What We Collect.
What We Don't.

primalkodex.com, the email list and The Primal Table cohort are run by Spencer James Dearing, an individual in Nanaimo, British Columbia, Canada, doing business as The Primal Kodex. "We" and "us" in this policy mean him.

Spencer is personally responsible for how personal information is handled here. How to reach him is in section 17.

This policy follows British Columbia's Personal Information Protection Act (PIPA). Where federal law applies, it also follows the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).

It covers the website, the email list, and every part of The Primal Table: the application, payment, calls, journals and group chat.

Your email address, and your first name if you choose to give it, when you sign up for the newsletter or The Subtraction Kodex.

Whether you confirmed, opened, clicked or unsubscribed, and which form you used. Kit records this automatically.

Visit statistics. Google Analytics records which pages are viewed, roughly where visitors are (city level at most), device and browser type, how they arrived, and actions such as clicking a link or signing up. We read it in aggregate. It is never linked to your email address or your application, and Google's advertising features are switched off.

Standard server logs kept by our web host: IP address, browser type, pages requested. Your IP address also reaches Google when the site's typefaces load.

Anything you write to us by email.

Contact details: your email address, name, and city and time zone, and which seat you are applying for.

Health information. The application asks what you want to be different in nine weeks, what you have already tried with food and what happened, what you are most afraid of, and whether you are under a doctor's care or taking medication where a significant change in diet could matter. Your answers can include health information, so all of them are treated as if they do.

Four baseline scores you give yourself at intake (Ancestral Nutrition, Stillness, Journaling, Gut Health), and the same four at your exit call. The guarantee is measured against them.

Call notes and your personal map from your private intake and exit calls.

Journal entries you submit during the nine weeks.

Payment details: your name, email, billing country and postal code, what you paid and when, and your card's brand and last four digits. Stripe collects the full card number. We never see it and never store it.

Founding seats only: the written testimonial and the recorded exit interview you agree to in the Participant Agreement.

Full card numbers, government ID, passwords, or social media logins.

Email address: to send what you signed up for, and to answer you when you write.

Health information: for three reasons and no others. To decide, before you pay, whether The Primal Table is right for you and appropriate for you. To build your personal map at intake. To measure your guarantee at the exit call.

Payment details: to take payment, send receipts, charge the second payment on a payment plan, process any refund, and keep the records tax law requires.

Visit statistics: to see which pages help readers and which do not, and whether signups and applications are working.

Server logs: to keep the site secure and running.

If we ever want to use your information for anything not listed here, we ask you first.

Email is double opt-in. You enter your address, then confirm it from your inbox. Nothing is sent until you do. That is express consent under CASL.

Applying is express consent to collect and use the health information in your application for the three purposes in clause 3.2. The application links to this policy before you start.

Applying does not add you to the email list. If you want the newsletter, sign up for it separately.

You can withdraw consent at any time. Unsubscribe with the link in any email. To withdraw an application or have your health information removed, email us (section 13).

If you withdraw consent during a run, parts of the program may no longer be possible, including measuring your guarantee. We will tell you exactly what changes before acting on it.

Using the site means you accept the visit statistics in clause 2.3. You can block them at any time, as set out in section 9.

Where it lives. Google Forms writes each application to a Google Sheet in The Primal Kodex's Google Workspace account. Call notes, personal maps, scores and journal entries are kept in Google Docs and Sheets in the same account.

Who sees it. Spencer, and nobody else. It is not shared with other participants, pod stewards, guest speakers, designers or anyone else.

How it is protected. The account is protected by a strong password and two-factor sign-in. Application responses are never shared by link or with any other account.

What never happens to it. It is never sold, never used for advertising, never added to the email list, never linked to site analytics and never published.

Testimonials. Your name, words, scores and story are never published without your clear written permission.

What it is not. The Primal Kodex is not a health care provider, and your application is not a medical record. It is still treated as the most sensitive information held here.

