Privacy Policy

Subject To Contract is a weekly newsletter published by Welto Limited (“we”, “us”, “our”), a company registered in England and Wales with company number 14630258. Our registered office is 167–169 Great Portland Street, London, England, W1W 5PF.

We are the data controller for the personal data described in this policy, which means we decide how and why it is used. We are registered with the Information Commissioner’s Office under registration number ZC278996.

If you have any questions about this policy or your data, email us at subjecttocontract@weltomedia.com.

When you subscribe on our website. Your email address. The signup form is provided by beehiiv, our newsletter platform.

When you subscribe through a Facebook or Instagram lead form. Your email address. Meta collects this on our behalf and passes it to us so we can add you to the newsletter.

When you read the newsletter. Like most email newsletters, beehiiv records whether an email was delivered and opened and which links were clicked, along with basic device and location information inferred from your IP address.

When you visit our website. Our site uses the Meta Pixel and the LinkedIn Insight Tag (see section 5), which collect information such as your IP address, browser and device type, pages viewed, the advert that brought you to the site, and whether you went on to subscribe.

When you contact us. Your name, email address and anything you choose to include in your message.

• To send you the newsletter and occasional related emails, such as a welcome email. Our legal basis is your consent, which you give when you subscribe. You can withdraw it at any time by clicking “unsubscribe” in any email.
• To understand how the newsletter performs, for example which stories are most read, so we can improve it. Our legal basis is our legitimate interest in running and improving the publication.
• To run and measure advertising on Meta (Facebook and Instagram) and LinkedIn, including finding out which adverts lead to subscriptions and showing adverts to people likely to be interested. Where this relies on cookies or similar technologies, our legal basis is your consent.
• To reply to your messages and handle requests about your data. Our legal basis is our legitimate interest in responding to you, or our legal obligation where it concerns your data protection rights.

We do not sell your personal data, and we do not use it to make automated decisions about you.

We only share your data with service providers who help us run Subject To Contract:

• beehiiv, which hosts our subscriber list and sends the newsletter. beehiiv acts as our processor. See the beehiiv privacy policy.
• Meta Platforms Ireland Ltd, for Facebook and Instagram lead forms, the Meta Pixel and ad measurement. See the Meta privacy policy.
• LinkedIn Ireland Unlimited Company, for the LinkedIn Insight Tag and ad measurement. See the LinkedIn privacy policy.
• Our website host, which processes standard server logs such as IP addresses to keep the site running and secure.

We may also disclose data where required by law, or to a buyer if Subject To Contract is ever sold or transferred.

If you accept cookies on our website, we load small pieces of code from Meta and LinkedIn that set cookies or similar identifiers in your browser. If you reject them, or haven’t made a choice yet, they are not loaded. They tell us how many people visit from our adverts and how many go on to subscribe, help us build audiences for future adverts, and let Meta and LinkedIn show our adverts to people who are more likely to find them relevant.

Meta and LinkedIn may link this information to your account on their platforms and use it in line with their own privacy policies. We only see aggregated reports, not who you are.

We store your choice in your browser so we don’t ask again. You can change it at any time using the “Cookie settings” link at the bottom of every page.

You can also control this tracking by:

• adjusting the cookie settings in your browser, or blocking third-party cookies;
• changing your ad preferences in Meta and LinkedIn; or
• opting out of interest-based advertising at youronlinechoices.com.

The newsletter itself also uses tracking pixels and link tracking provided by beehiiv to measure opens and clicks. You can block these by turning off image loading in your email client.

beehiiv is based in the United States, and Meta and LinkedIn may process data in the United States and elsewhere. Where your data is transferred outside the UK, we rely on safeguards recognised under UK data protection law, such as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses or the UK–US Data Bridge.

We keep your subscriber details for as long as you are subscribed. If you unsubscribe, we keep a record of your email address so we don’t contact you again, and delete the rest of your subscriber data within a reasonable period. Lead form data held by Meta is retained according to Meta’s own policies. Emails you send us are kept for as long as needed to deal with your enquiry.

Under UK data protection law you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to how we use your data, including for direct marketing;
• receive your data in a portable format; and
• withdraw your consent at any time, without affecting anything we did before you withdrew it.

To use any of these rights, email subjecttocontract@weltomedia.com. We may need to confirm your identity, and we will respond within one month.

If you are unhappy with how we have handled your data, please contact us first so we can try to put it right. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

We use reputable service providers and take reasonable steps to protect your data from loss, misuse and unauthorised access. No method of sending or storing data online is completely secure, so we cannot guarantee absolute security.

Subject To Contract is a professional publication and is not aimed at anyone under 18. We do not knowingly collect data from children.

We may update this policy from time to time, for example if we start using a new service. The date at the top of this page shows when it was last changed. If we make significant changes, we will let subscribers know by email.