Frugal Chic® Privacy & Cookie Policy

Effective date: 01 November 202

Website: frugalchic.co.uk

Introduction

Frugal Chic® (“we”, “us”, or “our”) is authored and published by Mia McGrath. We respect your privacy and are committed to protecting your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy & Cookie Policy informs you how we collect, use, store, and safeguard your personal data when you visit frugalchic.co.uk (the “Site”), subscribe to our newsletter, interact with our content, or purchase a paid subscription.

1. Data Controller Information

For the purposes of applicable data protection law:

• Primary Data Controller: Mia (operating as Frugal Chic) determines the purposes and means of processing subscriber lists, custom publication communications, and reader interactions.

• Platform Provider & Co-Controller/Processor: Frugal Chic is hosted on Substack, Inc. (“Substack”). Substack provides the technical infrastructure, payment handling framework, and platform analytics. Substack acts as a Data Processor on our behalf for newsletter distribution, and as an independent Data

Controller for general platform administration, account creation, and security.

Contact Details:

• Data Controller: Mia McGrath / Frugal Chic

• Email: admin@frugalchic.co.uk

• Website: frugalchic.co.uk

2. Personal Data We Collect

We may collect, use, store, and transfer different kinds of personal data about you, categorised as follows:

• Identity & Contact Data: Your name (if provided), username/handle, and email address when you sign up for free or paid tiers.

• Financial & Transaction Data: Information required to process paid subscription plans. Payments are processed directly by Stripe, Inc. We do not view, store, or process your credit/debit card numbers or bank details.

• Interactive & Profile Data: Comments, likes, message replies, survey responses, and feedback you post or send within the Frugal Chic community.

• Technical & Usage Data: Information about how you access and interact with the Site, including your IP address, browser type, operating system, pages viewed, time spent on pages, and engagement with our emails (e.g., email open rates and link clicks via tracking pixels).

3. How We Collect Your Personal Data

We collect data through:

1. Direct Interactions: When you enter your email address to subscribe, upgrade to a paid subscription, fill out forms, or post comments.

2. Automated Technologies: As you interact with our website or open our emails, Substack automatically collects technical data via cookies, web beacons, and server logs.

3. Third Parties: We receive payment confirmation status and billing metadata from Stripe.

4. Legal Bases for Processing (UK GDPR)

Under the UK GDPR, we rely on the following lawful bases to process your personal data:

5. Third-Party Service Providers & Data Sharing

We do not sell, rent, or trade your personal data. We share your information only with trusted third-party service providers necessary to run Frugal Chic:

• Substack, Inc. (Platform Operator): Hosts our content, manages our mailing list, and maintains subscriber logs. You can review Substack’s Privacy Policy at substack.com/privacy.

• Stripe, Inc. (Payment Processor): Manages payment collection, billing, and PCI-compliant processing for paid subscribers. You can review Stripe’s Privacy Policy at stripe.com/privacy.

6. Cookies & Tracking Technologies

Frugal Chic uses cookies and similar tracking technologies provided by our platform host, Substack, Inc., to ensure website functionality, manage user accounts, and analyse readership engagement under PECR and UK GDPR.

a. What are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device, keep you logged in, and analyse website performance.

b. Categories of Cookies We Use

1. Strictly Necessary Cookies (Platform Functionality)

• Purpose: Essential for navigating the website, keeping you logged into your account, maintaining platform security, and granting access to paid or subscriber-only posts.

• Legal Basis: Strictly necessary to provide services requested by the user (exempt from prior consent under PECR).

2. Analytical & Performance Cookies

• Purpose: Help us measure aggregated traffic statistics and understand reader navigation across frugalchic.co.uk so Mia can improve content quality and site design.

c. Third-Party Payment Cookies

• Purpose: When you purchase or manage a paid subscription, our payment processor, Stripe, Inc., uses security and fraud-prevention cookies to process payment credentials safely.

d. Disclosure of Email Tracking Pixels (Web Beacons)

Newsletter emails sent by Frugal Chic contain tiny electronic images known as tracking pixels (or web beacons) provided by Substack.

What they do: When you open an email or click on a link within a newsletter, these pixels record your engagement (such as open rates and click-through rates). This helps Mia understand which posts and topics resonate most with readers.

How to Opt-Out of Email Tracking: If you prefer not to have your email engagement tracked, you can easily disable tracking pixels by adjusting your email application settings:

• Disable “Load remote images” or turn off “Automatic image downloads” in your email client (e.g., Apple Mail, Gmail, Outlook).

• Read newsletters directly on the website at frugalchic.co.uk while using browser privacy extensions or ad/tracker blockers.

e. Managing Cookies in Your Browser

You can set your browser to refuse all or some browser cookies. However, disabling cookies may affect your ability to log in or access certain features on the Site.

7. International Data Transfers

Frugal Chic is hosted via Substack, which is based in the United States. Consequently, your personal data will be transferred to and processed outside the United Kingdom.

Where international data transfers occur, appropriate safeguards are implemented to ensure your personal data receives an equivalent level of protection as in the UK, including:

• Reliance on Standard Contractual Clauses (SCCs) / the UK International Data Transfer Addendum.

• Transfers to entities certified under recognised frameworks (such as the UK Extension to the EU-US Data Privacy Framework, where applicable).

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Active Subscribers: We retain your contact details while your subscription remains active.

• Unsubscribed Users: If you unsubscribe, your email address is kept on an inactive suppression list to ensure we honour your preference not to receive further mailings.

• Financial Records: Transaction records for paid tiers are kept for standard tax and statutory compliance periods (typically up to 6 years in the UK).

9. Your Legal Rights (UK GDPR)

Under UK data protection law, you have the following rights regarding your personal data:

1. Right to Access: Request a copy of the personal data we hold about you.

2. Right to Rectification: Request corrections to inaccurate or incomplete data.

3. Right to Erasure (“Right to be Forgotten”): Request the deletion of your personal data when it is no longer needed.

4. Right to Restrict Processing: Request that we restrict the processing of your data under certain circumstances.

5. Right to Data Portability: Request the transfer of your personal data to you or a third party in a structured, commonly used format.

6. Right to Object: Object to our reliance on legitimate interests as a legal basis.

7. Right to Withdraw Consent: Unsubscribe at any time using the link in the footer of any Frugal Chic email.

To exercise any of these rights, please contact us at admin@frugalchic.co.uk.

10. How to Complain

If you have concerns about how we handle your personal data, we encourage you to contact us directly so we can resolve the issue.

You also have the right to lodge a formal complaint with the UK supervisory authority:

Information Commission (ICO)

4th Floor, No. 3 Circle Square, 5 Hawkshaw Street, Manchester M1 7BL

Website: ico.org.uk

Helpline: 0303 123 1113

11. Children’s Privacy

Frugal Chic is not directed at individuals under the age of 13 (or 16 in certain jurisdictions), and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can promptly delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. Any updates will be posted on this page with an updated “Last Updated” date.

13. Contact Us

If you have questions, comments, or requests regarding this Privacy Policy, please contact:

• Publication: Frugal Chic

• Author: Mia McGrath

• Email: admin@frugalchic.co.uk

• Website: frugalchic.co.uk