PRIVACY POLICY

Effective Date: 29 November 2025
Last Updated: 29 November 2025

1. INTRODUCTION

This Privacy Policy explains how Carson Wagner (”I”) collects, uses, discloses, and protects information about you when you access or use The Compass newsletter and website (the “Service”).

By using the Service, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information as described herein. If you do not agree with this Privacy Policy, you must discontinue use of the Service immediately.

2. INFORMATION I COLLECT

2.1 — Information You Provide Directly

I collect information that you voluntarily provide when you:

• Subscribe to the newsletter

• Create an account or profile

• Submit comments or interact with content

• Contact me via email or contact forms

• Participate in surveys, polls, or other interactive features

• Make purchases or transactions through the Service

This information may include:

• Name

• Email address

• Profile information

• Payment information (processed by third-party payment processors)

• Any other information you choose to provide

2.2 — Information Collected Automatically

When you access the Service, certain information may be collected automatically through cookies, web beacons, and similar tracking technologies:

• IP address

• Browser type and version

• Device type and operating system

• Pages viewed and time spent on pages

• Referring website or source

• Links clicked within the Service

• General location information (city/region level based on IP address)

• Date and time of access

2.3 — Information from Third Parties

I may receive information about you from third-party platforms and services, including:

• Substack (newsletter platform)

• Analytics providers (Google Analytics, etc.)

• Payment processors

• Social media platforms if you interact with the Service through social media

• Advertising networks and affiliate platforms

3. HOW I USE YOUR INFORMATION

I use the information I collect for the following purposes:

3.1 — Service Delivery and Communication

• Delivering newsletter content to your email inbox

• Managing your subscription and account

• Responding to your inquiries, questions, and comments

• Sending important updates about the Service, including changes to Terms or this Privacy Policy

• Providing support

3.2 — Service Improvement and Analytics

• Understanding how users interact with the Service

• Analyzing trends, usage patterns, and user preferences

• Improving content quality and relevance

• Developing new features and functionality

• Conducting research and analysis

3.3 — Marketing and Promotional Activities

• Sending promotional emails about new content, features, or offerings (you may opt out at any time)

• Personalizing content recommendations based on your interests

• Managing affiliate relationships and tracking referrals

3.4 — Legal and Security Purposes

• Enforcing the Terms of Service and other policies

• Protecting against fraud, abuse, or illegal activity

• Complying with legal obligations and responding to lawful requests from authorities

• Protecting my rights, property, and safety, as well as those of users and others

3.5 — Other Purposes

• Any other purpose disclosed to you at the time information is collected

• With your consent for specific purposes

4. HOW I SHARE YOUR INFORMATION

I do not sell your personal information to third parties. However, I reserve the right share your information in the following circumstances, at my sole discretion:

4.1 — Service Providers and Platforms

I share information with third-party service providers who assist in operating the Service, including:

• Substack: Newsletter hosting and email delivery platform

• Analytics providers: Google Analytics and similar services for understanding user behavior

• Payment processors: Stripe, PayPal, or other payment services (I do not store your complete payment card information)

• Cloud storage providers: For data storage and backup

• Email service providers: For managing communications

These service providers are contractually obligated to use your information only as necessary to provide services to me and are required to maintain confidentiality.

4.2 — Legal Requirements

I may disclose your information if and when required by law or in response to:

• Court orders, subpoenas, or other legal processes

• Requests from government authorities or law enforcement

• Legal obligations or regulations

• Protection of my legal rights or defense in legal proceedings

4.3 — Business Transfers

If I sell, merge, or transfer the Service or any assets related to it, your information may be transferred as part of that transaction. You will be notified via email or prominent notice on the Service of any such change in ownership or control.

4.4 — With Your Consent

I may share your information with third parties when you have given explicit consent to do so.

4.5 — Aggregated or De-Identified Information

I may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, or other purposes.

5. COOKIES AND TRACKING TECHNOLOGIES

5.1 — What Are Cookies?

Cookies are small text files stored on your device that help websites remember information about your visit. The Service uses cookies and similar tracking technologies to enhance user experience and collect usage data.

5.2 — Types of Cookies Used

• Essential Cookies: Necessary for the Service to function properly

• Analytics Cookies: Help me understand how users interact with the Service (e.g., Google Analytics)

• Preference Cookies: Remember your settings and preferences

• Advertising Cookies: Used by third-party advertising networks to deliver relevant ads

5.3 — Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

• View and delete cookies

• Block cookies from specific websites

• Block all cookies

• Delete cookies when you close your browser

Note that disabling cookies may affect the functionality of the Service.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout

5.4 — Do Not Track Signals

Some browsers support “Do Not Track” signals. The Service does not currently respond to Do Not Track signals, as there is no industry-wide standard for how to interpret and respond to such signals.

