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GRAY MATTER EDITS

Privacy Policy

Your words, your information, your trust. Here's how we protect them.

Last updated: 21 October 2026

At Gray Matter Edits, privacy and confidentiality are fundamental to the relationship between an editor and a client. Whether you are sharing an academic manuscript, an unpublished novel, a personal story, or a simple enquiry, your information deserves careful handling.

This Privacy Policy explains what personal data Gray Matter Edits collects, why it is processed, how it is protected, when it may be shared, and the rights you have over your information.

We aim to collect only what is necessary, use it responsibly, and respect the confidentiality of your work.

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SECTION 01

Who We Are

Gray Matter Edits is an independent editorial, writing, and creative-development business operated by Jodie Gray, based in Sauvo, Finland, and serving clients internationally.

The business operates under the Gray Matter Edits name, including its fiction-services identity, The Writer's Spellbook.

For personal data processed in connection with the business's own website, enquiries, administration, and direct client relationships, Jodie Gray, trading as Gray Matter Edits, is the data controller.

DATA CONTROLLER

Gray Matter Edits

Jodie Gray
Urheilukentätie 8
Sauvo 21570
Finland

Business ID: 3554010-3
Email: jodie@graymatteredits.com

In certain commissioned projects, particularly those involving information supplied by universities, organisations, or other professional clients, the allocation of data-controller and data-processor responsibilities may differ.

Where required, these responsibilities will be addressed in the relevant project agreement or data-processing arrangement.

SECTION 02

Scope of This Policy

This policy applies to personal information processed through Gray Matter Edits' business activities, including:

  • Visiting and interacting with this website
  • Submitting enquiries or requesting quotations
  • Communicating by email or contact forms
  • Commissioning editorial or writing services
  • Submitting manuscripts or project materials
  • Purchasing digital products where available
  • Managing invoices, payments, and contracts
  • Providing testimonials or other voluntary feedback

The policy covers both academic and fiction-related services.

It should be read alongside our Terms of Service , which govern the contractual relationship between Gray Matter Edits and its clients.

This policy is prepared with reference to the EU General Data Protection Regulation (GDPR), the Finnish Data Protection Act, and other applicable privacy and electronic-communications requirements.

SECTION 03

Personal Information We Collect

The information processed depends on how you interact with Gray Matter Edits.

Contact and identification information

This may include:

  • Your name and email address
  • Your business, institution, or professional affiliation
  • Postal or billing address, where necessary
  • Telephone number, if provided or required for a transaction

Project and service information

This may include:

  • Manuscripts, research documents, story outlines, and creative briefs
  • Project instructions, preferences, and requested deadlines
  • Style guides, reference lists, planning documents, and research materials
  • Editorial correspondence, feedback, comments, and revision requests
  • Relevant contractual records and project histories

Transaction information

Where you purchase a service or product, information may include invoice details, amounts charged, payment status, transaction references, and records necessary for financial administration.

Complete payment-card details are ordinarily handled by the relevant payment provider rather than sent directly to Gray Matter Edits.

Website and technical information

When you visit the website, the hosting platform and any enabled analytics services may process technical information such as:

  • IP address and approximate location
  • Browser type and device information
  • Pages visited and referral sources
  • Session information and cookie preferences
  • Technical information required for security and site operation

The precise information collected depends on the website's enabled features, analytics configuration, and your consent choices.

Information received from others

In some cases, a client or prospective client may be referred by another editor, colleague, organisation, or freelance platform.

Information received may include contact details, professional affiliation, project requirements, and other details supplied in connection with the referral.

Where required by data-protection law, individuals will be given appropriate information about the source and use of their personal data.

SECTION 04

How and Why We Use Personal Data

Personal data is processed only where there is an appropriate legal basis under the GDPR or other applicable law.

Responding to enquiries and quotations

To respond to questions, assess service suitability, prepare quotations, and discuss prospective projects.

