Last Updated: July 7, 2026

1. Welcome

War on the Rocks Media, Inc. (“WOTR” “we,” “us,” or “our”) operates the website https://warontherocks.com (the “Site”). This Privacy Policy describes how we collect, use, disclose, and protect your personal information in compliance with applicable privacy laws. By accessing the Site on any computer, mobile phone, tablet, or other device (collectively, “Device”), subscribing to our newsletters, purchasing or using a membership subscription, or otherwise interacting with WOTR, you agree to the terms of this Privacy Policy. By using our Site, you consent to the collection, use, and storage of information as outlined in this Privacy Policy. If you do not agree, please do not use the Site.

2. Information We Collect

2.1 Account and Membership Information

If you purchase, activate, or manage a membership subscription, we may collect:

• Identifiers and contact details (such as name, email address, and similar account identifiers);
• Account access data used to authenticate you (for example, password or authentication tokens, depending on the login method);
• Membership subscription details (subscription status, renewal, and cancellation information);
• Billing address and related transaction details; and
• Customer support and membership administration communications.

2.2 Payment Information

When you pay for a membership or other purchase, payment card information is generally processed by third-party payment processors and/or subscription platforms. We may receive limited information about the transaction (such as payment status and partial card metadata like card type and last four digits), but typically do not receive or store full payment card numbers.

2.3 Member Profile Information

If you sign up to receive newsletters (including our daily newsletter and other topical newsletters), we may collect your email address and, in some cases, your name and other fields requested at sign-up (for example, an optional website field or professional context). If you have an account, we may also store your newsletter and content preferences so we can send the newsletters you choose and tailor delivery of member-only features.

2.4 Community and User Content

Some Services may allow member interaction through a community forum (including the War Hall). If you participate, we may collect:

• Profile information you choose to provide (e.g., display name, biography, profile image);
• Content you post (comments, replies, messages, reactions, or other contributions); and
• Moderation, safety, and integrity-related records associated with those contributions.

Please remember that content you choose to post in a community forum or similar feature may be visible to others, depending on the settings and design of the forum.

2.5 Submissions, Pitches, and Editorial Communications

If you submit a pitch or article (or otherwise communicate with editorial staff), we may collect the personal information included in your email and attachments, such as your name, email address, professional background, affiliations, CV/resume, biography, and other information you choose to provide.

If we publish content you author, we may also process the information required for attribution, publication, and editorial integrity (for example, author name, bio, and related credentials), consistent with our editorial practices.

2.6 Automatically Collected Information

When you use our Site, we may collect certain information automatically from you, which may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about when and how you use our Services, and other technical information. When you access our Services through a mobile device, we also automatically collect certain mobile device information, including the type of device, your mobile operating system, and your mobile Internet browser.

2.7 Communications

We collect your email address if you sign up to receive emails, invites, and newsletters from us regarding our activities. We collect information, such as your name and email address, to the extent necessary to provide the Services you have requested and/or to provide customer support.

2.8 Information from Third Parties

We may receive information from third parties in limited contexts, such as:

• Subscription platforms and processors that facilitate membership subscription, authentication, or delivery of membership benefits;
• Podcast and distribution platforms used to deliver content;
• Social networks if you engage with our pages or content there; and
• Service providers that help us with analytics, advertising measurement, and fraud/security monitoring.

3. How We Use Your Information

We use the information we collect for the purposes described in this Privacy Policy, which may include to:

• Providing and improving our publishing Services;
• Operating membership subscriptions and delivering member benefits;
• Processing payments, orders, and transactions, process donations, event registrations, and related transactions;
• Managing newsletter subscriptions, content preferences, and communications you request;
• Responding to inquiries and providing customer support;
• Editorial operations, including reviewing pitches/submissions and communicating with authors;
• Advertising, sponsorship, and business development (including measurement and reporting related to marketing and ad placements);
• Operate, maintain, and improve our Site, member systems, and communications;
• Respond to inquiries, comments, and requests for support;
• Send administrative communications (e.g., confirmations, updates, policy notices, security alerts);
• Prevent, investigate, and respond to fraudulent, unauthorized, or unlawful activity;
• Comply with applicable legal obligations.

