Between Startup and Exit

Effective Date: 9/1/26

This Privacy Policy explains how Grab Bag Holdings LLC dba Blue Chair Advisory (”Blue Chair,” “we,” “us,” “our”) handles information in connection with Between Startup and Exit (the “Publication”) at articles.bluechairadvisory.com. The Publication is available to subscribers worldwide. This Policy applies alongside our Terms of Service and does not cover Substack’s own handling of your information, which is governed by Substack’s privacy policy.

1. What We Collect

When you subscribe, Substack processes subscriber information through its platform. For information Substack processes on our behalf in connection with our subscriber list, Blue Chair is the data controller and Substack acts as a data processor. This may include your email address, name or display name if provided, subscription status, and engagement data Substack makes available to us, such as opens, clicks, pageviews, reader counts and referral information. If you send us an inquiry or reply directly, we receive whatever information you include in that message. We do not separately collect information through self-assessments, checklists or other downloadable resources; those are completed and scored by you, and nothing you enter is submitted to us.

2. How We Use It

We use subscriber information for the following purposes, each with its own basis under applicable law: delivering the Publication to you, based on your consent when you subscribed or, where applicable, our legitimate interest in providing content you requested; responding to communications you send us, based on our legitimate interest in doing so; and measuring general engagement with the Publication, based on our legitimate interest in understanding and improving it. Our review of engagement data is limited to aggregate publication performance; we do not currently build individual behavioral profiles, predict subscriber preferences, segment subscribers based on behavioral history, or combine this data with external behavioral datasets. Where we rely on your consent, you may withdraw it at any time by unsubscribing, without affecting the lawfulness of processing carried out before withdrawal. We do not sell subscriber information.

3. Third Parties

We may disclose information to service providers that support operation of the Publication, where necessary to provide those services, and as required by law. Substack’s own processing of subscriber information is governed by Substack’s Privacy Policy and Publisher Agreement. For subscriber information it processes on our behalf, Substack acts as our data processor; it may also act as an independent data controller for its own platform-related purposes, as described in its privacy materials.

4. International Data Transfers

Blue Chair is based in the United States, and subscriber information may be processed in the United States and other countries. Where required by applicable law, cross-border transfers are made subject to recognized legal safeguards, which may include adequacy mechanisms, contractual safeguards or other approved transfer frameworks.

5. Data Retention

We retain subscriber information for as long as reasonably necessary for the purposes described in this Policy and as permitted or required by applicable law. Information processed through Substack is also subject to Substack’s own retention practices and contractual obligations.

6. Your Rights

Depending on where you live, you may have rights such as access, correction, deletion, restriction, objection or portability with respect to your information. Not every right applies in every jurisdiction. You can exercise available rights by unsubscribing directly or by contacting us. If you are located in the European Economic Area, the United Kingdom or another jurisdiction with a supervisory authority for data protection, you also have the right to lodge a complaint with that authority.

7. Children

The Publication is not directed to children, and Blue Chair does not knowingly use subscriber information for the purpose of marketing the Publication to children.

8. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by an updated effective date above.

9. Contact

Questions about this Privacy Policy can be directed to inquiries@bluechairadvisory.com.