Legal basis: Steps requested before entering into a contract, or legitimate interests in handling general correspondence.

Providing commissioned services

To communicate with clients, review and process supplied materials, perform agreed editorial or writing work, deliver completed projects, and manage revisions.

Legal basis: Performance of a contract or steps necessary before concluding one. Where a business client supplies information about other individuals, additional legal bases may apply.

Invoices, payments, and accounting

To issue invoices, record transactions, administer payments, and meet legal, tax, and accounting obligations.

Legal basis: Performance of a contract and compliance with legal obligations.

Business administration and security

To maintain accurate business records, manage projects, respond to disputes, protect confidential materials, and prevent misuse of the website and associated systems.

Legal basis: Legitimate interests in operating and protecting the business, or compliance with legal obligations.

Website analytics

Where enabled, analytics may help understand visitor activity, website performance, and the effectiveness of its content.

Legal basis: Consent where required for non-essential cookies or similar tracking technologies, together with an applicable GDPR processing basis.

Marketing and updates

If marketing communications are offered, contact information may be used to send updates where valid permission or another applicable legal basis exists.

Legal basis: Consent or another lawful basis permitted by applicable direct-marketing rules.

Information needed to provide services

Certain details, such as contact information and the materials needed to perform a commissioned service, are necessary to enter into or fulfil a contract.

If required information is not provided, Gray Matter Edits may be unable to prepare an accurate quotation or complete the requested service.

Information requested for optional activities, including consent-based marketing, is not a condition of purchasing editorial services.

SECTION 05

Manuscripts, Research and Sensitive Information

Editorial and creative-development work can involve information considerably more personal than an ordinary commercial transaction.

Manuscripts and supporting materials may contain unpublished creative work, identifiable individuals, private correspondence, personal experiences, or sensitive research information.

Academic and research materials

Academic manuscripts may contain research-participant information, interview extracts, case studies, or material subject to institutional confidentiality or research-ethics requirements.

Clients should anonymise or pseudonymise personal data wherever reasonably possible, particularly where identifiable information is not necessary for the agreed editorial work.

Where identifiable research data is necessary, the client and Gray Matter Edits should establish appropriate instructions, responsibilities, and safeguards before the material is transferred.

Autobiographical and personal writing

Ghostwriting and fictionalised-life-story commissions may involve personal memories, relationships, family histories, correspondence, photographs, or information about other individuals.

Such material is treated as confidential project information and used for the agreed service or another lawful purpose.

Special categories of personal data

Certain personal information, including information concerning health, racial or ethnic origin, religious beliefs, political opinions, and sexual orientation, receives additional protection under the GDPR.

Where processing these categories is necessary, an applicable legal basis and an additional condition under Article 9 of the GDPR must be established.

Depending on the circumstances, this may require explicit consent from the relevant individual or another legally available condition.

A note on sharing sensitive material

Please avoid including unnecessary personal identifiers, confidential research data, or sensitive information about third parties in an initial enquiry. If your project requires special handling, this can be discussed before materials are submitted.

AI-assisted and external processing tools

Where external text-analysis, language-assistance, or generative AI tools are used in a project, their use must comply with applicable confidentiality arrangements, data-protection requirements, and the agreed project scope.

Any proposed processing of identifiable or confidential client material through an external service must be assessed for an appropriate legal basis, contractual safeguards, and any required authorisation.

Clients may raise particular confidentiality or AI-processing requirements before commissioning work.

SECTION 06

Enquiries, Forms and Communication

Contact forms and quotation requests

Information submitted through website forms is used to respond to the request, consider project requirements, prepare quotations, and arrange potential services.

Form information may be processed through the website platform and associated communication or administrative services.

Email correspondence

Business email communications are managed through Google Workspace. Correspondence may be retained where necessary for ongoing projects, administration, contractual records, or legitimate follow-up.

