TheracelLab Privacy Policy

TheracelLab is an independent publication operated by Variana Volk ("TheracelLab," "we," "us," or "our").

This Privacy Policy explains how TheracelLab may collect, use, disclose, and otherwise process personal information in connection with our publication, website, newsletters, subscriptions, digital products, purchases, communications, and related services (collectively, the "Services").

TheracelLab currently publishes primarily through Substack. We may also use our own website or third-party service providers to offer digital products, communicate with subscribers and customers, process transactions, or provide other Services.

1. Information We May Collect

Depending on how you interact with TheracelLab, we may collect or receive:

Contact and account information

• name;
• email address;
• display name;
• subscription status or subscription tier; and
• other information you provide when subscribing, purchasing, registering, or communicating with us.

Communications and information you provide

• emails;
• direct messages;
• comments or replies;
• forms;
• surveys;
• customer-service communications; or
• other voluntary communications with TheracelLab.

Purchase and transaction information

• your name and email address;
• product or subscription purchased;
• transaction amount and date;
• payment status; and
• billing or other transaction-related information made available by the relevant platform or payment provider.

Full payment-card information is generally processed directly by payment processors or commerce platforms and is not received or stored by TheracelLab unless expressly stated otherwise at the time of collection.

Subscriber and platform information

• subscriber information and information relating to readership, engagement, referrals, subscription status, or interactions with the Publication that the platform makes available to publishers.

Website and usage information

• IP address;
• browser or device information;
• referring website;
• pages or content viewed;
• approximate location derived from IP address; and
• interactions with emails, links, or website features.

The specific technologies used may change as the Services evolve.

2. How We Use Personal Information

We may use personal information to:

• provide and administer free and paid subscriptions;
• deliver newsletters, articles, digital products, and other Content;
• process and administer purchases;
• communicate with subscribers, readers, and customers;
• respond to questions, messages, and customer-service requests;
• send administrative or transactional communications;
• send newsletters, product announcements, promotional communications, or other marketing where permitted by applicable law;
• maintain and manage our subscriber and customer lists;
• understand readership, product usage, and engagement;
• improve or develop our Publication, website, products, and Services;
• protect the security and integrity of the Services;
• prevent fraud, abuse, unauthorized access, or misuse;
• maintain accounting, tax, and business records;
• enforce our Terms & Conditions;
• establish, exercise, or defend legal claims; and
• comply with applicable legal obligations.

3. Email and Marketing Communications

If you subscribe to TheracelLab, purchase a product, request information, or otherwise provide your email address, we may use your email address to provide the requested service and to communicate with you as permitted by applicable law.

This may include TheracelLab publication emails, information about new articles, digital products, services, or other TheracelLab offerings.

Where applicable law requires consent before sending particular marketing communications, we will rely on consent or another lawful basis permitted by applicable law.

You may unsubscribe from marketing or publication emails using the unsubscribe mechanism included in applicable messages or through available account or subscription controls.

We may retain limited information necessary to record and honor an unsubscribe or opt-out request.

4. Substack and Other Service Providers

TheracelLab currently uses Substack to publish Content, manage subscriptions, communicate with readers, and facilitate paid subscriptions.

For certain subscriber information processed by Substack on behalf of TheracelLab, TheracelLab may act as the data controller and Substack as a data processor.

Substack also processes information independently for its own purposes under its own Privacy Policy and other policies. TheracelLab does not control those independent processing activities.

As the Services evolve, TheracelLab may use additional service providers for functions such as:

• email delivery;
• website hosting;
• digital-product delivery;
• payment processing;
• analytics;
• forms or customer communications;
• accounting;
• security; or
• other infrastructure reasonably necessary to operate the business.

Such providers may process personal information only as necessary to provide the relevant services or as otherwise permitted under their own relationship with you and applicable law.

5. Cookies and Similar Technologies

Substack and other platforms used by TheracelLab may use cookies, analytics, email-measurement technologies, and similar technologies under their own policies and consent mechanisms.

If TheracelLab operates an independent website, we may use cookies or similar technologies for functions such as:

• operating and securing the website;
• remembering preferences;
• understanding traffic and engagement;
• measuring how Content or products are used; and
• improving the Services.

