RAW THIRST — Privacy Policy

Effective date: 30 March 2026

1. Introduction

This Privacy Policy explains how RAW THIRST, a publication by Magnus Wolfe (”the Publisher”, “we”, “us”, “our”), collects, uses, stores, and protects your personal information when you subscribe to, access, or interact with our publication at magnuswolfe.substack.com.

RAW THIRST is hosted on Substack. As such, your personal data is handled by both the Publisher and Substack Inc. This policy covers only the Publisher’s use of your data. For information on how Substack collects and processes your data as a platform, please refer to [Substack’s Privacy Policy](https://substack.com/privacy).

We are committed to protecting your privacy and complying with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations (PECR).

2. Data Controller

For UK data protection law, the data controller for the personal information processed through this publication is:

Magnus Wolfe

Email: magnusthewolfe@gmail.com

Substack: [magnuswolfe.substack.com](https://magnuswolfe.substack.com)

Substack Inc. acts as a data processor on behalf of the Publisher for certain processing activities and as an independent data controller for its own platform operations. Further details are available in [Substack’s Privacy Policy](https://substack.com/privacy).

3. What Personal Data We Collect

When you subscribe to RAW THIRST, the following personal data may be made available to us through Substack:

• Name - your first and last name, as provided during subscription.

• Email address - used to deliver the publication to your inbox.

• Subscription status - whether you are a free or paid subscriber.

• Engagement data - aggregated information such as open rates and click-through rates, which Substack may provide to us through its analytics dashboard.

We do not directly collect, process, or store the following data — these are handled entirely by Substack and its payment processor, Stripe:

• Payment and billing information (credit/debit card details, billing address).

• Browser or device information, IP addresses.

• Cookies or tracking data (see Section 7 below).

4. How We Use Your Data

We use the personal data available to us for the following purposes:

Purpose / Lawful Basis (UK GDPR)

Delivering the publication to your inbox | Performance of a contract (Article 6(1)(b)) — fulfilling your subscription |

Managing your subscription (free or paid) | Performance of a contract (Article 6(1)(b)) |

Responding to your enquiries or requests | Legitimate interests (Article 6(1)(f)) — maintaining communication with subscribers |

Understanding readership through aggregated analytics | Legitimate interests (Article 6(1)(f)) — improving the publication |

Sending occasional updates about RAW THIRST (e.g. new series, schedule changes) | Legitimate interests (Article 6(1)(f)) — keeping subscribers informed about the publication they signed up for |

We will never use your personal data for purposes unrelated to RAW THIRST. We will never sell your data to third parties.

5. Who We Share Your Data With

We do not sell, rent, or trade your personal information.

Your data may be accessible to the following parties, solely for the purposes described in this policy:

• Substack Inc. - as the hosting platform and data processor. Substack handles email delivery, subscription management, payment processing, and platform analytics. Substack is based in the United States and complies with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. DPF. See [Substack’s Privacy Policy](https://substack.com/privacy) for full details.

• Stripe - Substack’s third-party payment processor. Stripe handles all payment transactions. We do not have access to your full payment details. See [Stripe’s Privacy Policy](https://stripe.com/gb/privacy) for more information.

We will not share your personal information with any other third parties unless required to do so by law.

6. International Data Transfers

Substack Inc. is based in the United States. By subscribing to RAW THIRST, your personal data may be transferred to and processed in the United States.

Substack has certified its compliance with the EU-U.S. Data Privacy Framework (DPF) and the UK Extension to the EU-U.S. DPF, which provides a lawful mechanism for transferring personal data from the UK and EEA to the United States. For further information, see [Substack’s Privacy Policy](https://substack.com/privacy).

If you have concerns about international data transfers, please contact us using the details in Section 12.

7. Cookies and Tracking

The Publisher does not independently set any cookies or tracking technologies on your device.

However, Substack uses cookies and similar technologies to operate the platform. These include:

• Strictly necessary cookies - required for the website to function (e.g. login, security).

• Performance cookies - collect anonymised information about how visitors use the site.

• Functionality cookies - remember your preferences and settings.

Substack may also enable tracking pixels within emails to measure open rates and engagement. This data is presented to the Publisher in aggregated form only.

For full details on Substack’s use of cookies and how to manage your preferences, see [Substack’s Privacy Policy](https://substack.com/privacy). You can also manage cookies through your browser settings.

8. Data Retention

We retain your personal data (name, email address, subscription status) for as long as you remain subscribed to RAW THIRST.

If you unsubscribe, your data will be removed from our active subscriber list. However, please note that Substack may retain certain data in accordance with its own retention policies and legal obligations.

If you wish to have your data fully deleted from Substack’s systems, you may need to contact Substack directly at privacy@substackinc.com or through your Substack account settings.

9. Your Rights

Under the UK GDPR and the Data Protection Act 2018, you have the following rights in relation to your personal data:

• Right of access - you can request a copy of the personal data we hold about you.

• Right to rectification - you can ask us to correct inaccurate or incomplete data.

• Right to erasure - you can request that we delete your personal data, subject to any legal obligations we may have to retain it.

• Right to restrict processing - you can ask us to limit how we use your data in certain circumstances.

• Right to data portability - you can request that we provide your data in a commonly used, machine-readable format.

• Right to object - you can object to us processing your data based on legitimate interests.

• Right to withdraw consent - where processing is based on your consent, you may withdraw it at any time. This does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at the email address in Section 12. We will respond to your request within one month, as required by law.

You also have the right to unsubscribe from RAW THIRST at any time by using the unsubscribe link at the bottom of any email, or by managing your subscription through your Substack account.

10. Age Restriction

RAW THIRST publishes sexually explicit adult content and is intended exclusively for readers aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18.

If we become aware that we hold data relating to a person under 18, we will take steps to delete that data promptly. If you believe a minor has subscribed to RAW THIRST, please contact us immediately.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify subscribers through the publication or by email. The date at the top of this policy will always reflect the most recent revision.

Continued use of RAW THIRST after any changes have been communicated constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a complaint about how your data has been handled, please contact:

Magnus Wolfe

Email: magnusthewolfe@gmail.com

Substack: magnuswolfe.substack.com(https://magnuswolfe.substack.com)

You also have the right to lodge a complaint with the UK’s data protection authority:

Information Commissioner’s Office (ICO)

Website: [ico.org.uk](https://ico.org.uk)

Helpline: 0303 123 1113

For queries related to Substack’s handling of your data, contact Substack’s UK representative:

Bird & Bird GDPR Representative Services UK

12 New Fetter Lane, London, EC4A 1JP, United Kingdom

Email: UKrepresentative.Substack@twobirds.com

*Last updated: 30 March 2026*