We may communicate with you via email, postal mail, or other permitted channels to provide services and updates related to your membership or interactions with WOTR. You may opt out of marketing communications at any time.

4. Legal Bases for Processing

Where applicable (including for users located in the EEA, Switzerland, or the UK), we process personal data only when we have a lawful basis to do so:

• Performance of Contract. When you become a Member and subscribe, we will process your information to provide you with member benefits, including access to member-only content, and as necessary to fulfill those obligations.
• Legitimate Interests. We may process personal data for organizational administration, alumni engagement, fraud prevention, security monitoring, analytics, and governance purposes, provided those interests are not overridden by your rights.
• Consent. Where required, we rely on your consent (e.g., marketing communications, certain cookies). You may withdraw consent at any time.
• Legal Compliance. We process personal data as necessary to comply with legal and regulatory obligations.

5. Disclosure and Sharing of Information

We do not sell or rent your personal information.

We may disclose personal information in the following circumstances:

5.1 Service Providers

We may share personal information with service providers that help us operate the Services, such as:

• Website hosting and infrastructure providers;
• Email and newsletter delivery vendors;
• Customer support tools;
• Analytics and security vendors; and
• Order and payment-related vendors.

These service providers are contractually required to use your information solely to provide services to us (and for no other purpose) and to comply with appropriate security measures.

5.2 Membership, Subscription, and Content Partners

Our membership program and certain membership benefits may be delivered through third-party subscription platforms and podcast delivery services. For example, membership sign-up flows may direct you to a checkout experience and gift subscription checkout is available through Supporting Cast. Depending on your choices, these partners may process personal information as part of providing subscription management, authentication, and delivery of membership benefits (such as private podcast feeds).

Such sharing is limited to legitimate organizational purposes (e.g., membership administration, scholarship review, leadership development, event coordination).

5.3 Advertising, Sponsorship, and Measurement

WOTR offers podcast and newsletter advertising and sponsorship opportunities. We may work with advertising and measurement services that use cookies or similar technologies to understand performance, measure ad impressions, and improve delivery. Depending on the tools used, these disclosures could be considered “sharing” for cross-context behavioral advertising under certain laws. If so, we provide opt-out mechanisms as described in the “Your Privacy Rights” section below.

5.4 Business Transfers

In the unlikely event of a merger, restructuring, or organizational transition, personal information may be transferred as part of that process, subject to continued protection consistent with this Privacy Policy.

5.5 Analytics Services

We use third-party web analytics services, like Google Analytics, in our online services. These providers help us analyze how users navigate our online platforms. Information collected through Google Analytics is automatically sent to Google, which may use cookies to assist with the analysis. Google Analytics can also provide demographic, interest-related, geographic, and referral data that WOTR may use to better understand our customer base. Session User ID tracking and stitching may also be used to gain further insights into how our users access our websites from different devices.

5.6 Legal Requirements

We may disclose your personal data if required to do so by law (including responding to a subpoena or request from law enforcement, court, or government agency or other public authorities) or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect or defend our rights, interests, or property or that of other customers or users, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability or potential fraud, as determined in our sole discretion.

5.7 With Your Consent

We may disclose your information for other purposes with your explicit consent.

6. International Data Transfers

We are based in the United States, and we and our service providers may process personal information in the United States and other countries. Sharing of information sometimes involves cross-border data transfers to the United States and other jurisdictions. WOTR may also subcontract processing to, or share your personal data with, third parties located in countries other than your home country or your country of residence. Your personal data, therefore, may be subject to privacy laws that are different from those in your country of residence.

Where our Services are available to users in the European Economic Area (“EEA”), UK, or Switzerland, and when we transfer their personal data to countries outside of these regions as processors, we do so in accordance with applicable privacy laws. This includes implementing appropriate contractual, technical, and organizational measures as outlined in the Standard Contractual Clauses approved by the EU Commission. Standard Contractual Clauses are commitments between companies transferring personal data, ensuring they protect your data’s privacy and security.

