You agree to the privacy policy below, and the Privacy Policy for Substack, the technology provider.
Privacy Policy
1. General Provisions
1.1. This Privacy Policy describes the procedures for collecting, storing, using, and protecting the personal data of Users provided when subscribing to the Newsletter.
1.2. Using the Newsletter constitutes the User’s unconditional consent to the terms of this Policy, as well as an acknowledgment of it prior to providing personal data, if technically feasible.
2. Collection and Processing of Personal Data
2.1. When subscribing, the User provides their email address and, possibly, other contact details. Additionally, data such as the IP address, browser type, access time, and other technical information may be automatically collected through standard analytics tools.
2.2. Legal Basis. The processing of personal data is carried out based on the User’s consent provided at the time of subscription, as well as for the fulfillment of contractual obligations with the User.
2.3. If the User is a citizen of a country where the General Data Protection Regulation (GDPR) or other similar legislation (for example, CCPA) applies, the User has additional rights as listed in Section 2.8.
3. Purposes of Processing Personal Data
3.1. The primary purpose of processing is to deliver analytical materials and informational notifications related to the Newsletter.
3.2. Additionally, personal data may be used for analytics, improving content quality, and optimizing the operation of the platform; however, data will not be used for other purposes without the separate consent of the User.
4. Transfer of Personal Data to Third Parties
4.1. Users’ personal data is not transferred to third parties, except in the following cases:
- Transfer of data to authorized government agencies in the manner provided by law;
- Transfer of data to service providers (for example, the Substack platform, analytics services) that are obligated to use the data solely for purposes related to the operation of the Newsletter and to observe security measures in accordance with legal requirements.
4.2. In cases of international data transfers, measures will be taken to ensure adequate protection of the information in accordance with applicable law.
5. Security Measures
5.1. The Author takes all reasonable organizational and technical measures to protect Users’ personal data from unauthorized access, loss, alteration, or disclosure.
5.2. Despite these measures, the Author cannot guarantee absolute security of data when transmitted over the internet.
6. Use of Cookies and Similar Technologies
6.1. When using the Newsletter, cookies and similar technologies may be employed to enhance functionality, analyze statistics, and personalize content.
6.2. The User can adjust browser settings to manage the use of cookies; however, this may affect the correct display or operation of the platform. If necessary, additional information about cookies (for example, a separate cookie policy) may be provided.
7. Retention Period of Personal Data
7.1. Personal data is retained until the User unsubscribes from the Newsletter or until the User requests the deletion of their data.
7.2. Upon request, the User’s personal data will be deleted within a reasonable timeframe, except in cases provided by law where data is subject to mandatory retention.
8. User Rights
8.1. The User has the right to:
- Request information regarding their personal data held by the Author.
- Request correction, updating, or deletion of their data.
- Restrict the processing of their data or object to its processing.
- Withdraw previously given consent for the processing of personal data (however, processing based on legal grounds will continue).
8.2. To exercise these rights, the User may submit a request using the contact details provided in Section 3.
9. Changes to the Privacy Policy
9.1. The Author reserves the right to amend this Privacy Policy. The new version will become effective upon its publication on the platform.
9.2. It is recommended to periodically review the current version of the Policy to stay informed of any changes.
Contact Information
1. Feedback
For any questions related to this Agreement, the Terms of Service, or the Privacy Policy, as well as to exercise your rights, the User may contact the Author via the Substack platform or by email: adlerscryptoinsights@substack.com
2. Additional Information
If the User believes that their rights regarding the processing of personal data have been violated, they have the right to contact the supervisory authorities in accordance with applicable U.S. law.