This website uses cookies

Read our Privacy policy and Terms of use for more information.

1. Data Controller

Murinus Advisers SIA is the data controller for personal data processed in connection with the Newsletter.Company: Murinus Advisers SIA Registration No: 40103668844 VAT No: LV40103668844 Address: "Doktorats", Pales pag., Limbazu nov., Latvia Email: [email protected]Latvia's supervisory authority for data protection is the Data State Inspectorate (Datu valsts inspekcija): www.dvi.gov.lv | +371 67 223 131.

2. Data We Collect

Email address — required to subscribe to the Newsletter Name — if provided when subscribing Payment information — billing name, address, and card details, collected and processed by Stripe (we do not store raw card numbers) VAT / tax identification number — if you provide this at checkout Survey responses — if you complete optional surveys linked to the Newsletter Correspondence — if you contact us by email or other means Email engagement data — open rates, click-through rates, and device/client type, collected by beehiiv IP address and approximate location — collected by beehiiv and Stripe for security and fraud prevention Subscription and billing history — records of subscription tier, payment dates, and status

3. Legal Bases for Processing

Performance of a contract (Art. 6(1)(b)): Processing necessary to deliver the Newsletter, manage your subscription, and process your payment. Consent (Art. 6(1)(a)): Where you have given explicit consent, for example when signing up. You may withdraw consent at any time. Legitimate interests (Art. 6(1)(f)): For security, fraud prevention, improving the Service, and direct marketing to existing subscribers. Legal obligation (Art. 6(1)(c)): Where processing is required to comply with applicable law, such as VAT record-keeping obligations.

4. How We Use Your Data

To deliver the Newsletter (free and paid editions) to you by email To manage your subscription, process payments, and send billing communications To send service-related notices (e.g. changes to pricing, Terms, or this Privacy Policy) To personalise your experience (e.g. showing paid content to paid subscribers) To send marketing communications about new features or related content (where permitted) To comply with legal and regulatory obligations (e.g. tax and accounting requirements) To detect, prevent, and investigate fraud, abuse, and security incidents To analyse aggregate subscriber behaviour to improve our content and service

5. Data Processors and Third Parties

beehiiv (Morning Brew Inc., USA): Newsletter delivery platform. Stores subscriber data, email engagement metrics, and publication content. beehiiv relies on the EU-US Data Privacy Framework for transatlantic data transfers.Stripe Inc. (USA): Payment processing. Processes and stores payment data, billing history, and identity verification data. Stripe relies on the EU-US Data Privacy Framework and Standard Contractual Clauses for data transfers.We do not sell your personal data to any third party. We may disclose data to competent authorities where required by law.

6. International Data Transfers

As beehiiv and Stripe are US-based companies, your personal data may be transferred to and processed in the United States. These transfers are carried out on the basis of the EU-US Data Privacy Framework (where applicable), Standard Contractual Clauses (SCCs) approved by the European Commission, and other appropriate safeguards as required under Chapter V of the GDPR.

7. Data Retention

Subscriber email and name: for the duration of your subscription plus 3 years after cancellation Payment and billing records: 10 years (required under Latvian accounting and tax law) Email engagement data: 2 years from collection Correspondence: 3 years from the date of the correspondence Consent records: for the duration of processing plus 3 yearsAfter these periods, data is securely deleted or anonymised.

8. Your Rights Under GDPR

Right of access (Art. 15): You may request a copy of the personal data we hold about you. Right to rectification (Art. 16): You may ask us to correct inaccurate or incomplete data. Right to erasure (Art. 17): You may ask us to delete your data, subject to certain exceptions. Right to restriction of processing (Art. 18): You may ask us to restrict processing of your data in certain circumstances. Right to data portability (Art. 20): Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, machine-readable format. Right to object (Art. 21): You may object to processing based on legitimate interests or for direct marketing purposes. Right to withdraw consent (Art. 7(3)): Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. Right not to be subject to solely automated decision-making (Art. 22): We do not currently make decisions about you based solely on automated processing.To exercise any of these rights, please contact us at [email protected]. We will respond within one month. You also have the right to lodge a complaint with the Data State Inspectorate (Latvia) or the supervisory authority in your EU country of residence.

9. Cookies and Tracking

Emails sent by the Newsletter may contain tracking pixels that record whether and when an email has been opened, and which links have been clicked. This data is used to measure engagement and improve content quality. If you wish to prevent email tracking, you can disable image loading in your email client. Our Newsletter website (hosted on beehiiv) may use cookies. Please refer to beehiiv's cookie policy for details.

10. Marketing Communications

We may send you marketing emails about new features, paid subscription tiers, or related content. You may unsubscribe at any time by clicking the unsubscribe link in any email or by contacting us directly. Unsubscribing from marketing will not affect delivery of newsletters you have subscribed to receive.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data, including encrypted transmission (TLS/HTTPS), access controls limiting who can access subscriber data, and use of reputable, security-accredited third-party processors. In the event of a personal data breach, we will notify the Data State Inspectorate within 72 hours and inform you without undue delay where required under GDPR Article 34.

12. Children’s Privacy

The Newsletter is not directed at children. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently collected data from a minor, please contact us and we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email at least 30 days before the updated Policy takes effect. The current version will always be published on our website.

14. Contact

For any questions, requests, or concerns relating to this Privacy Policy:Murinus Advisers SIA Email: [email protected] Address: "Doktorats", Pales pag., Limbazu nov., LV-4052, Latvia