Freelance-platform communication

Where clients communicate or contract through Upwork or another freelance platform, personal data may also be processed under that platform's independent privacy arrangements.

Gray Matter Edits processes the information it receives through those platforms for the purposes of managing enquiries, contracts, project delivery, and payments.

Unsolicited material

Please do not submit full manuscripts, confidential records, or other extensive personal data through a general enquiry unless the material has been requested or an appropriate transfer arrangement has been agreed.

SECTION 07

Cookies, Analytics and Website Technology

This website is built using Squarespace, which uses cookies and similar technologies to support website operation, security, visitor preferences, and certain optional features.

Cookies are small pieces of information stored on or accessed through your device when you visit a website.

Essential cookies

Essential cookies support functions required to operate the website and provide services specifically requested by visitors.

These may include security functions, session management, form functionality, and remembering cookie preferences.

Where a cookie is strictly necessary under applicable law, separate consent is not required.

Analytics and performance cookies

Where enabled, Squarespace analytics cookies can help measure website visits, understand traffic sources, and analyse visitor interactions.

Squarespace documents the following analytics cookies, which may be applicable if those features are enabled and consented to:

These are Squarespace's documented analytics cookies, not confirmation that every cookie listed is active on this website. The final cookie inventory must reflect the site's actual configuration.

Third-party cookies and integrations

Additional cookies or similar tracking technologies may be used where third-party services are integrated into the website, including optional media, analytics, payment, or marketing features.

Such technologies must be disclosed and, where legally required, activated only after appropriate consent.

Managing your cookie choices

Visitors must be able to accept or reject non-essential cookies through the website's consent controls.

Consent for non-essential cookies is voluntary and can be withdrawn or changed using the website's cookie-preferences controls.

Refusing optional cookies should not prevent access to ordinary website content, although some optional features may be unavailable.

You may also manage or delete cookies through your browser settings. Browser controls do not replace any consent mechanism legally required on the website.

Further technical information about Squarespace's cookies is available in its cookie documentation .

SECTION 08

Payments, Purchases and Digital Products

Commissioned services

Payment and billing information is processed to administer contracts, issue invoices, maintain transaction records, and comply with financial reporting obligations.

Depending on the agreed payment method, a bank, freelance platform, or payment service provider may process transaction information.

Those providers may act as independent data controllers for parts of their payment and compliance operations.

Digital products

Where digital resources, templates, courses, or other products are available for purchase, information necessary to process the transaction and provide the purchased content may be collected.

Such information may include purchaser contact details, order details, billing information, and access or delivery records.

Any additional platform used for digital product delivery will need to be reflected in this policy where it processes customers' personal data.

Financial record-keeping

Transaction records may be retained for the periods required by Finnish accounting and tax law, even where other information associated with a completed project has been deleted.

SECTION 09

Marketing, Updates and Testimonials

Marketing communications

If Gray Matter Edits offers email newsletters, service updates, or promotional communications, these will be sent only where permitted by applicable law.

Where consent is required, it will be requested separately and will not be assumed merely because someone submits an enquiry or purchases a service.

Recipients may withdraw consent or object to direct marketing at any time, including through an unsubscribe mechanism where provided.

Withdrawal will not affect the lawfulness of processing that occurred before consent was withdrawn.

Service correspondence

Administrative messages concerning enquiries, quotations, contracts, deadlines, invoices, and project delivery are not treated as optional marketing.

Testimonials and portfolio examples

Testimonials, identifiable client feedback, manuscript excerpts, and project case studies may be published with appropriate permission or another applicable legal basis.

Unpublished client manuscripts and confidential creative materials are not made publicly available merely because editorial services have been provided.

Permission may be withdrawn where applicable, subject to lawful limits and any rights already exercised.

SECTION 10

Sharing Information and Service Providers

Gray Matter Edits does not sell personal information to data brokers or advertisers.

Personal data may be made available to service providers or other recipients where necessary for the purposes described in this policy.

