Privacy Policy

Barkworthy Notes Privacy Policy

Last Updated: May 16, 2025

At Barkworthy Notes, we are committed to protecting your privacy and ensuring transparency in how we handle your personal information. This Privacy Policy explains how we collect, use, share, and safeguard your data when you access, read, or use our content or services across any publication channels, including but not limited to our website (https://thebarkworthynotes.com), blogs, email newsletters, social media accounts (e.g., X, TikTok, YouTube), Discord servers, Substack trade plans, videos, podcasts, live streams, and any other current or future platforms (collectively, “Services”). This policy is part of our broader Disclaimer, which governs the use of our Services and outlines their entertainment, educational, and informational purposes.

As a business registered in Norway, we comply with the General Data Protection Regulation (GDPR) for European Economic Area (EEA) users and applicable U.S. laws, such as the California Consumer Privacy Act (CCPA), for U.S. users. By accessing, reading, or using our Services, you expressly agree and acknowledge that you have read, understood, and consent to this Privacy Policy, as noted in our Disclaimer’s Section 20.

1. Information We Collect

We collect information to deliver our educational Services, improve user experience, communicate with you, and comply with legal obligations. The types of information we may collect include:

a. Information You Provide

  • Comments: When you leave comments on our website, we collect data shown in the comment form (e.g., name, email, comment text), your IP address, and browser user agent string to aid spam detection. If you use Gravatar, an anonymized email hash may be sent to check for a profile picture, which is publicly visible after comment approval. Gravatar’s privacy policy is at https://automattic.com/privacy/.
  • Contact Information: Email addresses, names, or other details you provide when subscribing to Substack newsletters, joining our Discord community, contacting us via forms or email, or participating in surveys or promotions.
  • User-Generated Content: Comments, posts, or messages you share on our platforms (e.g., Substack comments, Discord messages), which may include personal information you choose to disclose.
  • Account Information: Usernames, profile details, or preferences you set when registering for Substack, Discord, or other interactive Services.

b. Information Collected Automatically

  • Cookies and Tracking: If you comment on our website, you may opt-in to cookies saving your name, email, and website for convenience, lasting one year. Login pages set temporary cookies to check browser compatibility, discarded on browser close. Login cookies (two days) and screen options cookies (one year) save login information and display choices; “Remember Me” extends login to two weeks. Editing/publishing articles sets a one-day cookie with the post ID. Affiliate links (e.g., TradingView, Substack) may use cookies to track referrals, typically lasting 30-90 days.
  • Usage Data: Information about your interactions with our Services, such as pages visited, links clicked, time spent, and content viewed, collected via cookies, web beacons, or analytics tools (e.g., Google Analytics).
  • Device and Log Data: IP addresses, browser type, operating system, device identifiers, and access times, collected when you visit our website or use our Services.
  • Affiliate Tracking Data: Data collected via affiliate links to track clicks, sign-ups, or purchases, often using cookies or tracking pixels.

c. Information from Third Parties

  • Social Media Data: Interactions with our X, TikTok, or YouTube accounts may provide data (e.g., usernames, engagement metrics), subject to their privacy policies.
  • Affiliate Partners: Partners like TradingView or Substack may share data about your actions (e.g., subscription status, referral completions) to facilitate affiliate commissions, as disclosed in our Affiliate Disclosure Policy.
  • Analytics Providers: Third-party tools provide aggregated data about user behavior to improve our Services.
  • Spam Detection Services: Visitor comments may be checked via automated spam detection services, which may process your IP address or comment data.

We do not collect sensitive financial information (e.g., trading account details) unless required for transactions (e.g., Substack payments), handled by secure third-party processors.

2. How We Use Your Information

We use your information to:

  • Provide and Improve Services: Deliver newsletters, trade plans, Discord discussions, and website content, approve and display comments, and enhance user experience based on usage data.
  • Communicate with You: Send updates, newsletters, promotional offers, or responses to inquiries, with your consent where required (e.g., GDPR opt-in for EEA users).
  • Support Affiliate Programs: Track referrals and commissions via affiliate links, as outlined in our Affiliate Disclosure Policy.
  • Analyze and Optimize: Use analytics to understand user behavior, improve content, and ensure platform functionality (e.g., website performance).
  • Ensure Safety and Compliance: Moderate user-generated content (e.g., comments, Discord posts) to prevent unlawful or objectionable material, as noted in our Disclaimer’s Section 13, and comply with legal obligations (e.g., GDPR, CCPA).
  • Personalize Content: Tailor content or offers based on preferences or interactions, where applicable.

We do not use your information for personalized investment advice, recommendations, or solicitations, as our Services are for entertainment, educational, and informational purposes only, per our Disclaimer’s Section 1.

3. How We Share Your Information

We may share your information with safeguards to protect your privacy:

  • Service Providers: With trusted third parties like Substack (newsletters), Discord (community), Google Analytics (usage), or payment processors (Substack subscriptions), bound by confidentiality and data protection agreements.
  • Affiliate Partners: With partners like TradingView or Substack to track referrals, sharing click data or subscription status, per our Affiliate Disclosure Policy.
  • Spam Detection Services: Comments may be processed by automated spam detection services, sharing IP addresses or comment data.
  • Legal Compliance: When required by law, regulation, or legal process (e.g., court orders), or to protect our rights, safety, or property, including GDPR/CCPA requests. Password reset emails may include your IP address.
  • Business Transfers: In mergers, acquisitions, or asset sales, your data may be transferred with notice and consent where required.
  • Public Content: Comments or user-generated content (e.g., Discord posts, Gravatar profile pictures) may be publicly visible, and you are responsible for shared information, per our Disclaimer’s Section 13.
  • Aggregated/Anonymized Data: Non-identifiable data (e.g., traffic statistics) may be shared for analytics or marketing.

