Privacy Policy

1. Who We Are

The Plains Ledger is a newsletter and commentary publication operated by Josh Dambacher ("we," "us," or "our"), accessible at www.theplainsledger.com. For privacy matters, Josh Dambacher is the data controller.

This policy applies to personal data collected through this website and through our newsletter subscription service. It is intended to comply with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), the California Consumer Privacy Act (CCPA), and the US CAN-SPAM Act.

2. What Data We Collect

We collect the following categories of personal data:

• Email address — collected when you subscribe to The Plains Ledger newsletter via our subscription form, which is operated by Kit (formerly ConvertKit).
• Usage data — collected automatically via Google Analytics, including your IP address (anonymised), browser type, pages visited, time on site, and referral source.
• Email engagement data — collected by Kit, including whether you open our emails and whether you click links within them.

We do not collect your name, postal address, payment details, or any special category data (such as health, political opinion, or ethnicity) unless you volunteer it by contacting us directly.

3. How We Use Your Data

We use your personal data for the following purposes:

• To send you The Plains Ledger newsletter, which you have subscribed to receive.
• To understand how our website is used, so we can improve the quality and relevance of our content (via Google Analytics).
• To manage our subscriber list, including processing unsubscribe requests.
• To comply with our legal obligations under applicable law.

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal Basis for Processing (UK & EU GDPR)

We rely on the following legal bases to process your personal data:

• Consent — when you subscribe to the newsletter, you consent to receiving it. You may withdraw this consent at any time by unsubscribing.
• Legitimate interests — we use Google Analytics on the basis of our legitimate interest in understanding how our content performs. We have assessed that this interest is not overridden by your rights, given the anonymised nature of the data collected.

5. Third-Party Services (Data Processors)

We use the following third-party services that may process your personal data on our behalf:

• Kit (formerly ConvertKit) — our newsletter platform, which stores your email address and manages sending and unsubscribing. Kit is based in the United States. Data transfers are covered by Standard Contractual Clauses. Kit's privacy policy is available at kit.com/privacy.
• Google Analytics — we use Google Analytics 4 to collect anonymised usage data. IP addresses are anonymised. Google's privacy policy is available at policies.google.com/privacy. You may opt out of Google Analytics tracking via the Google Analytics Opt-out Browser Add-on.
• Netlify — our website hosting provider. Netlify may process server log data including IP addresses. Netlify's privacy policy is available at netlify.com/privacy.

We do not sell your personal data to third parties. We do not share your email address with advertisers or any party outside of those listed above.

6. International Data Transfers

Our newsletter platform (Kit) and analytics provider (Google) are based in the United States. Where data is transferred from the UK or EU to the United States, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the relevant supervisory authority.

7. How Long We Keep Your Data

We retain your email address for as long as you remain a subscriber to The Plains Ledger. If you unsubscribe, your data will be removed from our active mailing list. You may also request complete deletion of your data at any time (see Section 8 below).

Anonymised Google Analytics data is retained in accordance with Google's standard retention periods.

8. Your Rights

Depending on your location, you have the following rights regarding your personal data:

• Right of access — you may request a copy of the personal data we hold about you.
• Right to rectification — you may ask us to correct inaccurate data.
• Right to erasure — you may ask us to delete your personal data. You can also unsubscribe directly from any newsletter email.
• Right to restrict processing — you may ask us to limit how we use your data in certain circumstances.
• Right to data portability — you may request your data in a commonly used, machine-readable format.
• Right to object — you may object to processing based on legitimate interests.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time by unsubscribing from the newsletter.

California residents have additional rights under the CCPA, including the right to know what personal information is collected, the right to delete, and the right to opt out of the sale of personal information. We do not sell personal information.

To exercise any of these rights, please contact us using the details in Section 10.

9. CAN-SPAM Compliance

All emails sent by The Plains Ledger comply with the US CAN-SPAM Act. Specifically:

• Every email clearly identifies the sender.
• Every email includes a clear and functioning unsubscribe mechanism.
• Unsubscribe requests are honoured promptly.
• Emails are not deceptive in subject line or header information.

You may unsubscribe from our newsletter at any time by clicking the unsubscribe link in any email we send you, or by contacting us directly.

10. Cookies

This website uses cookies set by Google Analytics to collect anonymised usage data. These are analytics cookies only. We do not use advertising cookies, tracking pixels for third-party advertising, or cookies for any purpose other than understanding how this site is used.

You may disable cookies in your browser settings at any time. Doing so will not affect your ability to read content on this website, though it will prevent Google Analytics from collecting data about your visit.

11. Complaints

If you are located in the UK and believe we have handled your personal data unlawfully, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

If you are located in the EU, you have the right to complain to your local supervisory authority.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page reflects when the policy was last revised. We will not materially reduce your rights under this policy without notice.