7. Data Retention

We retain personal data only as long as reasonably necessary to fulfill the purposes described in this Privacy Policy. Retention periods may vary based on:

• Whether you have an active membership and need ongoing access to member benefits;
• Transaction and accounting needs for processing subscriptions and purchases;
• The need to comply with legal obligations and enforce agreements;
• Security and fraud monitoring requirements.

Retention periods may be extended where required by law or for legitimate governance purposes.

8. Your Privacy Rights

8.1 Rights for All Users

Depending on where you live and subject to legal exceptions, you may have rights to:

1. Access. Request confirmation of whether we process your personal information and access to such information.
2. Correction. Request correction of inaccurate personal information.
3. Deletion. Request deletion of your personal information, subject to legal exceptions.
4. Opt-Out of Marketing. Unsubscribe or opt-out from communications such as marketing emails by using the link in emails or adjusting account settings.
5. Right to Limit Use of Sensitive Personal Information. Limit our use and disclosure of sensitive personal information to permitted purposes.
6. Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

8.2 United States Privacy Rights

If you are located in the United States, this Privacy Policy explains how we collect, use, and disclose your personal information under applicable state privacy laws. While we disclose personal information to service providers for the business purposes described in Section 5, we do not “sell” your personal information. We do not collect “sensitive” personal information for purposes that would trigger additional consent requirements or a “Right to Limit” under applicable state laws, as our collection is limited to necessary business purposes.

8.3 California-Specific Notice (CCPA/CPRA)

California residents have the following additional rights:

1. Right to Know. Request disclosure of the personal information we have collected about you, including the categories of personal information, the purposes for collection and use, and any third parties to whom the information has been disclosed.
2. Right to Delete. Request deletion of personal information we have collected from you, subject to certain exceptions (e.g., completing transactions, detecting security incidents, complying with legal obligations, internal uses reasonably aligned with your expectations).
3. Right to Correct. Request correction of inaccurate personal information we maintain about you.
4. Right to Opt-Out. Opt out of the sale or sharing of personal information. As stated above, we do not sell personal information.
5. Right to Limit Use of Sensitive Personal Information. Limit our use and disclosure of sensitive personal information to permitted purposes.
6. Right to Non-Discrimination. We will not discriminate against you for exercising your CCPA/CPRA rights.

8.4 Response Time and Verification

We will confirm receipt within 10 business days and respond within 45 days (extendable by 45 days with notice). We will verify your identity before fulfilling your requests by comparing the information you provide with the information we have on file.

8.5 EEA, Switzerland, and UK Residents (GDPR/UK GDPR)

If you are located in countries that are within the European Economic Area (the “EEA”), Switzerland, or the UK, GDPR and its Swiss and UK GDPR counterparts provide you rights with respect to your personal data, subject to any exemptions provided by the law, including the following rights:

1. Right to Access. Request access to your personal data.
2. Right to Correction. Request correction or deletion of your personal data.
3. Right to Limit Use. Request that we limit our use and processing of your personal data.
4. Right to Data Portability. Request portability of your personal data.
5. Right to Withdraw Consent. Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
6. Right to Object. You have the right to object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
7. Right to Lodge a Complaint. Users located in EEA, United Kingdom, or Switzerland have the right to make a complaint to a government supervisory authority.

8.6 How to Exercise Your Privacy Rights

To submit a privacy rights request, please contact us at:

• Email: privacy@warontherocks.com
• Subject Line: “Privacy Rights Request – [Type of Request]”
• Include: Your name, the email address associated with your account (if applicable), a description of your request, and your state of residence.

We may take reasonable steps to verify your identity before processing any request, and we will respond within the timeframes required by applicable law.

Privacy Contacts

Data Protection Officer (GDPR / UK GDPR): privacy@warontherocks.com

Supervisory Authorities

United Kingdom: Information Commissioner’s Office (ICO)

European Economic Area: A list of EEA supervisory authorities is available at https://edpb.europa.eu/about-edpb/board/members_en.

