Transaction Intelligence is a personal publication run by me, Matt Berryman. This policy explains what the site collects when you read, subscribe or comment, why, and what you can do about it. I decide how this information is used, which makes me its controller under the UK GDPR and, for readers in the EU, the EU GDPR. You can reach me at hello@transactionintelligence.net.
When you read the site
The site counts its readers with Ghost's built-in web analytics. They are first-party, served from this domain, and they use no cookies and no other persistent storage in your browser. Unique visitors are counted within 24-hour windows, so someone who reads today and again next week counts twice. What I see is which pages are read, which sites send readers here, and which countries they come from. If you subscribe and are signed in, Ghost also records your member ID against the visit.
Ghost processes this data with its analytics partner, Tinybird. For sites hosted by Ghost, as this one is, the analytics data is stored in EU regions.
So that I can see where subscribers come from, Ghost keeps a short list of the pages you have viewed in your browser's session storage. It stays in that tab and is cleared when you close it. It leaves your browser only if you subscribe, when the first entry tells me which page or site brought you here.
The sign-up and search tools load from the jsDelivr content delivery network, which, like any web server, receives your IP address when it sends them.
When you subscribe
I hold your email address, your name if you give it, the newsletter you chose, when you subscribed and last visited, the page or site you subscribed from, and your approximate location, which Ghost works out from your IP address when you sign up.
Each newsletter records whether you open it, through a small image in the email, and which links you click, as each link passes through the site on its way to its destination. That tells me which essays are read and followed up. Most email apps let you block images, which stops the open count.
Your email address is used to send the newsletter and the sign-in links you ask for. It is never sold, never used for advertising, and never shared with anyone except the providers below, who run the site and send its email.
When you comment
Your name and your comment are shown publicly beside the essay.
Cookies
Signing in sets cookies that keep you signed in; the site cannot keep you signed in without them. The site sets no advertising or analytics cookies.
Who processes it for me
Ghost (Ghost Foundation) hosts the site and sends the newsletter, acting as my processor under its data processing agreement, and uses providers of its own to do so. Tinybird runs Ghost's web analytics. Some of that processing takes place outside the UK and the EU; where it does, Ghost's agreement applies standard contractual clauses.
The basis for using it
I send the newsletter because you asked for it, and you can withdraw that consent at any time by unsubscribing. I count readers, sources and newsletter opens and clicks because I have a legitimate interest in knowing which essays are read, and the measures above (no cookies for analytics, no advertising, no sharing) are how I balance that against your privacy.
How long I keep it
Your subscriber record stays until you ask me to delete it. Unsubscribing stops the emails but keeps the record, so that I don't add you again by mistake. Tell me if you want it gone and I will delete it.
Your rights
You can ask to see the information I hold about you, to correct it, to delete it or to take a copy, and you can object to its use for analytics. Email hello@transactionintelligence.net. If you are unhappy with my answer, you can complain to the Information Commissioner's Office (ico.org.uk) or, in the EU, to your national data protection authority.
Changes
If I change this policy in a way that matters, I will say so here and, if you subscribe, by email.
Last updated: 16 October 2026