Privacy Policy

Privacy Policy

Effective Date: March 25, 2026 Last Updated: March 25, 2026

This Privacy Policy describes how Subconscious Mind (“we,” “us,” or “our”), operated by The Vanderbilt Portfolio AG, collects, uses, shares, and protects personal information when you visit subconsciousmind.ai (the “Site”). This policy applies to all visitors worldwide and has been drafted to comply with the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the CPRA, the Saudi Arabia Personal Data Protection Law (PDPL), and other applicable data protection legislation.

By accessing or using the Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our practices, please do not use the Site.

1. Data Controller

The data controller responsible for your personal data is:

The Vanderbilt Portfolio AG Email: info@subconsciousmind.ai Website: https://subconsciousmind.ai/

For data protection inquiries, please contact our Data Protection Officer at info@subconsciousmind.ai.

2. Information We Collect

2.1 Information Collected Automatically

When you visit the Site, we automatically collect certain information through cookies and similar technologies, including:

• Log Data: Internet Protocol (IP) address, browser type and version, operating system, referring/exit pages, date and time stamps, clickstream data, and pages viewed.
• Device Information: Device type, screen resolution, unique device identifiers, and mobile network information.
• Location Data: Approximate geographic location derived from IP address (country and city level only).
• Usage Data: Pages visited, time spent on pages, scroll depth, click patterns, and interaction with site features.

2.2 Information Collected via Cookies

We use cookies and similar tracking technologies to collect and store information. Categories of cookies used include:

• Essential Cookies: Required for core site functionality including navigation, security, and session management. These cookies cannot be disabled.
• Analytics Cookies: Used via Google Analytics 4 (GA4) to understand how visitors interact with the Site. These cookies collect anonymous usage data including page views, session duration, bounce rate, and traffic sources.
• Advertising Cookies: Used via Google AdSense to serve personalized advertisements. These cookies track browsing behavior across websites to build interest profiles and deliver relevant ads.

For detailed information about each cookie, see our Cookie Policy.

2.3 Information You Provide Voluntarily

We may collect information that you voluntarily provide, including:

• Contact Information: Name and email address when you contact us via email at info@subconsciousmind.ai.
• Subscription Data: Email address when you subscribe to newsletters or premium content.
• Feedback: Any comments, suggestions, or other communications you send to us.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Site Operation: To provide, maintain, and improve the Site and its content.
• Analytics: To understand how visitors use the Site, identify trends, and optimize user experience.
• Advertising: To display relevant advertisements through Google AdSense, supporting the free availability of our content.
• Communication: To respond to your inquiries and provide customer support.
• Security: To detect, prevent, and address technical issues, fraud, and abuse.
• Legal Compliance: To comply with applicable laws, regulations, and legal processes.

3.1 Legal Bases for Processing (GDPR)

Under the GDPR, we process your personal data on the following legal bases:

• Consent (Article 6(1)(a)): For analytics and advertising cookies. You may grant or withdraw consent at any time through our cookie consent banner.
• Legitimate Interests (Article 6(1)(f)): For site operation, security, and essential functionality. Our legitimate interest is to provide and secure our journalism platform.
• Legal Obligation (Article 6(1)(c)): Where processing is necessary to comply with legal requirements.

4. Google Consent Mode v2

The Site implements Google Consent Mode v2 to ensure compliance with privacy regulations. This means:

• All Google tags (Analytics, AdSense) load in a restricted mode by default until you provide consent.
• Consent defaults are set to DENIED for: ad_storage, ad_user_data, ad_personalization, and analytics_storage.
• When you grant consent through our cookie banner, consent signals are updated in real-time.
• Your consent preferences are stored in localStorage and restored on subsequent visits.
• You can modify your preferences at any time by clicking “Cookie Settings” in the site footer.

5. Third-Party Services

5.1 Google Analytics 4

We use Google Analytics 4 to collect and analyze usage data. Google Analytics uses cookies to track user interactions. Data collected is processed by Google LLC in accordance with their Privacy Policy. We have configured GA4 to:

• Anonymize IP addresses where required by law.
• Respect consent signals via Consent Mode v2.
• Retain data for 14 months.

5.2 Google AdSense

We use Google AdSense to display advertisements. Google AdSense may use cookies and web beacons to serve ads based on your prior visits to the Site and other websites. Google’s use of advertising cookies is governed by the Google Advertising Privacy Policy. You can opt out of personalized advertising by visiting Google Ad Settings.

5.3 Google Fonts

We use Google Fonts to display typography. Google Fonts may collect your IP address and browser user agent when fonts are loaded. See Google Fonts Privacy.

5.4 Cloudflare

The Site is hosted on Cloudflare Pages. Cloudflare may process traffic data for security and performance purposes. See Cloudflare Privacy Policy.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share information with:

• Service Providers: Google (Analytics, AdSense, Fonts), Cloudflare (hosting) — only as described in this policy.
• Legal Requirements: When required by law, subpoena, or court order.
• Business Transfers: In connection with a merger, acquisition, or sale of assets.
• Protection of Rights: To protect the rights, property, or safety of Subconscious Mind, our users, or the public.