8.7 Categories of Personal Information Collected (Last 12 Months)

8.8 No Sale or Sharing

We do not sell personal information. We have not sold personal information in the preceding 12 months. We do not share personal information for cross-context behavioral advertising purposes.

9. Cookies and Tracking Technologies

We use cookies, pixels, tags, analytics tools, and similar tracking technologies to operate and secure our website, remember your preferences, understand how visitors interact with our Services, improve performance, and support advertising or marketing activities where permitted by law.

We use TrustArc to help manage our cookie banner and consent management platform. When you visit our website, you may be presented with a cookie banner or preference center that allows you to review additional information about the categories of cookies and similar technologies used on our website and, where applicable, manage your preferences. You can update your cookie preferences at any time through the cookie settings link or preference center available on our website.

Some cookies are necessary for the website to function and cannot be disabled through our preference center. Other cookies, such as analytics or advertising cookies, may be disabled or managed through the TrustArc preference center, depending on your location and applicable law. You may also be able to control cookies through your browser settings, but disabling cookies may affect the functionality or availability of certain features of the Services.

We may update the cookies and similar technologies used on our website from time to time. The TrustArc preference center is intended to provide more current and detailed information about the specific cookie categories and preference options available to you.

For users located in the European Economic Area and the United Kingdom, we comply with applicable requirements under the GDPR and the ePrivacy Directive. Except for strictly necessary cookies, we obtain your prior consent before placing cookies or accessing information stored on your device.

10. Security Measures

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. These measures are calibrated to the nature, scope, context, and purposes of processing, as well as the risks posed to individuals’ rights and freedoms. Our safeguards may include encryption, access controls, secure infrastructure, incident response procedures, and regular evaluation of our security practices. You are responsible for maintaining the confidentiality of your account credentials and for any activity conducted under your account.

11. Children’s Privacy

Our services are intended for a general audience and are not designed for or meant to be used by children. We do not knowingly collect information from children under 13 without parental permission. If a parent or guardian learns that their child has provided us with information without their consent, they should contact us at privacy@warontherocks.com as soon as possible. We will delete such information from our records within a reasonable time. For users in the EU/UK, our services are not intended for children under 16. We comply with the Children’s Online Privacy Protection Act (COPPA) and do not knowingly collect personal information from children under the applicable age.

12. Third-Party Links and Services

Users can follow WOTR on Facebook, Instagram, X (formerly Twitter), LinkedIn, Bluesky, and other social media platforms as they become available. Users should review the privacy policies for each platform to understand what information is collected. We may provide links to third-party websites, apps, and services. This Privacy Policy does not cover the activities of third parties when they collect or use data for their own purposes. We are not responsible for the privacy practices or content of third-party services. We recommend reviewing their privacy policies before sharing your information.

13. Data Breach Notification

In the event of a personal data breach, we will:

• Notify Affected Individuals. If a breach is reasonably likely to result in a risk to your rights and freedoms (GDPR/UK GDPR) or requires notification under applicable law (e.g., California Civil Code § 1798.82), we will notify affected individuals without undue delay, and where feasible, within 72 hours of becoming aware of the breach.
• Notify Supervisory Authorities. For GDPR/UK GDPR compliance, we will notify the relevant supervisory authority within 72 hours of becoming aware of a breach that poses a risk to individuals’ rights and freedoms, unless the breach is unlikely to result in such risk.
• Notify California Attorney General. For breaches affecting more than 500 California residents, we will notify the California Attorney General as required by California Civil Code § 1798.82.

14. Changes to This Privacy Policy

If WOTR makes material changes to its Privacy Policy, it will notify you by: (i) updating the Last Updated Date at the top of the Privacy Policy, (ii) sending an email to its users, and/or (iii) adding a notice to the Site. Material changes include new categories of personal information collected, new purposes for processing, new categories of third parties with whom we share information, or substantial changes to your rights. Your continued use of the Services after notice indicates acceptance of the updated policy.

15. Contact Information

If you have any questions regarding privacy while using our Services or about our practices, please contact via the following:

For General Inquiries

Email: privacy@warontherocks.com

Data Protection Officer

Email: privacy@warontherocks.com