BelongingFirst: Rethink Culture

Privacy Policy
Effective date: August 22, 2025

This Privacy Policy explains how we collect, use, share, and protect information when you read, subscribe to, or interact with BelongingFirst: Rethink Culture (the “Publication”) on Substack.

Important: Substack powers our website, emails, payments, and account features. Substack is a separate company with its own Privacy Policy and Terms. Substack may act as a data controller for its platform‑level processing and as our data processor for publisher‑level subscriber relationships. Please review Substack’s Privacy Policy and role explanation for details. Substack Support

1) Who we are

This Publication is created and published by Andrea Carter, CEO of Andrea Carter Consulting and the creator of the neuroscience based Belonging First Methodology™. Andrea is an Organizational Scientist with a Master of Arts in Industrial and Organizational Psychology and an Adjunct Professor at Adler University. She is an award‑winning consultant and strategist.

Contact: info@belongingfirst.com

2) What we collect

We collect the minimum information needed to deliver this Publication and community.

• Subscriber data: email address, subscription tier, payment status, and settings. Payments are handled by Substack and its payment providers. Substack

• Engagement data: opens, clicks, reads, likes, comments, and replies captured by Substack analytics. Substack

• Community content: comments, replies, messages, and any profile information you choose to share.

• Technical data: IP address, device, and cookie identifiers collected by Substack for security, performance, and analytics. Substack

If you email us or fill out a form, we collect the information you provide so we can respond.

3) How we use information

We use your information to:

• send the newsletter and manage your subscription

• respond to messages and moderate community spaces

• improve content using aggregate analytics

• administer promotions or surveys when offered

• meet legal, security, and compliance requirements

Substack also processes your information for platform services. See Substack’s Privacy Policy for its uses as a controller. Substack

4) Legal bases (EU/UK GDPR)

Where GDPR applies, our legal bases include consent (for subscribing and receiving emails) and legitimate interests (to secure our services, measure performance, and improve content). Substack provides platform‑level GDPR materials and SCCs for international transfers.Substack GDPR

5) Consent and subscriber imports

We only email people who have opted in. We do not add people without consent. Substack requires consent for imported lists and may restrict publications that import non‑consenting contacts. We follow Substack’s import policy and content guidelines. Substack Support

6) Cookies and analytics

Substack uses cookies and similar technologies for authentication, performance, and analytics on publisher sites and substack.com. Cookie practices are explained in Substack’s Privacy Policy. Your browser settings may allow you to block cookies, but core features may not work. Substack Privacy

7) Sharing and service providers

We share your data with:

• Substack to operate the site, email delivery, comments, payments, and analytics

• Payment processors used by Substack to manage paid subscriptions

• Service providers we may use for lawful purposes such as support or compliance

We do not sell your personal information.

8) International transfers

Your information may be processed outside your province, state, or country. Substack explains its transfer mechanisms in its Privacy Policy. Substack

9) Data retention

We keep your information while you have an active subscription or account and for a reasonable period afterward for records, moderation, and compliance. We will retain and delete data consistent with legal obligations.

10) Your rights

Your privacy rights depend on your location. We honour applicable requests and will coordinate with Substack where required.

• Canada (PIPEDA): right to access and correct personal information and to challenge compliance. Privacy Commissioner Canada+1

• EU/UK GDPR: rights to access, rectification, erasure, restriction, objection, and portability, subject to legal limits. Substack provides GDPR guidance for platform processing. Substack Support

• California (CCPA/CPRA): rights to know, delete, correct, and opt out of certain uses where applicable. See Substack’s CCPA Policy for platform processing. Substack

How to make a request: For platform‑level data that Substack controls, you may also need to contact Substack directly via its help center. Substack Requests

11) Community spaces

Comments and community activity are public by default on Substack. Do not share sensitive personal information in public comments. We moderate according to our house rules and Substack’s community standards. Substack Guidelines

12) Children’s privacy

This Publication is for adults. You must meet Substack’s age requirements to use the platform and subscribe. Substack

13) Security

We use reasonable technical and organizational safeguards and partner with Substack, which provides platform‑level security and access controls. No online service can guarantee perfect security.

14) Changes to this policy

We may update this Privacy Policy from time to time. We will change the “Effective date” and post the new version here. Your continued use of the Publication means you accept the updated Policy.

15) Contact

Questions or privacy requests: admin@belongingfirst.com