Privacy Policy

Six Minutes Past Nine Ltd
Last updated: 12/02/2026

1. Who We Are

Six Minutes Past Nine Ltd (“we”, “us”, “our”) operates:

• sixminutespastnine.com
• Six Minutes Commons (currently hosted via Substack or successor platform)
• Studio Cycles and Labs (which may operate via Discord or other platforms)
• Associated project sites (including but not limited to plasticprognosticate.com)

For the purposes of UK data protection law, Six Minutes Past Nine Ltd is the data controller of personal data collected through our websites and activities, except where third-party platforms act as independent controllers (see Section 6).

Contact:
info@sixminutespastnine.com
United Kingdom

2. What Personal Data We Collect

Depending on how you engage with us, we may collect:

A. Information You Provide Directly

• Name
• Email address
• Billing information (via payment processor)
• Submission materials
• Application information for Studio Cycles or Labs
• Correspondence sent to us

B. Technical Data

• IP address
• Browser type and device information
• Basic usage analytics
• Cookies (see Section 8)

C. Programme Participation Data

If you participate in Studio Cycles or Labs:

• Attendance records
• Communication via Discord or other platforms
• Submitted project documentation
• Optional feedback

We do not intentionally collect special category data (e.g. health, ethnicity, political beliefs). Please do not submit such data unless strictly necessary and requested.

3. How We Use Your Data

We process personal data for the following purposes:

• To respond to enquiries
• To manage submissions to the Commons
• To administer Studio Cycles and Labs
• To process payments
• To maintain internal records
• To improve our website and communications
• To comply with legal obligations

We do not sell personal data.

4. Legal Bases for Processing (UK GDPR)

We rely on the following lawful bases:

• Consent – where you subscribe to mailing lists or opt in to communications
• Contract – where you purchase a product or participate in a paid programme
• Legitimate Interests – to operate and improve our platforms
• Legal Obligation – for accounting, taxation, or regulatory compliance

You may withdraw consent at any time where processing relies on consent.

5. Email Communications

If you subscribe to the Commons (via Substack or similar platform):

• Your email is processed by that platform under their privacy terms.
• We may access subscriber email data within that platform’s dashboard.
• You may unsubscribe at any time via the unsubscribe link.

We do not add individuals to mailing lists without consent.

6. Third-Party Platforms

We use third-party platforms to operate certain surfaces, including:

• Substack (Commons publishing)
• Discord (Studio Cycles communication)
• Payment processors
• Hosting providers
• Analytics providers

These providers may act as independent data controllers or data processors.

Your use of those platforms is governed by their own privacy policies. We encourage you to review them carefully.

We are not responsible for how third-party platforms process your data beyond our direct control.

7. Data Sharing

We may share personal data with:

• Accountants or professional advisors
• Payment processors
• Hosting and IT providers
• Legal authorities if required

We do not sell or rent personal data to third parties.

8. Cookies and Analytics

Our websites may use:

• Essential cookies (required for site function)
• Analytics cookies (to understand traffic and usage patterns)

You can control cookie settings through your browser.

If we use third-party analytics tools, those providers may collect anonymised usage data.

9. Data Retention

We retain personal data only as long as necessary:

• Subscriber data – until you unsubscribe
• Programme application data – up to 24 months unless legally required longer
• Financial records – as required by UK law (typically 6 years)
• Correspondence – as needed for operational continuity

You may request deletion where applicable (see Section 11).

10. Data Security

We take reasonable technical and organisational measures to protect personal data, including:

• Secure hosting
• Restricted administrative access
• Encrypted payment processing via third-party providers

However, no system can guarantee absolute security.

11. Your Rights (UK GDPR)

You have the right to:

• Access your personal data
• Request correction
• Request deletion
• Restrict processing
• Object to processing based on legitimate interests
• Request data portability (where applicable)
• Lodge a complaint with the Information Commissioner’s Office (ICO)

ICO website: https://ico.org.uk

To exercise your rights, contact:
info@sixminutespastnine.com

12. International Transfers

Some third-party providers (e.g. Substack or Discord) may process data outside the UK.

Where applicable, transfers rely on:

• Adequacy regulations
• Standard contractual clauses
• Other lawful safeguards

13. Children

Our platforms are not directed at children under 18.

We do not knowingly collect data from minors.

14. Changes to This Policy

We may update this Privacy Policy periodically.

The most current version will always be published on our website.

Continued use of our platforms constitutes acceptance of any changes.

15. Contact

For privacy-related questions:

info@sixminutespastnine.com
Six Minutes Past Nine Ltd
United Kingdom