Privacy Policy

BAS Holdings LLC — Broke-Ass Stuart

PO Box 420345, San Francisco, CA 94142

[email protected]

Last Updated: September 13, 2026

This Privacy Policy applies to brokeassstuart.com and shop.brokeassstuart.com (collectively, "our sites"), operated by BAS Holdings LLC ("we," "us," or "our"). It explains what information we collect, how we use it, who we share it with, and your rights regarding your data. Please read this policy carefully. By using our sites or subscribing to our newsletter, you agree to the practices described here. --- ## 1. Information We Collect From newsletter subscribers (brokeassstuart.com): - Email address - Name (if provided) - Newsletter engagement data (opens, clicks, subscription preferences) - General location data derived from IP address From shop customers (shop.brokeassstuart.com): - Name, email address, and phone number - Billing and shipping address - Purchase history and order details - Payment information (processed securely by Shopify — we do not store your full payment card details) From all site visitors: - Browsing behavior and page views collected via beehiiv's built-in website analytics and Google Analytics 4 - Device type, browser, and general location information - Cookies and similar tracking technologies (see Section 4) --- ## 2. How We Use Your Information We use the information we collect to: - Send you our newsletter and event updates you've subscribed to - Process and fulfill shop orders, including shipping and customer service - Analyze how our content and site are performing so we can improve them - Understand where our audience comes from and what they care about - Conduct remarketing — showing ads to people who have previously visited our site, via platforms like Meta (Facebook/Instagram) — if you have not opted out - Comply with legal obligations and protect our rights We do not use your information to make automated decisions that significantly affect you. Identifying potential supporters Some of our journalism is funded through charitable contributions made via our fiscal sponsor, Independent Arts & Media, a 501(c)(3) nonprofit organization. To support that fundraising, we may review information we already hold about you — your newsletter engagement, your history of purchases or memberships, and the city or region you have told us you live in — to understand who might be interested in supporting our work more deeply. We may also consult publicly available sources such as public campaign finance filings, published nonprofit donor listings, professional profiles, and public business records. We do not currently purchase wealth estimates, net worth scores, or financial profiles from commercial data brokers. If that ever changes, we will update this policy and tell subscribers before we begin. If you would prefer that we not include your information in this analysis, email us at [email protected] and we will exclude you. This will not affect your subscription or your access to anything we publish. --- ## 3. How We Share Your Information We do not sell your personal information to third parties. We share information only with the service providers who help us operate: - beehiiv — our newsletter platform and website host, which processes subscriber and analytics data on our behalf - Shopify — our e-commerce platform, which processes shop orders and payment data - Google — we use Google Analytics 4 to understand site traffic and user behavior. Google may use this data in accordance with its own privacy policy. You can opt out at tools.google.com/dlpage/gaoptout. - Meta (Facebook/Instagram) — we may use Meta's pixel for remarketing purposes, which allows us to show ads to past site visitors. You can manage your ad preferences at facebook.com/adpreferences. - Legal and safety disclosures — we may share information when required by law, to protect our rights, or to prevent harm. We do not share your personally identifiable information with advertisers or other third parties for their independent marketing purposes. --- ## 4. Cookies Our sites use cookies — small files placed on your device — to help us understand how visitors use our sites and to support remarketing. The types of cookies we use include: - Essential cookies: Required for the site to function (e.g., shopping cart, login) - Analytics cookies: Used by Google Analytics 4 to track page views and site behavior - Advertising cookies: Used by Meta and similar platforms for remarketing You can control cookies through your browser settings. Note that disabling some cookies may affect your experience on our sites. --- ## 5. Data Security We take reasonable steps to protect your information from unauthorized access or disclosure. Our sites use SSL encryption, and sensitive payment data is handled directly by Shopify and never stored on our servers. In the event of a data breach that affects your personal information, we will notify you by email within 7 business days. --- ## 6. Data Retention We retain newsletter subscriber data for as long as your subscription is active. If you unsubscribe, your data may be retained for a period of time for legal and operational reasons before being deleted. Shop order data is retained as required for accounting, tax, and legal compliance. You may request deletion of your data at any time (see Section 8). --- ## 7. Children's Privacy Our sites are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us and we will promptly delete it. --- ## 8. Your Rights and Choices Unsubscribe from email: Every newsletter we send includes an unsubscribe link. You can also email us at [email protected] to be removed. Update your information: Email us and we'll make corrections. Request deletion: You can request that we delete your personal data by emailing us at [email protected]. Opt out of Google Analytics: Use Google's opt-out browser add-on at tools.google.com/dlpage/gaoptout. Opt out of Meta remarketing: Manage your ad preferences at facebook.com/adpreferences or visit aboutads.info. --- ## 9. California Privacy Rights (CCPA/CPRA) If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA): - Right to Know: You can request a copy of the personal information we have collected about you, the categories of sources it came from, and the purposes for which it was used. - Right to Delete: You can request that we delete your personal information, subject to certain exceptions. - Right to Correct: You can request that we correct inaccurate personal information we hold about you. - Right to Opt Out of Sale or Sharing: We do not sell your personal information. However, our use of Google Analytics and Meta's advertising pixel may constitute "sharing" under California's broad definition. You can opt out of this at any time (see below). - Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights. - Right to Limit Use of Sensitive Personal Information: We do not collect sensitive personal information as defined by CPRA. To exercise any of these rights, email us at [email protected] with the subject line "California Privacy Request." We will respond within 45 days. --- ## 10. Do Not Sell or Share My Personal Information We do not sell your personal information. However, our use of third-party analytics and advertising tools (Google Analytics 4 and Meta pixel) may be considered "sharing" of personal data under California law. To opt out of this sharing: - Google Analytics: tools.google.com/dlpage/gaoptout - Meta advertising: facebook.com/adpreferences - Email us directly: [email protected] and we will assist you

We honor Global Privacy Control (GPC) signals where technically feasible.

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## 11. Third-Party Links

Our site may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

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## 12. CAN-SPAM Compliance

In accordance with the CAN-SPAM Act, all marketing emails we send will:

• Clearly identify themselves as commercial communications

• Include our physical mailing address (PO Box 411194, San Francisco, CA 94141)

• Include a working unsubscribe link

• Honor unsubscribe requests promptly

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## 13. DMCA / Copyright

If you believe content on our site infringes your copyright, please send a written notice to:

Stuart Schuffman
BAS Holdings LLC
PO Box 420345
San Francisco, CA 94142
[email protected] Phone: 415-322-9269 Your notice must include: identification of the copyrighted work, identification of the infringing material and its location on our site, your contact information, a good faith belief statement, and a statement of accuracy under penalty of perjury. --- ## 14. Changes to This Policy We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. --- ## 15. Contact Us For any privacy-related questions or requests: BAS Holdings LLC PO Box 420345
San Francisco, CA 94142 [email protected] --- This policy covers brokeassstuart.com (powered by beehiiv) and shop.brokeassstuart.com (powered by Shopify). For Shopify's own privacy practices, see shopify.com/legal/privacy. For beehiiv's privacy practices, see beehiiv.com/privacy.