Privacy Policy – Last updated: 21 April 2025*

This Privacy Policy constitutes a legally binding instrument between the individual user (“you”) and Underground Media Network (“UMN”, “we”, “our”, or “us”), delineating the principles and mechanisms by which personal data is acquired, processed, retained, and disclosed in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This Policy specifically pertains to the operations of UMN’s Substack-hosted publication and other associated digital communication interfaces.

By continuing to access or interact with our services, including subscription to our newsletters, submission of user-generated content, or direct communication via digital channels, you affirm your agreement to the terms herein. Should you dissent to any component of this Privacy Policy, your immediate cessation of engagement with our services is required.

1. Jurisdiction and Applicability

This Policy is operative in the context of UMN’s Substack-hosted environment and all affiliated digital properties wherein personal information is collected and managed. It extends to all data transactions initiated through our interface, including subscription workflows, comment functions, data analytics tools, and payment processing systems facilitated by Stripe. The provisions outlined herein are binding and enforceable within the jurisdiction of New South Wales, Australia.

2. Categories of Personal Information Collected

2.1 Volitional Data Provision

We acquire personal data that you elect to submit through the following modalities:

• Newsletter subscription forms (inclusive of name and email credentials);

• Email or direct message communication initiated by you;

• User responses, comments, and interactions with published content;

• Data furnished through user-initiated feedback mechanisms or survey participation.

2.2 Data Captured via Substack Infrastructure

Substack, as a data processor and host platform, automatically collects technical and behavioural data, including:

• Internet Protocol (IP) address;

• Device specifications and browser configurations;

• Geolocation approximations and referrer information;

• On-site behavioural metrics such as page views and interaction timestamps.

This data, while anonymised where feasible, is transmitted to UMN for evaluative and optimisation purposes.

2.3 Payment Metadata via Stripe

Stripe administers all financial transactions on behalf of UMN. We do not collect or retain raw payment card data. Instead, we may receive ancillary metadata including transaction identifiers and billing timestamps, which are used exclusively for accounting and verification purposes.

3. Legal Foundations for Data Processing

Data collection and utilisation by UMN is predicated upon one or more of the following statutory justifications:

• Freely given, specific, informed, and unambiguous consent;

• Execution of contractual or quasi-contractual obligations with the data subject;

• Legal compliance with statutory mandates applicable to media entities;

• Pursuit of legitimate interests, provided such interests are not overridden by the fundamental rights and freedoms of the individual.

4. Purposes for Data Processing

The utilisation of personal data is confined to the following functional and strategic objectives:

• Dissemination of digital content, including newsletters and editorial materials;

• Facilitation of responsive communication in relation to user queries and technical support;

• Analytical refinement of publication reach, thematic resonance, and user engagement;

• Assurance of infrastructural integrity and mitigation of cybersecurity threats;

• Compliance with legal or regulatory obligations applicable to the entity.

Personal information is never monetised, commodified, or transferred to external entities for independent commercial exploitation.

5. Confidentiality of Sources and Whistleblowers

In alignment with ethical journalistic principles, UMN adopts a stringent protocol to protect individuals disclosing sensitive or confidential information:

• Communications via end-to-end encrypted services (e.g., ProtonMail, Signal) are strongly endorsed;

• All sensitive data are sequestered within encrypted repositories with controlled personnel access;

• No disclosure of identifying attributes will occur absent prior informed consent or judicial compulsion.

This framework is designed to safeguard the autonomy and anonymity of contributors engaging in whistleblowing or investigative collaboration.

6. Data Sharing and Third-Party Engagement

Disclosure of personal information may be necessitated in the following circumstances:

• To Substack for hosting, analytics, and email delivery services;

• To Stripe for payment processing and transaction reconciliation;

• To regulatory authorities or judicial bodies pursuant to legally binding directives.

All third-party service providers are contractually bound to implement data handling protocols consonant with the APPs.

7. Cross-Jurisdictional Data Transfers

Given the transnational nature of our service providers, certain data processing operations may occur in foreign jurisdictions, notably the United States. To this end:

• Data transfer mechanisms such as Standard Contractual Clauses or equivalent safeguards are employed;

• By interacting with our platform, you expressly consent to such overseas disclosures subject to these protections.

8. Data Integrity and Security Architecture

UMN and its service partners apply industry-standard security controls to prevent data breaches, including:

• HTTPS encryption for all data in transit;

• Tiered access restrictions for personnel accessing user information;

• Continuous surveillance of digital infrastructure for anomalies or threats.

While absolute invulnerability cannot be guaranteed, our frameworks are periodically audited and refined to reflect evolving cybersecurity standards.

9. Retention and Data Lifecycle Management

Personal data is retained only for the duration necessary to:

• Fulfil its original purpose;

• Satisfy legal or compliance-related obligations;

• Address user-initiated complaints or enquiries.

Post-utility, data is irrevocably destroyed or anonymised using advanced de-identification protocols consistent with prevailing industry norms.

10. Data Subject Rights Under Australian Statute

Pursuant to the Privacy Act 1988 (Cth), you are entitled to:

• Request access to your personal information and receive a copy of said data;

• Request rectification of inaccuracies or incomplete records;

• Withdraw consent at any juncture, without prejudice to prior lawful processing;

• Lodge a grievance with the Office of the Australian Information Commissioner (OAIC) in the event of non-compliance.

All such requests may be submitted to UMN via the contact details listed below.

11. Cookie Policy and Passive Data Collection

Substack’s infrastructure utilises cookies and similar tracking technologies to:

• Authenticate returning users;

• Personalise content delivery;

• Aggregate behavioural metrics for editorial optimisation.

Your continued usage signifies tacit acceptance of cookie deployment in accordance with this Privacy Policy and Substack’s own cookie governance regime. Users retain the right to adjust cookie preferences through their browser settings.

12. Amendments to this Policy

UMN reserves the right to revise this Privacy Policy in response to legislative amendments, technological evolutions, or internal policy reforms. Notice of substantive modifications will be communicated via email or prominently on the publication platform. Continued engagement with the platform post-notification signifies assent to the updated terms.

13. Contact Protocol

For matters concerning privacy rights, data access requests, or compliance grievances, please direct correspondence to:

📧 Email: UndergroundMediaNetwork@proton.me

This Privacy Policy is governed by the laws of New South Wales, Australia. Jurisdiction over disputes arising from its interpretation or enforcement lies with the courts or tribunals of competent authority therein.

© 2025 Underground Media Network. All rights reserved.