Website and communications

Squarespace provides website-hosting and website-management functionality.

Google Workspace is used for business email and associated communications.

Project management and professional tools

Editing, document-processing, reference-management, storage, and administrative software may be used to produce and manage agreed deliverables.

Where a tool receives personal data, its use must be appropriate for the information involved and supported by relevant safeguards.

Freelance and payment platforms

Upwork or other platforms may process information for contracts, communications, identity checks, transaction handling, or platform administration.

Banks and payment processors may receive the information necessary to complete payments.

Professional and legal obligations

Information may be disclosed where necessary to accountants, professional advisers, public authorities, or other authorised recipients, subject to applicable legal requirements and confidentiality obligations.

Confidentiality and access

Access to personal data is limited to persons and providers who require it for a legitimate business or legal purpose.

Appropriate contractual protections, including data-processing agreements, are used where required.

Personal data is not shared with unrelated third parties for their independent advertising purposes without an appropriate legal basis.

SECTION 11

International Data Transfers

Gray Matter Edits operates from Finland and serves clients in different countries.

Some website, email, payment, and professional service providers may store, access, or otherwise process personal information outside the European Economic Area (EEA).

Where personal data is transferred to a country outside the EEA, the transfer must be supported by an appropriate legal mechanism under the GDPR.

Depending on the recipient and destination, safeguards may include:

  • An applicable European Commission adequacy decision
  • The EU-US Data Privacy Framework, where the recipient is eligible and certified
  • European Commission Standard Contractual Clauses, with supplementary measures where required
  • Another lawful transfer mechanism where applicable

Information about the relevant transfer safeguards, including how to obtain further details or a copy where applicable, may be requested using the contact details below.

The safeguards used for any particular service depend on that provider's current arrangements and the processing involved.

SECTION 12

How Long We Keep Information

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, or for another lawful purpose.

Retention periods depend on the nature of the information, ongoing contractual requirements, relevant limitation periods, and applicable legal obligations.

General enquiries

Enquiries that do not result in a commission are retained for up to 12 months after the last relevant contact, unless a longer period is necessary for an identified lawful purpose.

Client and project records

Contractual records and project correspondence may be retained where necessary to administer the client relationship, document agreed work, respond to subsequent queries, or resolve disputes.

Manuscripts and working files

Manuscripts, annotations, working documents, and completed deliverables are normally retained for 12 months after final delivery, unless an alternative arrangement is agreed or a longer period is lawfully required.

Files may be deleted earlier where appropriate, including following a valid request and where no conflicting legal or contractual obligation requires further retention.

Financial and accounting records

Records subject to Finnish accounting requirements are retained for the applicable statutory periods.

These may include retention of supporting accounting documents for at least six years and certain core accounting records for at least ten years, depending on the record type.

Marketing information

Where marketing subscriptions are offered, relevant information is retained while the subscription remains valid and as necessary to document or honour unsubscribe and consent choices.

Deletion and anonymisation

When information is no longer needed and no lawful retention requirement remains, it will be deleted or anonymised using appropriate methods.

Information held in routine system backups may remain until the relevant backup expires under the provider's retention arrangements.

SECTION 13

Data Security and Confidentiality

Reasonable technical and organisational measures are used to protect personal information from unauthorised access, accidental loss, alteration, or disclosure.

Such measures may include appropriate access controls, account security, secure communication methods, software maintenance, and responsible handling of project files.

Confidential editorial work

Client manuscripts, research, unpublished ideas, and personal creative materials are treated as confidential.

Project materials are used for the agreed purpose and disclosed only where authorised or otherwise legally permitted.

Non-disclosure agreements

Additional confidentiality arrangements, including non-disclosure agreements, may be agreed where suitable for the project.

Security limitations

No method of internet transmission or electronic storage can be guaranteed completely secure.

If a personal-data breach occurs, Gray Matter Edits will assess the incident and make any notifications required by applicable data-protection law.