6. THIRD-PARTY LINKS AND SERVICES

The Service may contain links to third-party websites, services, or content. This Privacy Policy does not apply to those third-party sites or services.

I am not responsible for the privacy practices of third parties. I encourage you to review the privacy policies of any third-party sites or services you visit or use.

When you click on affiliate links or interact with third-party content, those parties may collect information about you according to their own privacy policies.

7. DATA RETENTION

I retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specific retention periods include:

• Active subscriber information: Retained while you maintain an active subscription

• Unsubscribed user information: May be retained for a reasonable period to comply with legal obligations and prevent re-subscription issues

• Analytics data: Typically retained for 26 months (Google Analytics default)

• Legal and compliance records: Retained as required by applicable law

When information is no longer needed, I will delete or anonymize it in accordance with applicable data protection requirements.

8. DATA SECURITY

I take reasonable measures to protect your information from unauthorized access, loss, misuse, alteration, or destruction. Security measures include:

• Encryption of data in transit using SSL/TLS

• Secure storage practices

• Limited access to personal information by authorized personnel only

• Regular security assessments of third-party service providers

However, no method of transmission over the internet or electronic storage is completely secure. While I strive to protect your information, I cannot guarantee absolute security. You transmit information at your own risk.

9. YOUR PRIVACY RIGHTS AND CHOICES

9.1 — Access and Correction

You have the right to access and update your personal information. You can:

• Update your email address and profile information through your Substack account settings

• Contact me directly to request access to or correction of your information

9.2 — Unsubscribe and Opt-Out

You may opt out of receiving promotional emails at any time by:

• Clicking the “unsubscribe” link at the bottom of any newsletter email

• Contacting me directly via Substack.
  

• Adjusting your subscription preferences in your account settings

Note that even if you opt out of promotional emails, I may still send you transactional or administrative communications related to your account or the Service.

9.3 — Cookie Management

You can manage cookie preferences through your browser settings as described in Section 5.

9.4 — Additional Rights (for Certain Jurisdictions)

Depending on your location, you may have additional rights under applicable privacy laws, including:

• Right to deletion: Request deletion of your personal information

• Right to data portability: Receive a copy of your information in a portable format

• Right to restrict processing: Request that I limit how I use your information

• Right to object: Object to certain types of processing

• Right to withdraw consent: Withdraw previously given consent

To exercise these rights, please contact me on Substack. I will respond to your request within the timeframe required by applicable law.

9.5 — California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information is collected, used, and shared

• Right to delete personal information

• Right to opt out of the sale of personal information (Note: I do not sell personal information)

• Right to non-discrimination for exercising privacy rights

To exercise these rights, contact me on Substack.

9.6 — European Union/EEA Rights

If you are located in the European Union or European Economic Area, you have rights under the General Data Protection Regulation (GDPR), including those listed in Section 9.4 above.

The legal basis for processing your information includes:

• Consent: When you have provided consent for specific processing activities

• Contract: When processing is necessary to provide the Service you’ve subscribed to

• Legitimate interests: When processing is necessary for my legitimate business interests

You also have the right to lodge a complaint with your local data protection authority.

10. CHILDREN’S PRIVACY

The Service is not specifically intended for children under the age of 13 (or 16 in the European Union). I do not knowingly collect personal information from children under these ages, except when explicit or implied permission is given in the pursuit of distributing the Service.

If I become aware that I have collected personal information from a child under the applicable age without parental consent, I will take steps to delete that information promptly.

If you believe I may have collected information from a child while failing to comply with applicable laws, please contact me immediately via Substack.

11. INTERNATIONAL DATA TRANSFERS

The Service is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where data protection laws may differ from those in your jurisdiction.

By using the Service, you consent to the transfer of your information to the United States and other jurisdictions as necessary to provide the Service.

12. CHANGES TO THIS PRIVACY POLICY

I reserve the right to modify or update this Privacy Policy at any time, at my sole discretion. Changes become effective immediately upon posting to the Service.

Material changes to this Privacy Policy will be communicated through:

• A notice on the Service

• An email to your registered email address

• A notice in the newsletter

Your continued use of the Service following any changes constitutes acceptance of the updated Privacy Policy. I encourage you to review this Privacy Policy periodically.

The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised.

13. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Policy or how your information is handled, please contact me at:

Carson Wagner
1776actanonverba@gmail.com
PO Box 344
Standard, CA 95373

I will respond to all reasonable requests and inquiries in a timely manner.

BY USING THE SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY AND AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED HEREIN.