Privacy Notice

Who is responsible

Hawk Thorne is responsible for the personal data processed through this website. For contact details, see our Imprint. You can reach the data-protection contact at the address given there.

What data we collect

Data you provide: when you subscribe to a briefing, we collect your email address and the briefings you select. If you contact us, we collect the information you choose to send.

Data collected automatically: when you visit the site, we and our analytics providers collect limited technical and usage data, such as pages viewed, approximate location derived from IP address, device and browser type, and interaction events. This is described in our Cookies Notice.

Why we process it, and our legal basis

We send you the briefings on the basis of your consent, given when you subscribe and withdrawable at any time through the unsubscribe link in every edition. We process account and payment data to provide any paid subscription you take out (performance of that contract) and to meet our legal obligations, and we operate and secure the website on the basis of our legitimate interest in running it. Analytics data is processed on the basis of your consent, which you may withdraw at any time.

We do not use your data for automated decision-making that produces legal effects, and we do not sell personal data.

Subscribers and payments

If you take out a paid subscription, you give us an email address and your payment is handled by Stripe. Stripe collects and processes your card and payment details as an independent controller under its own privacy policy; we do not see or store your full card number.

We store subscription and account records (such as your email, subscription status and billing history) in Google Firestore, and we send sign-in ("magic") links and account emails through our email provider. Billing and invoice records are kept for the statutory tax-retention period set out below.

Sharing and processors

We share personal data only with service providers who process it on our behalf under contract, including our email-delivery provider, the payment and subscription providers named above, and our analytics providers. Our analytics providers, Google (Google Analytics) and Microsoft (Microsoft Clarity), process data in the United States under the EU-US Data Privacy Framework; you may ask us for details. We may also disclose data where required by law or regulation.

How long we keep it

We keep your newsletter email until you unsubscribe and delete it within 30 days afterwards. Billing and invoice records are retained for the statutory tax-retention period (in Poland, five years from the end of the year to which they relate). Analytics data is retained for up to 14 months (Google Analytics) and up to one year (Microsoft Clarity), then aggregated or deleted.

Your rights

Subject to applicable law, you have the right to access the personal data we hold about you, to have it corrected or erased, to restrict or object to its processing, to receive it in a portable format, and to withdraw any consent you have given. You can unsubscribe from any briefing using the link in every edition.

To exercise any of these rights, contact us using the details in our Imprint. You also have the right to lodge a complaint with a data-protection authority. For users in Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa); you may also complain to the authority in your own country of residence.