
  • Direct email correspondence is kept for as long as needed to deal with the matter and for a reasonable period afterwards for record-keeping.
  • localStorage data on your device persists until you clear your browser’s stored site data.
  • Third-party server/CDN logs are kept in line with each provider’s published retention policies.

8. Security

Reasonable technical and organizational measures are used to protect personal data, including HTTPS delivery and relying on established providers with their own security programs. However, no method of transmission or storage is completely secure, and the site owner cannot guarantee absolute security. If you believe your data has been compromised, contact the site owner using the details in section 9.

9. Your rights and how to contact the site owner

Under Moroccan law — Law 09-08 on the protection of individuals with regard to the processing of personal data — and, for visitors in the European Union, under the GDPR, you may:

  • access a copy of the personal data held about you;
  • rectify inaccurate or incomplete data;
  • delete (erase) your data;
  • object to its processing, including to direct marketing at any time;
  • restrict its processing;
  • ask for your data in a portable, machine-readable format (EU visitors);
  • withdraw consent at any time (for the newsletter, use the one-click unsubscribe link in any email); and
  • not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. The site owner does not carry out such automated decision-making or profiling.

To exercise any of these rights, contact the site owner by email at [email protected]. Your request will be handled without undue delay and, where the GDPR applies, within one month. You may also lodge a complaint with the CNDP (Commission Nationale de Contrôle de la Protection des Données à Caractère Personnel), the Moroccan data-protection authority (cndp.ma). If you are in the European Union and the GDPR applies, you may lodge a complaint with your local supervisory authority. A French version of this policy is available on request.

10. Data breach notification

If a breach of personal data occurs that is likely to result in a risk to your rights and freedoms, the site owner will notify the relevant authority (the CNDP and, where the GDPR applies, the competent supervisory authority) without undue delay, and will inform affected individuals where required.

The site owner is based in Casablanca, Morocco, and processes personal data in line with Law 09-08 on the protection of individuals with regard to the processing of personal data (as amended). For visitors located in the European Union, the site applies GDPR-equivalent good practice — the principles in this policy (consent-based newsletter sign-up, purpose limitation, one-click unsubscribe, right of erasure, and transparency about data processors) are intended to meet that standard.

Declaration to the CNDP. The newsletter list is processing of personal data within the meaning of Law 09-08, so, in line with Article 5 of that law, the site owner declares this processing to the CNDP.

CNDP declaration reference (Law 09-08): pending — to be published here as soon as the declaration is filed.

12. Changes to this policy

This policy may be updated as the Site’s features change. The “Last updated” date at the top of this page reflects the latest revision; material changes will be reflected here, and, where required by law, subscribers will be informed by email. Continued use of the Site after changes take effect constitutes acceptance of the revised policy.