Please note, this Privacy Policy will take effect on 6 June 2025.
This is in preparation for migration to Substack. Please read more here.
You can view the previous Privacy Policy: Here.

Effective Date: 22 October 2024

Updated: 22 May 2025

Implementation: 6 June 2025

At Axia Editions Limited (“we,” “us,” or “our”), the owner of Asymmetrist, we value your privacy and are committed to protecting your personal information. This policy explains how we collect, use, and protect your data when you interact with our website or newsletter, both hosted via Substack, at www.asymmetrist.com.

Asymmetrist is a brand operated by Axia Editions Limited, a UK-registered company (Company No. 15889065), located at 4 Endsleigh Street, London, WC1H 0DS, United Kingdom.

Lawful Basis for Processing

We rely on the following lawful bases under the UK General Data Protection Regulation (UK GDPR):

  • Consent – for sending newsletters, editorial updates, occasional sponsored or partner messages, and for the use of any analytics or marketing cookies. Consent is obtained through explicit opt-in mechanisms (e.g. unchecked checkboxes and cookie banners).
  • Legitimate interests – may be used only for strictly necessary processing activities, such as delivering essential service communications (e.g. account issues or legal notifications), where your rights and freedoms are not infringed. We do not rely on legitimate interests for marketing, analytics, or tracking cookies.

You may withdraw your consent at any time by clicking “unsubscribe” in any email or adjusting your preferences via the Substack platform or cookie banner.

Mailing List Portability and Platform Changes

If we change our newsletter delivery platform, we may transfer our subscriber list to the new provider under the existing lawful basis. You will not need to re-subscribe, and you will continue to have the same rights to unsubscribe or object at any time.

We will inform you in advance of any such platform migration and provide a clear opportunity to opt out or unsubscribe in accordance with UK GDPR and PECR rules.

Information We Collect

1. Personal Information

We may collect your name, email address, and responses to forms, surveys, or correspondence. This is collected via our website, Substack, and direct communications.

2. Usage and Analytics Data

We use analytics tools such as Google Analytics 4 (GA4) and Substack’s native analytics to collect anonymised usage data, including browser type, device type, and referral source.

IP Anonymisation: We use GA4, which anonymises IP addresses by default. Your full IP address is never logged or stored by Google.

We may also integrate additional tracking tools in the future, including:

  • Google Tag Manager
  • Meta (Facebook) Pixel
  • Twitter/X Pixel
  • Parse.ly Analytics
  • Other analytics or marketing technologies

These tools are used only with your consent and help us understand audience behaviour and improve editorial performance. From time to time, we may update or replace these technologies with others that serve similar purposes. Any new tools will be implemented in accordance with this Privacy Policy and applicable laws.

Platform and Newsletter Delivery via Substack

Our site and newsletter are hosted on Substack, a U.S.-based provider acting as a data processor. Substack manages our subscriber database, delivers content, and provides analytics and cookie consent infrastructure.

Substack uses Standard Contractual Clauses (SCCs) and the UK Addendum to comply with international data transfer rules. We maintain a Data Processing Agreement (DPA) with Substack to ensure secure, lawful, and GDPR-compliant handling of your data.

Substack may use sub-processors (e.g. AWS) for infrastructure and delivery. For a full list, please see Substack’s Privacy Policy.

Cookie consent on Asymmetrist is managed through Substack’s global cookie banner. Users are presented with options to accept all cookies, reject non-essential cookies, or manage preferences in a granular way.

Non-essential cookies—including those used for analytics or marketing—are only activated when you give your explicit consent. You can manage or update your preferences at any time by revisiting the cookie banner (e.g. by clearing cookies or using incognito/private mode), or through your Substack account settings if applicable.

For more details, refer to Substack’s Cookie Policy.

Your Rights

You have the right to:

  • Access the personal data we hold about you
  • Correct inaccuracies
  • Request deletion (“right to be forgotten”)
  • Withdraw consent at any time
  • Object to processing where lawful grounds exist

To exercise any of these rights, please contact us at bogdan@asymmetrist.com. We aim to respond within 30 days.

Children’s Privacy

Asymmetrist is not intended for individuals under the age of 13. We do not knowingly collect data from children. If we become aware that we have done so, we will delete that data promptly.

Data Security

We safeguard your data using secure third-party services (e.g. Substack and Google Workspace), HTTPS encryption, and strict access controls. Only authorised personnel have access to user data.

Data Retention

We retain your personal data until you unsubscribe or request deletion. Most deletion requests are processed within 14 days.

From time to time, we may include:

  • Sponsored messages or editorial partnerships
  • Affiliate links or commercial partnerships
  • Third-party promotions relevant to our readership

These will always be clearly marked. We do not share your personal data with third parties for their own marketing purposes.

We do not currently engage in behavioural targeting. If we introduce it in the future, we will seek your explicit consent in advance, as required by UK law.

Policy Updates

We may revise this Privacy Policy from time to time to reflect legal, technological, or editorial changes.

Material updates will be communicated via email or prominently on our website with at least 14 days’ notice. We reserve the right to:

  • Change newsletter delivery platforms or processors
  • Introduce new tools or editorial formats
  • Update monetisation strategies or data processors

You will always be given the opportunity to unsubscribe or object. Where appropriate, we will rely on soft opt-in for existing subscribers when introducing similar new services.

Contact

For questions about this policy or your data:

bogdan@asymmetrist.com

Axia Editions Limited

4 Endsleigh Street

London, WC1H 0DS

United Kingdom