Privacy Policy

Last updated: 27 September 2026

This Privacy Policy explains how personal data is processed in connection with the Creative Leadership Forum, hosted on Substack.

1. Data Controller

The controller responsible for the processing described in this policy is:

Ingenious Thinking GmbH
Hauptstraße 151
10827 Berlin
Germany

Managing Director: Akin Duyar
Commercial Register: Amtsgericht Charlottenburg, HRB 156356
VAT ID: DE342978326
Email: contact@ingenious-thinking.com

2. Substack as Technology Provider

The Creative Leadership Forum is hosted on Substack.

Substack generally acts as a data processor when processing subscriber data on our behalf. For certain platform-related activities, Substack may also act as an independent data controller under its own Privacy Policy. Substack’s Publisher Agreement includes a Data Processing Addendum and Standard Contractual Clauses for transfers of personal data from the European Economic Area to third countries. Substack Unterstützung

3. Personal Data We Process

Depending on how you interact with the Creative Leadership Forum, we may process:

• your email address

• your name or profile information, where provided

• your subscription status

• information about your interaction with our publications, such as email opens, link clicks and article views

• comments, replies or other information you choose to submit

• correspondence when you contact us directly

Substack may collect additional technical and usage information for operating its platform under its own Privacy Policy. Substack

4. Purposes and Legal Bases

We process personal data for the following purposes:

Subscriptions and newsletter delivery
To manage your subscription and send you Creative Leadership Forum publications and updates. The legal basis is your consent under Article 6(1)(a) GDPR and, where applicable, processing necessary to provide a service you have requested under Article 6(1)(b) GDPR.

Communication
To respond to inquiries, comments or other communications. The legal basis is Article 6(1)(b) GDPR where the communication relates to a requested service, or Article 6(1)(f) GDPR based on our legitimate interest in communicating with readers, contributors and interested parties.

Analytics and improvement
We may use information made available through Substack, such as readership and engagement data, to understand how the publication is used and improve our content. The legal basis is Article 6(1)(f) GDPR, based on our legitimate interest in operating and improving the Creative Leadership Forum.

5. Data Recipients and International Transfers

Personal data may be processed by Substack, Inc. and service providers used by Substack to operate the platform.

Substack is based in the United States. Where Substack processes personal data on our behalf, its Publisher Agreement provides contractual safeguards, including EU Standard Contractual Clauses, for relevant international data transfers. Substack

6. Retention

We retain personal data only for as long as necessary for the purposes described above or as required by law.

Subscriber data is generally retained for the duration of the subscription. If you unsubscribe, we may retain limited information where necessary to document your unsubscribe request or comply with legal obligations.

7. Your Rights

Under the GDPR, you may have the right to:

• access your personal data

• correct inaccurate personal data

• request deletion of your personal data

• restrict processing

• object to certain processing

• receive your personal data in a portable format

• withdraw consent at any time with effect for the future

You may unsubscribe from Creative Leadership Forum emails at any time using the unsubscribe link contained in each email.

To exercise your rights, contact us at:

contact@ingenious-thinking.com

8. Right to Lodge a Complaint

You also have the right to lodge a complaint with a data protection supervisory authority.

The supervisory authority responsible for companies based in Berlin is the Berliner Beauftragte für Datenschutz und Informationsfreiheit. Datenschutz Berlin

9. Changes to This Privacy Policy

We may update this Privacy Policy if our services, technical setup or legal requirements change.