Custom Privacy Policy for Substack (Switzerland-Based)

Last Updated: March 2025

This Privacy Policy explains how this Substack publication (“the Service”) collects, uses, and protects personal data. The Service is operated by the author, a photographer based in Switzerland. This Policy is written in accordance with Swiss data protection law, including the Federal Act on Data Protection (FADP), rather than the European GDPR.

1. Purpose of Data Collection

This publication is created for personal and artistic communication. The author does not use subscriber information for commercial purposes. Personal data is collected solely to:

- Deliver newsletters to subscribers

- Share artistic, photographic, and educational content

- Manage subscription preferences

2. Data Collected

The Service only collects the following personal data:

- Email address (provided voluntarily upon subscription)

- Optional information users choose to share when interacting with posts or replies

- Technical information automatically gathered by Substack’s platform (e.g., basic analytics such as open rates)

3. Use of Personal Data

Your personal data is used exclusively to:

- Send newsletters and updates

- Manage free or paid subscriptions (if offered)

- Improve the quality and relevance of shared content

No personal data is used for advertising, profiling, or resale.

4. Legal Basis Under Swiss Law (FADP)

Under the Federal Act on Data Protection:

- Personal data is processed lawfully, in good faith, and proportionately.

- Subscription to the newsletter constitutes clear consent to receive emails.

- Users may withdraw consent at any time by unsubscribing.

5. Data Storage and Security

Data is stored securely through Substack’s infrastructure. The author does not store or process data outside the platform.

Substack may store data in servers located outside Switzerland. Their privacy and security practices apply to such storage.

6. Data Sharing

The author does not share personal data with third parties.

Substack, as the platform provider, may process data as described in its own Privacy Policy.

No data is sold, rented, or transferred for commercial purposes.

7. International Transfers

Because Substack is a U.S.-based service, data may be transferred internationally.

Use of the Service implies agreement with Substack’s handling of such transfers.

8. User Rights Under Swiss Law

Subscribers have the right to:

- Request information about their stored data

- Request correction or deletion of personal data

- Withdraw consent by unsubscribing

- Contact the author with privacy-related concerns

9. Cookies and Analytics

The Service does not use third‑party tracking tools beyond what Substack provides by default.

Substack may use essential cookies and basic analytics for platform functionality.

10. Retention Period

Personal data is retained only as long as a subscription is active.

When a user unsubscribes:

- The email address is removed from the mailing list

11. Contact Information

For questions or privacy-related requests, users may contact the author through Substack’s messaging system.

12. Changes to This Privacy Policy

This Policy may be updated periodically. Continued use of the Service constitutes acceptance of the updated Policy.