Privacy Policy

Effective Date: 10.04.2025

This Privacy Policy describes how GROW Substack ("we", "our", or "the publication") collects, uses, and protects your personal information. By subscribing or interacting with this publication, you agree to the terms below.

1. Data We Collect

When you subscribe or engage with this publication, we may collect:

• Email address (for sending newsletters and updates)

• Name (if optionally provided)

• Interaction data (e.g. open rates, clicks, via Substack analytics)

• Comments or messages you voluntarily post or send

We do not knowingly collect sensitive personal data.

2. How We Use Your Data

We use your data to:

• Deliver newsletters and updates you’ve signed up for

• Communicate directly (e.g. announcements or responses)

• Understand audience engagement (using Substack analytics)

We do not sell your data or use it for third-party advertising.

3. Who Has Access

Your data is accessed by:

• The publisher (GROW Substack)

• Substack, our technology provider (view Substack’s Privacy Policy)

We do not share your information with third parties, except as required by law.

4. Cookies and Analytics

Substack may use cookies or similar technologies to support performance, analytics, and delivery. These are covered under Substack’s Cookie Policy.

5. Your Rights

If you are in the EU, UK, or other applicable jurisdictions, you have the right to:

• Access your data

• Correct or update your data

• Request deletion (“right to be forgotten”)

• Withdraw consent at any time

To exercise any of these rights, email bromley.ryan(at)gmail.com. You can also unsubscribe at any time using the link in each email.

6. Data Security

Reasonable security measures are in place to protect your data. However, no system is fully secure, and we cannot guarantee absolute protection.

7. Data Retention

We retain your data only as long as needed to provide the service or comply with legal obligations. If you unsubscribe, your email will be removed from active lists but may remain in backup systems for a limited time.

8. Comments and Public Contributions

If you comment on posts or notes, you understand that:

• Your comments may be visible to other readers

• You are responsible for the content you post

• We reserve the right to moderate, remove, or highlight comments at our discretion, with or without explanation

By submitting a comment, you grant us a non-exclusive, royalty-free, perpetual licence to display, reproduce, or quote your comment within this publication and in related media, including but not limited to articles, books, newsletters, and promotional materials, with appropriate attribution.

9. Contact

For any questions or concerns, contact bromley.ryan(at)gmail.com.