Privacy Policy

1. Introduction

This Privacy Policy explains how Scott Cunningham ("Scott," "we," "us," or "our") collects, uses, shares, and protects information when you subscribe to or interact with The Digital Debrief (the "Newsletter") and the website at scottcbusiness.com (the "Site"). We are based in Toronto, Ontario, Canada and act as the controller of your personal information.

The Newsletter is a free publication delivered through beehiiv, Inc. ("beehiiv"). beehiiv processes data on our behalf as our email service provider; their handling of your information is also governed by beehiiv's Privacy Policy.

2. Information We Collect

We collect the following categories of information:

• Information you provide. Email address (required to subscribe), and any optional details you submit such as name, location, referral source, or messages sent via email or contact forms.
• Engagement and technical data (collected automatically by beehiiv). Email opens, clicks, time of interaction, referrer, IP address, approximate location derived from IP, device, browser, and operating system, and similar metadata used to deliver and measure the Newsletter.
• Site analytics. Standard log data when you visit the Site (pages viewed, referrer, IP-derived approximate location, device and browser info), which we may use to understand traffic and improve content.
• Communications. Records of correspondence if you reply to the Newsletter or contact us directly.

We do not collect payment information, financial data, government IDs, or sensitive categories of personal information, and we do not run paid subscriptions.

3. How We Use Information

We use the information we collect to:

• Deliver the Newsletter and related transactional messages (e.g. confirmations);
• Measure engagement and understand which content resonates so we can improve quality and relevance;
• Respond to your inquiries and provide support;
• Maintain the security and integrity of the Services and prevent abuse;
• Comply with legal obligations and enforce our Terms.

4. Legal Bases (EEA / UK)

If you are located in the European Economic Area or the United Kingdom, our legal bases for processing are: (a) consent, which you provide when you subscribe and which you can withdraw at any time by unsubscribing; (b) our legitimate interests in operating, securing, and improving the Newsletter; and (c) compliance with legal obligations where applicable.

5. How We Share Information

We do not sell or rent your personal information. We share limited information only as follows:

• Service providers. beehiiv (email delivery and analytics) and the hosting, infrastructure, and analytics providers that operate the Site, each acting as a processor under contract.
• Legal and safety. When required by law, subpoena, court order, or government request, or to protect rights, property, or safety.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections.

6. Cookies, Pixels, and Tracking

Newsletter emails include tracking pixels and tracked links, used by beehiiv to record opens and clicks. The Site may use minimal first-party and third-party cookies for functionality and aggregate analytics. You can disable cookies in your browser and disable image loading in your email client to limit tracking.

7. International Data Transfers

We are based in Canada and our service providers (including beehiiv) are based in the United States and other jurisdictions. By subscribing, you understand that your information may be transferred to, stored, and processed in countries with data-protection laws that differ from those in your country. Where required, our providers rely on appropriate safeguards (such as Standard Contractual Clauses) for international transfers.

8. Data Retention

We retain your subscriber information for as long as you remain subscribed and for a reasonable period afterward to comply with legal obligations, resolve disputes, and enforce our agreements. If you unsubscribe, we may retain a hashed or suppression record of your email address to ensure we do not contact you again. Engagement data may be retained in aggregated or anonymized form.

9. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect your information. No method of transmission or storage is 100% secure, however, and we cannot guarantee absolute security.

10. Your Rights and Choices

Depending on your location, you may have the right to: access, correct, update, delete, or port your personal information; object to or restrict certain processing; withdraw consent; and lodge a complaint with your local data-protection authority. To exercise any of these rights, contact us using the details below. You can also unsubscribe at any time using the link in any email.

California residents: we do not sell or share personal information as defined under the CCPA/CPRA. You may request access to or deletion of your personal information by contacting us.

Canadian residents: we comply with applicable Canadian privacy laws, including PIPEDA and Quebec's Law 25.

11. Children's Privacy

The Services are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you believe a child has provided us with personal information, please contact us and we will delete it.

12. Third-Party Links

The Newsletter and Site may contain links to third-party websites and services. We are not responsible for the privacy practices or content of those third parties; please review their privacy policies before providing them with information.

13. Do Not Track

We do not currently respond to browser "Do Not Track" signals because no consistent industry standard exists. You can control tracking through cookie and email-client settings as described above.

14. Changes to This Policy

We may update this Policy from time to time. The "Last updated" date above reflects the most recent revision. Material changes will be communicated via the Newsletter or posted on this page.

15. Contact

Privacy questions or requests? Email scottcbusiness@protonmail.com. You can also review our Terms of Service.