Personal Information Collection
Stratechery may collect and use the following kinds of personal information:
- We use third third-party vendors, identified below, to help with delivery of the Content and processing of your payment. We never see your full credit card number, which is handled through Stripe;
- If you participate in the Stratechery Forum, you will create additional user-generated content, which is used for the Stratechery Forum only.
Legal Basis for Collection of Information
Stratechery asserts the following legal grounds for the collection of data:
When you sign up for any Content (either free or paid) or any other account at Stratechery.com, you provide explicit consent for Stratechery to collect the above listed personal information.
If you enter an agreement with Stratechery for the provision of services in exchange for payment, Stratechery will be required to collect the above listed personal information.
Finally, Stratechery may have additional legitimate interests, including account maintenance and administrative purposes, for the collection of the above listed personal information.
Using Personal Information
Stratechery may use your personal information to:
- fulfill or meet the reason you provided the information. Specifically, access to the Content. If you provide your personal information to purchase Content, a product, or service, we will use that information to process your payment and facilitate delivery.
- create, maintain, customize, and secure your account with Stratechery.
- provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- administer Stratechery and the Content;
- personalize the website for you by displaying your name or changing the appearance of the website according to your settings if you log in;
- enable your access to and use of the Content and the website services;
- deliver the Daily Update podcast to subscribers;
- deliver the Dithering podcast to subscribers;
- send to you the newsletter and account-related email;
- send to you statements and invoices;
- collect payments from you;
- collect your personal information or as otherwise set forth in the GDPR, CCPA, or the applicable laws.
- prevent transaction fraud;
- respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and
- send you marketing communications.
Where Stratechery discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement. Except for the third-party vendors that collect your data separately when you sign up and pay, Stratechery does not share any of its user data with any third parties.
Stratechery uses the following data processors with respect to the personal information collected:
3rd-party Service Providers
In addition, Stratechery uses the following 3rd-party service providers for certain content served on Stratechery.com. By using Stratechery you are accessing these services. Stratechery does not provide or receive any personal information to or from these services.
In addition, by using Stratechery.com you are accessing Memberful, Stripe, and WPEngine.com, but Stratechery does not provide or receive any personal information to or from these services unless you are a subscriber.
Stratechery LLC also administers the distribution and collection of subscription fees for the Dithering Podcast, operated by Dithering, LLC.
Sales of Personal Information
In the preceding twelve (12) months, Stratechery has not sold personal information. In addition, Stratechery has no intention of ever selling personal information.
Data Retention Policy
Securing Your Data
Stratechery will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. If Stratechery stores any of your data, it will do so on secure servers.
Be advised that Stratechery does not monitor Stratechery Forum posts for disclosure of any personal information you may post in any user-generated content. The forum software (Discourse) includes tools allowing you to edit or delete your posts. If you need assistance, you may contact Stratechery with the contact information below.
Cross-border Data Transfers
In addition, personal information that you post to the Stratechery Forum will be published on the internet and may be available around the world.
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register with the Website or Newsletter. If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is allowed to provide any personal information to or on Stratechery. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.
California Online Privacy Protection Act Notice
(1) Stratechery does not track users, who interact with its website across the web, and therefore does not use “do not track” signals.
(2) Stratechery does not authorize the collection of personally identifiable information from users on any Stratechery website for third party use through advertising technologies.
GDPR and CCPA Compliance
Stratechery seeks to fully comply with the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other laws and regulations protecting consumer privacy. As such, you have the following rights on this website:
- Right to be forgotten: You may cancel your account at any time. If you wish your data to be permanently deleted, you may contact us at firstname.lastname@example.org and it will be deleted within 72 hours.
Right to object: We have never performed any data science projects on user data and do not anticipate doing so in the future. If, at some point in the future we determine a use for any sort of data science project on our user data, we will notify you in writing before doing so. In that event you may remove your contact data from any such project by emailing us at email@example.com with the subject line “Opt Out of Data Science”.
Right to access and rectification: You can contact us at firstname.lastname@example.org at any time to access copies of all user data we retain for you. We will remove, update, or change any personal information about you from our servers immediately upon your request.
Right of portability: We only retain your name and email address. Nevertheless, we will provide that information to you upon your request.
Without prejudice to any other administrative or judicial remedy, if located in the European Union, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
In addition to the above, an “unsubscribe” option is automatically included in the footer of every newsletter sent from the Stratechery. This allows you to easily unsubscribe from the newsletter. In the event you unsubscribe, we will immediately stop sending you the newsletter. Please note that unsubscribing from the newsletter with the newsletter’s “unsubscribe” button does not cancel your account with Stratechery LLC. In order to do so, please log in at Stratechery.com and cancel your account.
Stratechery will not discriminate against you for exercising any of your GDPR, CCPA, or other consumer privacy rights. Unless permitted by law, Stratechery will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, the nature of the services provided by Stratechery, a membership website, newsletter, and podcast feed, will require basic information including an active account and your email address in order for Stratechery to provide its services. Should you opt out entirely, Stratechery will be unable to provide you any of its services.
Statement of Rights and Choices with the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Below is a summary of information collected by category.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||YES|
|C. Protected classification characteristics under California or federal law.||NO|
|D. Commercial information.||YES|
|E. Biometric information.||NO|
|F. Internet or other similar network activity.||YES|
|G. Geolocation data.||YES|
|H. Sensory data.||NO|
|I. Professional or employment-related information.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||NO|
|K. Inferences drawn from other personal information.||YES|
Disclosure of Personal Information for a Business Purpose
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category D: Commercial information.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category K: Inferences drawn from other personal information.
Access to Specific Information and Data Portability Rights
You have the right to request that Stratechery disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information Stratechery collected about you.
- The categories of sources for the personal information Stratechery collected about you.
- Stratechery’s business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom Stratechery shares that personal information.
- The specific pieces of personal information Stratechery collected about you (also called a data portability request).
- If Stratechery sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Stratechery delete any of your personal information that Stratechery collected from you and retained, subject to certain exceptions. Once Stratechery receives and confirms your verifiable consumer request, Stratechery will delete (and direct our service providers to delete) your personal information, unless an exception applies.
Stratechery may deny your deletion request if retaining the information is necessary for Stratechery or its service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling Stratechery at +1 (714) 202-6571, or
- Sending a letter to us at Stratechery, LLC at 2093 Philadelphia Pike #9930, Claymont, Delaware, 19703, USA
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows Stratechery to reasonably verify you are the person about whom Stratechery collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows Stratechery to properly understand, evaluate, and respond to it.
Stratechery cannot respond to your request or provide you with personal information if Stratechery cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with Stratechery. Stratechery will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
Stratechery endeavors to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), Stratechery will inform you of the reason and extension period in writing.
If you have an account with Stratechery, Stratechery will deliver its written response to that account. If you do not have an account with Stratechery, Stratechery will deliver its written response by mail or electronically, at your option.
Any disclosures Stratechery provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Stratechery provides will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, Stratechery will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Stratechery does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Stratechery determine that the request warrants a fee, Stratechery will tell you why it made that decision and provide you with a cost estimate before completing your request.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of Stratechery’s website that are California residents to request certain information regarding Stratechery’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
Updating This Statement
Stratechery.com, the Newsletter, Podcast, and Dithering contain links to other websites and embedded links to other content on the Internet, such as tweets and YouTube videos. Stratechery LLC is not responsible for the contents of those third-party websites or responsible for the privacy policies or practices of any third party.
by email to firstname.lastname@example.org; or
by post to 2093 Philadelphia Pike #9930, Claymont, Delaware, 19703
Updated May 7, 2020