Dimidium Tales

Privacy Policy

Last Updated: February the 8th, 2025

1. Introduction

This privacy policy applies to The Dimidium Archives™ ("the Publication"), a Substack publication operated by Morgan A. Drake™, an independent creator with Italian VAT registration (Partita IVA). This policy supplements Substack's general privacy policy, which can be found at https://substack.com/privacy.

2. Data Controller

The data controller for The Dimidium Archives™ is:

• E.M.V. (operating under the pen name Morgan A. Drake™) Independent Creator

• Italian VAT (Partita IVA): [17966171005]

• Contact: Through Substack's platform contact forms

3. Information We Collect

In addition to the data collected by Substack's platform, we may collect:

• Email addresses for newsletter subscription

• Names (if provided)

• Comments and interactions on posts

• Correspondence sent directly to us

4. Legal Basis for Processing

We process your data based on:

• Your consent (for newsletter subscription)

• Legitimate interests (for content improvement and communication)

• Legal obligations under Italian and EU law

5. How We Use Your Information

We use your information to:

• Deliver the newsletter

• Respond to your comments and messages

• Improve our content

• Comply with legal obligations

• Analyze engagement (in aggregate, anonymous form)

6. Data Storage and Protection

All data is stored on Substack's secure servers. We do not maintain separate databases or storage systems. For details on Substack's security measures, please refer to their privacy policy.

7. Your Rights Under GDPR

Under GDPR, you have several fundamental rights regarding your personal data. Here's how to exercise them:

For Platform-Related Data (subscription, account, payment information):

• Access, correct, or delete your data through your Substack account settings

• Contact Substack support directly for data portability requests or technical issues

• Unsubscribe from our publication using the link in any email

• Delete your Substack account through platform settings

For Publication-Specific Requests:

• Contact us through the platform for:

  • Questions about how we use your data

  • Requests to remove your comments

  • Concerns about your personal information

  • Withdrawal of consent for specific uses of your data

Note: As we operate on Substack's platform, most data management occurs through their systems. We will assist with any requests within our control and direct you to Substack support for platform-level data management.

8. International Data Transfers

As Substack is a U.S.-based platform, your data may be transferred to and stored in the United States. These transfers are governed by appropriate safeguards as required by GDPR.

9. Data Retention

We retain your data only as long as necessary to provide our services or as required by law. You can delete your subscription at any time through your Substack account settings.

10. Cookies and Tracking

We rely on Substack's cookie policy and tracking systems. No additional tracking is implemented by The Dimidium Archives™. For details, see Substack's cookie policy.

11. Changes to This Policy

We reserve the right to update this privacy policy at any time. Significant changes will be announced in the newsletter and on the publication page.

12. Supervisory Authority

Under GDPR, you have the right to lodge a complaint with your local data protection authority. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

13. Contact Information

For privacy-related questions or concerns:

To submit a privacy request:

1. Use the subject line "PRIVACY REQUEST - [Type of Request]" (e.g., "PRIVACY REQUEST - Comment Removal")

2. Email us through Substack's platform using the 'Reply to post' feature

3. Or contact us through our Substack contact form

We will respond to all legitimate privacy requests within 30 days, as required by GDPR.

Note: For account-related privacy matters (subscription settings, account deletion, etc.), please access your Substack account settings directly or contact Substack support.

This privacy policy is effective as of February the 8th, 2025 and complies with Italian law, GDPR, and Substack's platform requirements.