We do not sell your personal information for unrelated marketing purposes.

4. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to enhance your experience, analyze usage, and support affiliate tracking:

  • Website Cookies:
    • Comment Cookies: Optional cookies save name, email, and website for one year if you comment.
    • Login Cookies: Temporary cookies check browser compatibility; login cookies (two days) and screen options cookies (one year) save login/display choices; “Remember Me” extends login to two weeks.
    • Article Editing Cookies: One-day cookies store post IDs for edited/published articles.
  • Essential Cookies: Enable website functionality (e.g., navigation, Substack login).
  • Analytics Cookies: Track usage (e.g., Google Analytics), anonymized where possible.
  • Affiliate Cookies: Track referrals (e.g., TradingView, Substack), typically 30-90 days.

EEA Users: We obtain consent for non-essential cookies via a website pop-up, per GDPR. Manage preferences through the cookie banner or contact [insert email]. Disabling cookies may affect functionality (e.g., affiliate tracking, analytics).

All Users: Manage cookies via browser settings, but this may impact features (e.g., Substack subscriptions). Third-party services (e.g., Substack, TradingView) may use cookies, subject to their policies.

5. Embedded Content from Other Websites

Our website may include embedded content (e.g., YouTube videos, TradingView charts, Substack widgets). These behave as if you visited the third-party site, which may collect data, use cookies, or track interactions, especially if you’re logged into their platform (e.g., YouTube account). We are not responsible for third-party practices, per our Disclaimer’s Section 13. Review their privacy policies (e.g., https://automattic.com/privacy/ for Substack).

6. Media and EXIF Data

If you upload images to our website (e.g., in comments or forums), avoid including embedded location data (EXIF GPS). Visitors can download and extract such data from images, and we are not liable for resulting privacy issues, per our Disclaimer’s Section 13.

7. Your Rights and Choices

You have rights regarding your personal information, depending on your location:

  • GDPR (EEA Users):
    • Access, rectify, erase, restrict, or port your data.
    • Object to processing for marketing or legitimate interests.
    • Withdraw consent (e.g., for newsletters), without affecting prior processing.
  • CCPA (California Users):
    • Know data collected, used, or shared.
    • Delete data, subject to exceptions.
    • Opt out of data sales (we do not sell data, but affiliate tracking may apply).
    • Non-discrimination for exercising rights.

To exercise rights, contact barky@thebarkworthynotes.com. We respond within GDPR (30 days) or CCPA (45 days) timelines, verifying identity. Unsubscribe from newsletters via email links or adjust Substack/Discord settings. For comments, you can request deletion, but approved comments are public, per Section 1.

8. Data Security

We use reasonable measures (e.g., HTTPS encryption, access controls) to protect your data. However, no system is fully secure, and we are not liable for data breaches, losses, or claims, including those caused by third-party or technical issues, per our Disclaimer’s Section 13. You use our Services at your own risk.

9. Data Retention

We retain data as necessary:

  • Comments: Retained indefinitely with metadata to recognize/approve follow-up comments, unless deleted upon request.
  • User Profiles: Stored for registered users (if any) until account deletion, editable by users (except usernames).
  • Newsletters/Subscriptions: Email data retained until you unsubscribe or request deletion.
  • Usage/Analytics Data: Up to 26 months (e.g., Google Analytics), then anonymized.
  • Affiliate Data: Retained per partner terms (e.g., 30-90 days for TrackingView cookies).

We delete or anonymize data when no longer needed, per GDPR and CCPA.

10. International Data Transfers

Our primary data processing occurs in the EEA, compliant with GDPR. Some providers (e.g., Substack, Google Analytics, Discord) or affiliates (e.g., TradingView) are U.S.-based. We ensure compliance via:

  • GDPR: Standard Contractual Clauses (SCCs) or adequacy decisions.
  • CCPA: U.S. provider privacy standards.

Consent to transfers is implied by Service use, per our Disclaimer’s Section 16, subject to your rights.

11. Children’s Privacy

Our Services are not for individuals under 18, due to trading risks, per our Disclaimer’s Section 2. We do not knowingly collect children’s data and will delete it if discovered. Contact barky@thebarkworthynotes.com if you believe this has occurred.

12. Updates to This Policy

We may update this policy to reflect changes in practices, regulations, or Services. The latest version is at https://thebarkworthynotes.com/privacy-policy, with significant changes notified via Substack, email, or social media. Continued use implies consent, per our Disclaimer’s Section 20.

13. Contact Us

For questions or to exercise data rights, contact our Data Protection Officer at barky@thebarkworthynotes.com. EEA users may contact the Norwegian Data Protection Authority (Datatilsynet). California users may contact the California Attorney General for CCPA concerns.

14. Acknowledgment

By accessing, reading, or using our Services through any publication channels, you expressly agree and acknowledge that you have read, understood, and consent to this Privacy Policy, including our data practices, as part of our Disclaimer.

If you do not agree, please do not use our Services.