Privacy Policy for Cranmer’s Substack

Effective Date: February 2025

Cranmer’s Substack, authored by Philip Crump, is committed to protecting your privacy. This Privacy Policy governs the collection, use, and protection of personal information in connection with this publication, which provides commentary on politics, culture, and law. It supplements Substack’s Privacy Policy, which applies to data processed by the Substack platform. By subscribing to, or engaging with, Cranmer’s Substack, you agree to the terms set out below.

1. Scope and Responsibility

This Privacy Policy applies to personal information collected by Philip Crump, acting as the data controller, through subscriptions, comments, direct correspondence, and related interactions with Cranmer’s Substack. Substack’s independent data practices are governed by its Privacy Policy.

2. Collection of Personal Information

Subscribers provide email addresses via Substack. Names or contact details may be collected if provided directly, for example, via email or promotional activities. For paid subscribers, names and subscription details are processed by Stripe, Substack’s payment provider; payment card details are not accessible to the author. Comments submitted by subscribers include names or pseudonyms and content, which may be visible to other subscribers unless otherwise restricted by Substack’s settings.

Substack uses cookies or similar technologies to enhance user experience, analyse usage, and deliver content, which may collect data such as IP addresses or browsing behaviour. This data may be processed in the United States or other countries, subject to Substack’s Privacy Policy. The author does not directly collect or process data via cookies and does not use additional tracking or analytics cookies beyond those used by Substack.

The author receives aggregate analytics from Substack, including page views, open rates, and subscriber counts, to understand readership trends. Substack also provides individual subscriber engagement data, such as usage patterns and open rates, to support content delivery. The author may rely on Substack’s automated systems to personalise content delivery based on engagement data.

3. Use of Personal Information

Email addresses are used to distribute free and paid content. Subscription details facilitate billing and access management. Comments may inform content development or facilitate interaction, subject to editorial discretion. Engagement data supports publication management and legal compliance, such as tax obligations. Correspondence is used to respond to inquiries.

4. Disclosure and International Data Transfers

Substack processes subscription and analytics data; Stripe processes payment information. Data collected via Substack or Stripe is primarily stored in the United States and may be processed in other countries where these platforms operate, subject to their privacy practices and safeguards, such as contractual clauses. Substack’s participation in the Data Privacy Framework provides additional protections for data transferred from the EU, UK, or Switzerland. By subscribing, you consent to these transfers for the purposes outlined in this policy.

Personal information is not disclosed to third parties except as required by law, to protect the author’s legal rights, or with subscriber consent. The author does not sell, trade, or share personal information for commercial purposes.

5. Retention and Security

Subscription data is accessible to the author during an active subscription and removed upon unsubscription via Substack. After unsubscription, Substack may retain data in accordance with its Privacy Policy, over which the author has no control. Comments are retained unless removed by the author. Correspondence may be retained for up to two years for administrative purposes, after which it is deleted unless legally required.

The author relies on the security measures of Substack and Stripe, including encryption and access controls, to protect personal information. To the fullest extent permitted by law, the author expressly disclaims liability for any data breaches or security incidents arising from Substack’s or Stripe’s systems, as these are beyond the author’s control. Subscribers acknowledge that responsibility for such breaches rests with Substack or Stripe, as the case may be, in accordance with their respective terms and conditions.

The author retains ownership of the subscriber email list collected through Cranmer’s Substack. In the event that Cranmer’s Substack ceases to operate on Substack or for any other reason, the author may export or transfer the subscriber email list to another platform or service. Subscribers will be notified of any such transfer where practicable, and their personal information will continue to be handled in accordance with this Privacy Policy and applicable data protection laws.

6. Subscriber Rights

Under the New Zealand Privacy Act 2020, subscribers may request access to, correction of, or deletion of, their personal information held by the author, subject to legal retention requirements. Contact cranmer@substack.com to exercise these rights. Responses will be provided within 20 working days, extendable with notice in certain circumstances.

Subscribers outside New Zealand may have additional rights under their local laws, such as GDPR for EU residents or the California Consumer Privacy Act for Californian residents, and should refer to Substack’s Privacy Policy for platform-related rights. Unsubscription via Substack terminates publication-related data collection.

7. Relationship with Substack’s Privacy Policy

This Privacy Policy complements Substack’s Privacy Policy, which governs platform-specific data practices. In case of inconsistency, this policy governs the author’s handling of personal information, while Substack’s policy applies to its platform operations.

8. Amendments

This Privacy Policy may be updated periodically. Subscribers will be notified of material changes via email or a Substack post. Continued engagement constitutes acceptance of the updated Privacy Policy.

9. Contact and Complaints

For inquiries or complaints, contact Philip Crump at cranmer@substack.com. Unresolved complaints may be directed to the Office of the Privacy Commissioner (privacy.org.nz). Subscribers outside New Zealand may contact their local data protection authority, as outlined in Substack’s Privacy Policy.