Privacy Policy

1. Controller

Habib Farr — postal address in the Impressum — e-mail: splitbrained@pm.me

2. Platform and hosting

This website and newsletter run on Substack, operated by Substack Inc., 548 Market Street PMB 72296, San Francisco, CA 94104, USA. Substack processes technical data (IP address, browser and device information, cookies) to deliver and secure the service — Art. 6(1)(f) GDPR. Substack Inc. is certified under the EU-U.S. Data Privacy Framework (adequacy, Art. 45 GDPR); in addition, EU Standard Contractual Clauses are incorporated in Substack's Publisher Agreement. If you create a Substack account, comment, or use platform features such as Notes, Substack acts as its own controller: https://substack.com/privacy

3. Newsletter

If you subscribe, your e-mail address is processed to deliver the newsletter — Art. 6(1)(b) GDPR — and stored for as long as you remain subscribed. E-mails sent through Substack contain the platform's built-in delivery and engagement measurement (open and click statistics, see section 2); I use the resulting statistics solely to monitor how the newsletter is performing — Art. 6(1)(f) GDPR. You can unsubscribe at any time via the link in every e-mail.

4. Your rights

You have the rights of access, rectification, erasure, restriction of processing, and data portability (Art. 15–20 GDPR). You also have the right to object at any time, on grounds relating to your particular situation, to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR). You may also lodge a complaint with a supervisory authority (Art. 77 GDPR) — e.g. the Berliner Beauftragte für Datenschutz und Informationsfreiheit.

5. No additional tracking

Beyond the platform functions above, I add no tracking, advertising, or analytics tools of my own.