The small print. In plain sight.
Privacy policy
Last updated
This policy explains what personal data we process when you use https://torinoinsider.com, as required by Article 13 of the EU General Data Protection Regulation (GDPR, Reg. 2016/679) and the Italian Privacy Code (D.Lgs. 196/2003).
1. Data controller
Hakan Ay. Contact: torinoinsider@protonmail.com
2. What we collect and why
| Data | Purpose | Legal basis | Kept for |
|---|---|---|---|
| Email address and subscription status (newsletter, collected on Substack) | Managing your subscription and sending the weekly email you asked for | Your consent (Art. 6(1)(a)), which you can withdraw any time | While subscribed. After you unsubscribe, we stop newsletter sends; limited records may remain where necessary to document consent, respect your opt-out or meet legal obligations. |
| Name, email and message content (when you email us) | Replying to you; handling business enquiries | Steps at your request / legitimate interest (Art. 6(1)(b),(f)) | Up to 24 months, or as required for accounting |
| Technical logs (IP address, browser, pages requested) | Delivering the site securely and preventing abuse | Legitimate interest (Art. 6(1)(f)) | Per the hosting provider's retention, normally a few days to weeks |
We don't sell your data, build advertising profiles or make automated decisions about you.
The subscribe button takes you to Substack. This website does not collect or transmit an email address for newsletter registration, and does not embed Substack forms or scripts. On Substack, you choose whether to subscribe. Email-only sign-ups must confirm their email address before subscribing. We do not import contact lists without a valid basis for doing so.
3. Who processes data for us
- Hosting: Cloudflare Workers (Cloudflare, Inc.) (privacy policy)
- Newsletter: Substack, Inc. (privacy policy). We are the data controller for our subscriber list. Substack processes subscriber data on our behalf and also acts as a separate controller for its own platform activities, as described in its policy.
Substack's Publisher Agreement includes its Data Processing Addendum. Substack may process data outside the EU/EEA, including in the United States. Its privacy policy describes its EU–US Data Privacy Framework participation and international-transfer safeguards. The hosting provider's privacy policy explains its processing and transfer arrangements.
Substack may collect technical and email interaction data, such as opens and link clicks, and make newsletter statistics available to publishers. Its privacy policy explains the platform's collection, retention and available privacy controls. We have not added advertising pixels or third-party analytics integrations to our publication.
4. Your rights
You can ask to access, correct, delete, restrict or port your data, object to processing, or withdraw consent at any time (Articles 15–22 GDPR). Email torinoinsider@protonmail.com. Every newsletter also has an unsubscribe link.
Unsubscribing stops our newsletter; it does not delete a Substack account or subscriptions to other publications. For deletion of our subscriber records, contact us. For data Substack controls independently, use the contact and account controls in its privacy policy.
You can also complain to the Italian data protection authority, the Garante per la protezione dei dati personali.
5. Age
Subscriptions through Substack are subject to its terms of use, including its age and eligibility requirements.
6. Changes
We'll update this page if anything changes, and show the date at the top.