Privacy Policy for Cranmer’s Substack

Effective Date: 27 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 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 are visible to the author.

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.

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.

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. By subscribing, you consent to these transfers for the purposes outlined in this Privacy 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. Comments are retained unless removed by the author. Correspondence may be retained for administrative purposes.

The author relies on Substack’s and Stripe’s security measures, 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 in accordance with their respective terms and conditions.

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 if complex. Unsubscription via Substack terminates publication-related data collection.

7. Relationship with Substack’s Privacy Policy

This Privacy Policy should be read together with Substack’s Privacy Policy, which governs platform-specific data practices. In case of inconsistency, this Privacy 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 policy.

9. Contact and Complaints

For inquiries 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).