FLUKE PRINT PRIVACY POLICY

Last Updated: September 12th, 2025

1. INTRODUCTION

This privacy policy applies to Fluke Print™ ("the Imprint"), a paranormal and speculative fiction imprint operated by Morgan A. Drake™ on the Substack platform. This policy supplements Substack's general privacy policy, which can be found at https://substack.com/privacy.

2. DATA CONTROLLER

The data controller for Fluke Print™ is:

E.M.V. (operating under the pen name Morgan A. Drake™)
Independent Creator
Italian VAT (Partita IVA): [17966171005]
Contact: Through Substack's platform contact forms

3. INFORMATION WE COLLECT

In addition to the data collected by Substack's platform, we may collect:

• Email addresses for newsletter subscription

• Names (if provided)

• Comments and interactions on posts

• Correspondence sent directly to us

4. LEGAL BASIS FOR PROCESSING

We process your data based on:

• Your consent (for newsletter subscription)

• Legitimate interests (for content improvement and communication)

• Legal obligations under Italian and EU law

5. HOW WE USE YOUR INFORMATION

We use your information to:

• Deliver the newsletter and story content

• Respond to your comments and messages

• Improve our content

• Comply with legal obligations

• Analyze engagement (in aggregate, anonymous form)

6. DATA STORAGE AND PROTECTION

All data is stored on Substack's secure servers. We do not maintain separate databases or storage systems. For details on Substack's security measures, please refer to their privacy policy.

7. YOUR RIGHTS UNDER GDPR

Under GDPR, you have the right to access, correct, or delete your data. You can:

For Platform-Related Data:

• Access, correct, or delete your data through your Substack account settings

• Contact Substack support directly for data portability requests

• Unsubscribe from our publication using the link in any email

• Delete your Substack account through platform settings

For Publication-Specific Requests:

• Contact us through the platform for questions about how we use your data

• Request removal of your comments

• Withdraw consent for specific uses of your data

8. INTERNATIONAL DATA TRANSFERS

As Substack is a U.S.-based platform, your data may be transferred to and stored in the United States. These transfers are governed by appropriate safeguards as required by GDPR.

9. DATA RETENTION

We retain your data only as long as necessary to provide our services or as required by law. You can delete your subscription at any time through your Substack account settings.

10. COOKIES AND TRACKING

We rely on Substack's cookie policy and tracking systems. No additional tracking is implemented by Fluke Print™. For details, see Substack's cookie policy.

11. CHANGES TO THIS POLICY

We reserve the right to update this privacy policy at any time. Significant changes will be announced in the newsletter and on the publication page.

12. SUPERVISORY AUTHORITY

Under GDPR, you have the right to lodge a complaint with your local data protection authority. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

13. CONTACT INFORMATION

For privacy-related questions or concerns:

Use the subject line "PRIVACY REQUEST - [Type of Request]"
Email us through Substack's platform using the 'Reply to post' feature
Or contact us through our Substack contact form

We will respond to all legitimate privacy requests within 30 days, as required by GDPR.

This privacy policy is effective as of September 12th, 2025 and complies with Italian law, GDPR, and Substack's platform requirements.