7. International Data Transfers

Your data may be transferred to and processed in countries outside your jurisdiction, including the United States and the European Economic Area. When such transfers occur, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Adequacy decisions where applicable.
• Certification frameworks such as the EU-US Data Privacy Framework.

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Analytics Data: 14 months (Google Analytics retention setting).
• Contact Information: Until you request deletion or 3 years after last contact.
• Cookie Consent Records: Until consent is withdrawn or 12 months, whichever comes first.
• Server Logs: 90 days (Cloudflare).

9. Your Rights

9.1 Rights Under GDPR (EU/EEA Residents)

You have the right to:

• Access: Request a copy of your personal data.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your data (“right to be forgotten”).
• Restriction: Request limitation of processing.
• Portability: Receive your data in a structured, machine-readable format.
• Object: Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent: Withdraw consent at any time without affecting prior processing.
• Lodge a Complaint: File a complaint with your local supervisory authority.

9.2 Rights Under CCPA/CPRA (California Residents)

California residents have the right to:

• Know: Request disclosure of personal information collected, used, and shared.
• Delete: Request deletion of personal information.
• Opt-Out: Opt out of the sale or sharing of personal information. We do not sell personal information.
• Non-Discrimination: Not be discriminated against for exercising privacy rights.
• Correct: Request correction of inaccurate personal information.
• Limit Use of Sensitive Personal Information: We do not collect sensitive personal information.

9.3 Rights Under PDPL (Saudi Arabia Residents)

Saudi Arabia residents have the right to:

• Be informed about data collection and processing purposes.
• Access their personal data.
• Request correction of inaccurate data.
• Request destruction of data when no longer needed.
• Withdraw consent.

10. Exercising Your Rights

To exercise any of the rights described above, contact us at:

Email: info@subconsciousmind.ai

We will respond to your request within 30 days (or sooner as required by applicable law). We may need to verify your identity before processing your request.

11. Children’s Privacy

The Site is not directed at children under 16 years of age. We do not knowingly collect personal information from children. If you believe we have collected data from a child, please contact us at info@subconsciousmind.ai, and we will promptly delete such information.

12. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• HTTPS encryption for all data in transit.
• Cloudflare DDoS protection and Web Application Firewall.
• Regular security assessments.
• Access controls and authentication for administrative functions.

However, no method of transmission over the Internet or electronic storage is completely secure.

13. Do Not Track

The Site does not respond to “Do Not Track” browser signals. However, you can control tracking through our cookie consent banner.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last Updated” date. Material changes will be communicated through a notice on the Site. Your continued use of the Site after changes constitutes acceptance of the updated policy.

15. Contact Information

For privacy-related inquiries:

Subconscious Mind Operated by The Vanderbilt Portfolio AG Email: info@subconsciousmind.ai Website: https://subconsciousmind.ai/

For general information about the site, visit our About page or Contact page.

16. Specific Cookie Details

The following cookies may be set when you visit subconsciousmind.ai:

16.1 Essential Cookies

16.2 Analytics Cookies (Require Consent)

16.3 Advertising Cookies (Require Consent)

17. Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal effects or similarly significant effects on you. Google AdSense may use automated processes to determine which advertisements to display, but this does not constitute automated decision-making as defined under GDPR Article 22.

18. Links to Other Websites

The Site contains links to other websites, including sister sites within The Vanderbilt Portfolio network and external authority sources. We are not responsible for the privacy practices of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

Within The Vanderbilt Portfolio network, each site operates under its own privacy policy, although all sites adhere to the same data protection standards described herein.

19. Supplementary Privacy Disclosures

19.1 For Nevada Residents

We do not sell covered information as defined under Nevada SB 220. If you are a Nevada resident and wish to submit a request regarding the sale of covered information, please contact us at info@subconsciousmind.ai.

19.2 For Virginia Residents (VCDPA)

Virginia residents have the right to access, correct, delete, and obtain a copy of personal data, as well as the right to opt out of the processing of personal data for purposes of targeted advertising, sale, or profiling. To exercise these rights, contact info@subconsciousmind.ai.

19.3 For Colorado Residents (CPA)

Colorado residents have similar rights under the Colorado Privacy Act, including the right to opt out of targeted advertising and the sale of personal data. Contact info@subconsciousmind.ai to exercise these rights.

19.4 For Connecticut Residents (CTDPA)

Connecticut residents may exercise their privacy rights, including the right to access, correct, delete, and obtain a copy of personal data. Contact info@subconsciousmind.ai.

20. Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) where processing is likely to result in a high risk to the rights and freedoms of individuals. Our assessment has determined that the current data processing activities on this Site present minimal risk, as we do not collect sensitive personal data, do not engage in large-scale profiling, and do not process data for purposes beyond those described in this policy.

21. Governing Law

This Privacy Policy is governed by and construed in accordance with applicable data protection laws, including the GDPR for EU/EEA residents, the CCPA/CPRA for California residents, and the PDPL for Saudi Arabia residents. In the event of a conflict between this policy and applicable law, the applicable law shall prevail.