Where applicable law requires consent for particular cookies or tracking technologies, we will use them subject to applicable consent requirements.

6. How We May Disclose Personal Information

We may disclose personal information where reasonably necessary to:

• Substack and other platforms through which the Services are provided;
• payment processors;
• website, email, hosting, digital-product, analytics, or technology providers;
• professional advisers such as attorneys, accountants, or tax professionals;
• governmental authorities or other parties where required by applicable law or legal process;
• protect the rights, safety, security, or property of TheracelLab or others;
• investigate fraud, abuse, or security incidents;
• complete a merger, acquisition, financing, reorganization, sale, or transfer of all or part of the business; or
• carry out another purpose with your consent or at your direction.

TheracelLab does not sell subscriber or customer personal information for money.

7. Affiliate and Third-Party Links

TheracelLab may include links to third-party websites, products, or services, including affiliate links.

When you follow a third-party or affiliate link, the third party or affiliate network may collect information about your interaction, including through referral identifiers, cookies, or similar technologies.

The collection and use of information by those third parties is governed by their own privacy policies and practices.

TheracelLab does not control third-party privacy practices.

8. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including providing Services, maintaining subscriber or customer relationships, administering purchases, maintaining legal and accounting records, resolving disputes, enforcing agreements, preventing fraud, and complying with applicable law.

Different categories of information may be retained for different periods.

We may retain certain limited information after you unsubscribe or stop using the Services where reasonably necessary for legal, accounting, security, recordkeeping, or opt-out purposes.

9. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information within our control.

Some personal information is stored or processed by platforms and service providers whose technical infrastructure TheracelLab does not directly control.

No transmission, storage system, website, or online service can be guaranteed to be completely secure.

10. Your Privacy Rights

Depending on your location and the laws applicable to TheracelLab and the relevant processing, you may have rights concerning your personal information, including rights to:

• request access;
• request correction;
• request deletion;
• request a portable copy of certain information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent; or
• opt out of certain communications or processing.

Privacy rights are subject to applicable legal thresholds, conditions, exceptions, and verification requirements.

To submit a request concerning personal information controlled by TheracelLab, contact: variana@theracellab.com

Information processed independently by Substack or another third-party platform may be subject to that platform's privacy-request procedures.

11. California Residents

California residents may have additional privacy rights where applicable California privacy law applies to TheracelLab and the relevant processing.

Nothing in this Privacy Policy represents that TheracelLab is subject to every provision of the California Consumer Privacy Act or other California privacy statutes where applicable statutory thresholds or requirements are not met.

Where applicable, California residents may have rights relating to access, correction, deletion, and certain forms of sale or sharing of personal information, subject to applicable exceptions and verification requirements.

12. EEA and UK Residents

Where EEA or UK data-protection law applies, TheracelLab may process personal information:

• as necessary to provide subscriptions, products, or Services you request;
• based on TheracelLab's legitimate interests in operating, protecting, and improving the Publication and Services;
• based on consent where consent is required; or
• where necessary to comply with legal obligations.

Where applicable, individuals may have rights including access, correction, deletion, restriction, portability, objection to certain processing, and withdrawal of consent where processing is based on consent.

You may also have the right to complain to the appropriate data-protection authority.

13. International Data Processing

TheracelLab is operated from the United States.

Personal information may be processed in the United States or in other jurisdictions where Substack or other service providers operate.

Where applicable law requires particular safeguards for international transfers, the relevant controller or service provider may use legally recognized transfer mechanisms or other permitted safeguards.

14. Children's Privacy

The Services are not directed to children under 16, and TheracelLab does not knowingly seek to collect personal information from children under 16.

If we learn that personal information has been collected from a child in circumstances where such collection was not permitted, we may take reasonable steps to delete or otherwise address that information.

15. Changes to This Privacy Policy

We may update this Privacy Policy as TheracelLab's Services, technologies, products, or legal obligations change.

The current version will be posted with an updated Effective Date.

16. Contact

For privacy questions or requests:

TheracelLab
Email: variana@theracellab.com