Clients should communicate any exceptional security requirements before transferring especially sensitive materials.

SECTION 14

Your Data Protection Rights

Under the GDPR, individuals have rights in relation to their personal data. The rights available in a particular situation depend on the relevant processing and legal basis.

01

Right of access

Request confirmation of whether personal data is being processed and receive access to that information where applicable.

02

Right to rectification

Request correction of inaccurate or incomplete personal data.

03

Right to erasure

Request deletion of personal information where the legal conditions for erasure are met.

04

Right to restrict processing

Request that processing is limited in certain circumstances.

05

Right to data portability

Receive eligible personal data in a structured, commonly used, machine-readable format and request its transmission where legally applicable.

06

Right to object

Object to processing based on legitimate interests where applicable, and object to direct marketing.

07

Right to withdraw consent

Withdraw consent at any time where processing relies on that consent, without affecting prior lawful processing.

08

Automated decision-making rights

Exercise applicable rights in relation to qualifying solely automated decisions with legal or similarly significant effects.

Automated decision-making

Gray Matter Edits does not ordinarily use solely automated decision-making or profiling that produces legal or similarly significant effects on clients.

Making a request

To exercise a data-protection right, email jodie@graymatteredits.com with a description of your request.

Reasonable information may be requested to verify your identity before disclosing or modifying personal data.

Requests will be addressed without undue delay and normally within one month, subject to extensions permitted by law where necessary.

Requests are generally handled without charge, except where applicable law permits a fee or refusal in particular circumstances.

Deletion requests and legal obligations

A request to delete personal information does not always require immediate deletion of every associated record. Information may need to be retained where legally required, including for accounting or the establishment, exercise, or defence of legal claims.

SECTION 15

Children and Information About Other People

Children's personal information

Gray Matter Edits' website and services are primarily intended for adult clients and professional users.

The business does not intentionally solicit personal information directly from children for independent marketing purposes.

Some commissioned projects may nevertheless contain information about children or young people, particularly within autobiographical materials, family histories, or research documents.

Such information must be handled in accordance with applicable data-protection requirements and any additional safeguards appropriate to the circumstances.

Third-party personal information

Clients should ensure that they have an appropriate legal basis and authority to provide personal information relating to other individuals.

Where possible, identifying information should be removed if it is not necessary for the commissioned work.

Additional arrangements may be necessary for projects involving substantial amounts of identifiable personal data.

SECTION 16

External Services and Policy Updates

External websites

This website may contain links to external websites, freelance platforms, payment services, or other third-party resources.

Those organisations may operate under their own privacy policies and data-processing arrangements.

Visitors are encouraged to review the privacy information provided by external services before submitting personal data.

Changes to this policy

This Privacy Policy may be updated to reflect changes in business practices, website functionality, service providers, or legal requirements.

The latest version will be published on this page, together with its most recent update date.

Where a change requires further notice or new consent under applicable law, appropriate steps will be taken before the relevant processing begins.

SECTION 17

Contact and Privacy Complaints

If you have questions about how your personal information is handled, wish to exercise a data protection right, or have a concern about privacy, please contact Gray Matter Edits.

PRIVACY ENQUIRIES

Gray Matter Edits

Jodie Gray
Sauvo, Finland

jodie@graymatteredits.com

Please use "Privacy Enquiry" in the email subject line where possible.

Finnish supervisory authority

If you believe your personal data has been processed unlawfully, you have the right to lodge a complaint with a competent data-protection supervisory authority.

In Finland, the relevant supervisory authority is:

Office of the Data Protection Ombudsman

Finland

Visit the Data Protection Ombudsman's website ↗

Where applicable, individuals may also contact a supervisory authority in the country where they live or work, or where an alleged infringement occurred.

We welcome the opportunity to address privacy concerns directly, although doing so is not a condition of exercising your right to make a complaint.