Privacy Policy / Datenschutzerklärung

1. General Information

This Privacy Policy explains how Luxe Ledger Media collects, uses, and protects personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable German data protection laws (BDSG).

The Company takes privacy seriously and processes personal data only when necessary to provide its services.

2. Data Controller

Luxe Ledger Media
Owner & Responsible Editor: Jacques Ledbetter
Email: jacques@luxeledgermedia.com
Registered Office: Hamburg, Germany

3. Data Collected

The Company may collect the following information:

• Subscriber name and email address

• Payment and billing data (handled securely by Substack or its payment processor)

• Technical data such as IP address, device type, and browser, collected automatically by Substack

• Optional information voluntarily provided by readers (e.g., comments, replies, or feedback forms)

4. Purpose of Processing

Personal data is used exclusively for:

• Managing newsletter subscriptions and paid access when necessary

• Sending new editions and service updates

• Responding to reader inquiries

• Analytics (aggregated and anonymized) to improve content and performance

No personal data is sold, rented, or shared with third parties.

5. Legal Basis for Processing

Data processing is based on:

• Article 6(1)(b) GDPR — performance of a contract (subscription delivery)

• Article 6(1)(f) GDPR — legitimate interests (analytics, platform improvement)

• Article 6(1)(a) GDPR — consent for optional communications or comments

6. Use of Substack

Subscriptions, payment processing, and email delivery are managed by Substack, Inc., headquartered in the United States.

Substack acts as a data processor under the EU–U.S. Data Privacy Framework. Its Privacy Policy is available at: https://substack.com/privacy.

Luxe Ledger Media ensures that Substack’s data processing complies with GDPR standards.

7. Data Retention

Subscriber data is retained only for as long as necessary to maintain the subscription or as required by law. Once a subscription ends, personal data is deleted or anonymized unless retention is legally required.

8. Data Rights

Subscribers have the following rights under GDPR:

• Access: Request a copy of personal data held by the Company.

• Correction: Request corrections to inaccurate or incomplete data.

• Deletion: Request deletion of personal data (“right to be forgotten”).

• Restriction or Objection: Limit or object to data processing under certain circumstances.

• Portability: Receive personal data in a commonly used, machine-readable format.

Requests may be sent to jacques@luxeledgermedia.com.

9. Data Security

The Company applies appropriate technical and organizational measures to protect data against unauthorized access, alteration, or loss. All transmissions through Substack use HTTPS encryption.

10. Cookies and Analytics

Substack may use cookies or analytics tools for performance measurement. Readers can adjust cookie preferences in their browser settings. Luxe Ledger Media does not use separate tracking cookies beyond Substack’s functionality.

11. External Links

The Publication may contain links to external websites. Luxe Ledger Media is not responsible for the privacy practices or content of these third-party sites.

12. Updates to This Policy

This Privacy Policy may be updated periodically to reflect changes in law or technology. The latest version will always be posted on this page, with the effective date clearly stated.

13. Contact for Privacy Inquiries

For any privacy-related questions or GDPR requests, contact:
Luxe Ledger Media
Email: jacques@luxeledgermedia.com
Registered Office: Hamburg, Germany