Datenschutzerklärung

1. Who is responsible

The controller for all personal data described here is:

Macadamia SA I B.V.
Kapelweg 34, 3951 AD Maarn, Netherlands
KvK 42088901 · VAT NL869659406B01
info@mac-daily.com

Macadamia SA I B.V. publishes Mac Daily and operates its newsletter. Editorial responsibility for what is published rests with Joris Kroese as publisher-of-record; responsibility for your personal data rests with the company. Both are reachable at the addresses in the imprint.

We have not appointed a Data Protection Officer. Our processing is not large-scale processing of special categories, and does not involve regular and systematic monitoring of individuals on a large scale, so art. 37 GDPR does not require one. Data-subject requests go to info@mac-daily.com and are handled by the controller directly.

1.1 The current state of this system

Newsletter delivery and new sign-in requests are not enabled. The public Answers service is available separately and processes submitted questions as described in section 9 below.

When this page last said otherwise, two things it describes were commitments rather than code: the automated deletion behind the retention periods in §8, and the one-way hashing of suppression addresses in §3.3 and §10. Both are now built. The deletion job runs daily and takes every period from the same list this page renders its §8 table from, so the published table and the job that enforces it cannot drift apart. Suppression addresses are hashed the moment a record is written, by the database layer rather than by whatever code happens to be calling it.

They were built before the form opened, which was the point. A retention promise made after the first address arrives is a promise made too late.

2. What we do not do

Stated first, because it removes most of what a privacy policy usually has to explain.

• Sign-in uses email links rather than passwords. New sign-in requests are currently unavailable.
• No payment data. Mac Daily is free. If paid tiers launch, this policy will be updated before any payment data is collected.
• No advertising, no ad networks, no ad tech, no tracking pixels, no third-party cookies, no cross-site tracking, no fingerprinting, no data brokers.
• No purchased, rented or scraped lists. Every address on our list was submitted by the person who owns it and confirmed by clicking a link in a confirmation email.
• We never sell, rent or trade personal data. Not to advertisers, not to industry bodies, not to anyone.
• No special categories of personal data (art. 9 GDPR) are collected, and we have no use for any.
• No profiling and no automated decision-making producing legal or similarly significant effects (art. 22 GDPR). We do not score, segment or rank subscribers.
• No open or click tracking in the newsletter. We do not embed tracking pixels and we do not rewrite links to measure who clicked what. We know how many people are subscribed; we do not know which of them read a given issue.
• Your data never goes to an AI model. See section 9 — this is the question we expect most often and it has a hard answer.

3. What we collect, and why

Everything below relates to the newsletter. Reading mac-daily.com requires you to give us nothing.

Providing an email address is entirely voluntary. Nothing on Mac Daily is withheld from you for declining, except the newsletter itself and any gated dataset.

3.1 Double opt-in, and why we hold your IP

When you submit the signup form we do not add you to the list. We create a pending record and send you one email containing a confirmation link. You become a subscriber only when you click it. If you never click, the pending record is deleted after 30 days.

That confirmation click is what makes the consent valid. To be able to prove it later — which the accountability principle requires us to be able to do — we record the IP address the signup came from, together with the timestamp. We keep it in full for 12 months, after which it is truncated (the last octet of an IPv4 address, or everything below the /48 prefix of an IPv6 address, is discarded) and it is deleted entirely at 36 months. Truncation leaves enough to corroborate a country and network, and not enough to identify a connection.

3.2 The referral programme

If you refer someone, we store your address and theirs as a linked pair so the referral can be credited. This means we hold a record connecting two identifiable people. We do not use those pairs for anything else — no network analysis, no inferred relationships, no lookalike targeting. Either party can have the pair deleted on request without affecting their own subscription; the referral credit is then reversed.

3.3 The suppression list

When you unsubscribe, we do not simply delete you. Deleting the record entirely would mean that if your address were ever re-imported or re-submitted, we would have no way to know you had opted out, and we would mail you again. So an unsubscribe writes a permanent suppression record.

To keep that record from being a retained mailing list, the address in it is reduced to a one-way cryptographic hash. A hash cannot be sent an email. It can only be used to check whether an address being added to the list has previously opted out — which is exactly its purpose. The readable address is deleted 24 months after unsubscribe; the hash remains indefinitely, because the obligation to honour your opt-out does not expire.

This is a case where erasure under art. 17 GDPR is limited: we will delete your subscriber record on request, but we will retain the suppression hash. Deleting it would defeat the very right you exercised.

4. Analytics

We use Plausible, self-hosted on our own infrastructure.

• No cookies. No local storage. Nothing is written to or read from your device.
• No personal data is retained. No IP address is stored, no persistent identifier is created, and no profile of you is built.
• No cross-site tracking. Plausible cannot follow you off mac-daily.com, and nothing about you leaves our own servers.
• We do not use Google Analytics or any hosted analytics service.

Because nothing is stored on or read from your terminal equipment, art. 11.7a of the Dutch Telecommunications Act (implementing art. 5(3) of the ePrivacy Directive) does not apply, and there is no consent to obtain. This is why Mac Daily has no cookie banner. We consider a banner that asks permission for something we do not do to be worse than useless.

What we learn is aggregate: how many people read a page, which pages, roughly from which country, and which site sent them. We use it to decide what to publish more of.

