Privacy Policy for Cranmer’s Substack

Effective Date: 27 February 2025

This Privacy Policy governs the collection, use, and protection of personal information by Philip Crump in connection with Cranmer’s Substack, a publication providing commentary and analysis on politics, culture, and law. This policy supplements Substack’s Privacy Policy, which applies to data processed by the Substack platform. By subscribing to or engaging with Cranmer’s Substack, you consent to the practices described herein.

1. Scope and Responsibility

Cranmer’s Substack is authored by Philip Crump, who is responsible for the handling of personal information as outlined in this policy.

This policy applies to personal information collected through subscriptions, comments, direct correspondence, and related interactions with this publication. It does not govern Substack’s independent data practices, which are addressed in its own policy.

2. Collection of Personal Information

Email addresses are collected via Substack for all subscribers. For paid subscribers, names and subscription details are processed through Stripe, Substack’s payment provider; payment card details are not accessible to the author.

Paid subscribers who submit comments provide their name (or pseudonym) and comment content, which are visible to the author.

Personal information, such as names or contact details, may be collected if provided directly via email or other means (e.g., promotional activities).

Substack provides the author with aggregate data, including views, open rates, and subscriber counts.

Substack also provides the author with individual subscriber engagement and usage data, including viewer engagement and open rates.

3. Use of Personal Information

Email addresses are used to distribute newsletters—free content to all subscribers and exclusive content to paid subscribers. Subscription details facilitate billing and access management.

Comments may be used to inform content development or facilitate interaction, subject to editorial discretion.

Personal information, including subscriber engagement and usage data, may be used to manage the publication, comply with legal obligations (e.g., tax), or respond to inquiries.

Artificial intelligence tools do not directly process subscriber personal information beyond aggregated analytics provided by Substack.

4. Disclosure of Personal Information

Substack processes subscription and analytics data; Stripe processes payment information.

Personal information is not disclosed to third parties except as required by law, to protect the author’s legal rights, or with subscriber consent.

Personal information is not sold, traded, or otherwise shared for commercial purposes.

5. Retention and Security

Subscription data is retained for the duration of an active subscription and deleted from the author’s access upon unsubscription via Substack. Comments are retained unless removed by the author. Correspondence may be archived for administrative purposes.

The author relies on Substack and Stripe’s security measures, including encryption and access controls, to protect personal information. No additional storage or processing occurs outside these platforms.

6. Subscriber Rights

Under the New Zealand Privacy Act 2020, subscribers may:
(a) Request access to their personal information held by the author;
(b) Request correction of inaccurate information;
(c) Request deletion of their information, subject to legal retention requirements.

To exercise these rights, contact the author at cranmer@substack.com. Requests will be responded to within 20 working days, extendable with notice if complex. Unsubscription via Substack terminates newsletter-related data collection.

7. Relationship with Substack Privacy Policy

This Privacy Policy is in addition to, and should be read in conjunction with, Substack’s Privacy Policy. In the event of any inconsistency, Substack’s Privacy Policy prevails to the extent of the inconsistency.

8. Amendments

This policy may be amended from time to time without prior notice, with updated versions posted on Cranmer’s Substack. Continued engagement constitutes acceptance of such amendments.

9. Contact and Complaints

For inquiries, requests, or complaints, contact Philip Crump at cranmer@substack.com.

Unresolved complaints may be directed to the New Zealand Office of the Privacy Commissioner (privacy.org.nz).