Privacy Policy for Vitr Advisory Substack

Last Updated: October 2, 2025

Vitr Advisory (“we,” “us,” or “our”) operates the Vitr Advisory Substack (the “Publication”), a newsletter providing educational content on investment research, economic analysis, valuation theory, portfolio management, and market strategies. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you access or subscribe to the Publication. By using the Publication, you consent to the practices described herein. If you do not agree, please do not access or subscribe.

1. Information We Collect

We may collect the following types of personal information:

• Subscriber Information: Email addresses, names, or other details voluntarily provided when you subscribe via Substack’s platform.

• Engagement Data: Information you voluntarily provide through comments, surveys, or interactions with the Publication, if applicable.

• Usage Data: Non-personally identifiable information, such as aggregated analytics on how you interact with the Publication, collected via Substack or third-party tools (e.g., Substack analytics).

2. How We Use Your Information

We use your information to:

• Deliver newsletters and content updates to your inbox.

• Respond to your inquiries or comments, if applicable.

• Analyze usage trends to improve the Publication’s content and functionality.

• Comply with legal obligations or enforce our Terms of Service.

3. How We Share Your Information

We do not sell or rent your personal information. We may share information:

• With Substack, Inc., which processes subscriber data (e.g., email addresses, payment details for premium subscriptions) under its Privacy Policy.

• With third-party service providers (e.g., analytics tools) that assist in operating the Publication, subject to confidentiality agreements.

• As required by law, such as in response to a subpoena or regulatory request.

4. Data Security

We take reasonable measures to protect your personal information, but no method of transmission over the internet is completely secure. We cannot guarantee the absolute security of your data.

5. Your Rights

Depending on your jurisdiction (e.g., California under CCPA, EU under GDPR), you may have rights to:

• Access, correct, or delete your personal information.

• Opt out of certain data uses or sharing.

• Unsubscribe from newsletters via the link in each email or by contacting us.
  To exercise these rights, contact us at vitradvisory@pm.me or use Substack’s account management tools.

6. International Subscribers

If you access the Publication from outside the United States, your data may be transferred to and processed in the United States, where privacy laws may differ. By subscribing, you consent to this transfer.

7. Third-Party Services

The Publication operates on Substack’s platform, and certain data practices are governed by Substack’s Privacy Policy. We may use third-party tools (e.g., analytics) that have their own privacy policies.

8. Children’s Privacy

The Publication is not intended for individuals under 18. We do not knowingly collect personal information from children.

9. Changes to This Policy

We may update this Privacy Policy periodically. Changes will be posted on the Publication, and continued use constitutes acceptance of the updated policy.

10. Contact Us

For questions or concerns about this Privacy Policy, contact us at vitradvisory@pm.me.