5. Cookies

Mac Daily sets no analytics, advertising or preference cookies.

The only cookies that may reach your browser are strictly necessary ones set by our CDN, Cloudflare, to distinguish human traffic from automated traffic and to keep the site available (for example __cf_bm, typically expiring within 30 minutes). These are exempt from the consent requirement under art. 11.7a(3) Tw as strictly necessary for delivering the service you requested. They carry no identifier we can read and we do not use them for any purpose of our own.

Links you follow to a gated dataset or a preference page carry a one-time token in the URL, not a cookie.

6. Who processes your data

Each processor operates under a written data processing agreement on art. 28 GDPR terms. We add no processor without one, and we do not use processors for purposes beyond those listed.

Beyond these, we disclose personal data to no one — with the single exception of a binding legal order from a competent authority, which we would comply with only to the extent required, and would tell you about unless legally prohibited from doing so.

7. Where your data is processed

Your data is processed within the EU/EEA.

The database, the newsletter system and the newsroom run on hardware we own and control, on our own premises, within the EU/EEA — not in a commercial data centre and not in a public cloud. We name the specific country to any data subject who asks, and to any supervisory authority on request; we do not publish the exact location of a physical machine that holds a subscriber list.

The public website is static and served from Cloudflare’s edge, so the site remains available whether or not our own hardware is running.

Transfers outside the EU/EEA. Amazon SES and Cloudflare are configured for EU processing, but both are subsidiaries of US-parent groups and limited access from outside the EU/EEA for support and security purposes cannot be excluded. Where that occurs it is covered by the European Commission’s Standard Contractual Clauses under art. 46(2)(c) GDPR, supplemented by the transfer assessments and technical measures in the relevant processor agreement. No other transfer outside the EU/EEA takes place.

8. How long we keep things

Each of these periods is carried out by an automated deletion job, not left to intention: nothing is kept “until we get round to it”. The job runs daily and reads this exact table — the periods above are its input, not a description of it.

9. AI, and your data

Mac Daily’s articles are generated by an AI pipeline. This raises an obvious question, and it has a categorical answer:

No subscriber data — no email address, no IP address, no preference, no referral pair, nothing derived from any of them — is ever sent to Anthropic or to any other AI model provider.

The editorial article-generation pipeline reads public sources and has no read access to the subscriber database. Subscriber records are not included in its model prompts. The separate Answers service processes the question text a reader submits.

The Answers service sends submitted question text and selected reference material to Cloudflare Workers AI to generate and check an answer. The public form requests publication of the question and answer in the community feed; a successful answer may be visible to other readers. Do not submit personal or confidential information. A safety check can refuse a question, but it is not a guarantee that private information will be detected.

The service stores operational question and answer records with a 90-day deletion rule. Shared entries in the public community feed are stored separately and do not have that automatic expiry. To request removal, contact the publisher using the details in the imprint and identify the question or answer.

Nor is AI used to make decisions about you. Nothing about your subscription — whether you receive an edition, what is in it, what it costs — is determined by a model.

How the editorial pipeline itself works is documented separately at the AI disclosure page.

10. Security

Access to the subscriber database is restricted to the controller. Confirmation tokens are stored only as hashes, and suppression addresses are hashed on write — the readable address is removed at its retention period while the hash remains. Traffic to and from the site is encrypted in transit. Administrative access to our own infrastructure is not exposed to the public internet and is gated behind authenticated access control. The AI pipeline’s model credentials exist only on the production machine and never in the build system.

No system is beyond compromise. If a breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the supervisory authority within 72 hours and notify you directly where art. 34 GDPR requires it.

11. Your rights

Under the GDPR you have the right to:

• Access — a copy of the personal data we hold about you
• Rectification — correction of anything inaccurate
• Erasure — deletion of your data, subject to the suppression-list limit in section 3.3
• Restriction — to have processing paused while a dispute is resolved
• Portability — your data in a machine-readable format
• Object — to any processing based on legitimate interest, including the signup IP record
• Withdraw consent — at any time, without giving a reason, and without affecting the lawfulness of what came before

How to exercise them. Email info@mac-daily.com. There is no form to complete and no account to create. We answer within one month, and if a request is genuinely complex we will tell you before that month is up and take at most two more. We do not charge for any of this.

To unsubscribe you do not need to invoke a right: every newsletter carries a one-click unsubscribe link and a link to the preference centre, both of which work immediately and without logging in.

We may ask you to confirm control of the email address in question before acting on a request — this is the only identifier we hold, and answering an access request to the wrong person would itself be a breach.

12. Complaints

If you think we have handled your data wrongly, tell us first at info@mac-daily.com — we would rather fix it than be told about it by a regulator.

You also have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is:

Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag, Netherlands
autoriteitpersoonsgegevens.nl

You may also complain to the supervisory authority in the EU/EEA country where you live or work, or where the alleged infringement took place.

13. Children

Mac Daily is a business publication for the macadamia industry. It is not directed at children, and we do not knowingly collect data from anyone under 16. If you believe a child has subscribed, write to info@mac-daily.com and we will delete the record.

14. Changes to this policy

We will update this page when what we do changes. The version number and effective date at the foot of the page always reflect the current text, and material changes are summarised below. Where a change affects the basis on which we hold your data, we will tell subscribers by email before it takes effect rather than relying on you to check this page.