The Primal Table is a group. On group calls and in the group chat, the men in your cohort see and hear what you choose to share, along with your name, and your face on video calls.

The cohort group chat runs on WhatsApp, which shows your phone number and profile to everyone in the group.

Every participant agrees to keep what is shared in the group confidential. The terms of that sit in the Participant Agreement. We can require it. We cannot guarantee what another man does, so share what you are comfortable sharing.

If a call is ever recorded, everyone on it is told before recording starts.

Your information is never sold, rented or traded. It is handled only by the services the site and the cohort need to run:

Their policies: Kit · Google · Stripe · Substack · WhatsApp · SiteGround

We disclose information to anyone else only when the law requires it, such as a valid court order, or to protect someone's safety.

Most of these services are based in the United States, so your information, including health information in your application, may be stored and processed there.

While it is outside Canada it is subject to that country's laws, which can include access by courts, law enforcement and national security authorities.

We want you to know this before you apply, not after. If it is a dealbreaker, tell us before you submit anything and we will talk it through.

Google Analytics sets cookies (named _ga and similar) so it can tell a returning visitor from a new one.

Kit's signup form may set a cookie so it can recognise a returning subscriber.

Stripe's checkout sets cookies needed to take payment safely and prevent fraud.

There are no advertising pixels, retargeting scripts or social media trackers on this site.

You can block or delete cookies in your browser, or install Google's Analytics opt-out add-on. The site works the same either way.

Once you leave primalkodex.com, the other site's privacy policy applies, not this one.

Some links are affiliate links, always labelled where they appear. If you click one, that company may record that you came from The Primal Kodex. We see that a sale happened and its value. We never see your name, contact details or payment details.

Subscribers: while you stay subscribed. After you unsubscribe, Kit keeps your address on a do-not-send list so you are never emailed by accident. Ask and it is deleted entirely.

Applications that do not go ahead: one year after the decision, then deleted. BC law requires information used to make a decision about you to be kept for at least one year, so you can ask to see it.

Participants: your application, scores, call notes, personal map and journal entries are kept for one year after your run ends, then deleted.

Payment records: six years, because the Canada Revenue Agency requires business records to be kept that long. They never include your card number.

Testimonials and recordings: kept and used only as you agreed in writing. You can ask us to stop any future use.

Email you send us: as long as it is useful to the conversation.

Visit statistics: kept in Google Analytics for no longer than 14 months, then deleted automatically.

You can ask for earlier deletion of anything except the payment records the law requires us to keep.

The site runs over HTTPS. Every account that holds your information is protected by a strong password and two-factor sign-in, and access is limited to Spencer.

Our email domain is authenticated with SPF, DKIM and DMARC, which makes it much harder for anyone to send mail pretending to be us.

No system is perfectly secure. If a breach of your information creates a real risk of significant harm to you, we will tell you promptly and report it to the privacy regulator where the law requires.

You can ask to see the personal information we hold about you, how it has been used, and who it has been shared with.

You can ask us to correct anything inaccurate or incomplete.

You can ask for a copy. You get it as a file you can keep.

You can ask us to delete it, subject to clause 11.8.

You can withdraw consent at any time, as set out in section 4.

To do any of this, email spencer@primalkodex.com. We may ask you to confirm the request comes from you, which protects you from someone else asking. There is no charge. You get a response within 30 days.

If you are in the European Economic Area or the United Kingdom, the GDPR or UK GDPR gives you the rights in section 13, plus the right to data portability and to object to processing.

Our legal basis is your consent for email and for the health information in an application, the contract between us for payment and delivering the cohort, and our legitimate interest in a secure, working website for server logs and visit statistics.

You can also complain to your local data protection authority.

The Primal Kodex is written for adults. It is not directed at anyone under 18, and The Primal Table accepts adults only.

If you believe someone under 18 has given us information, tell us and it will be deleted.

When this policy changes, the date at the top changes with it.

If a change affects how your information is used in a meaningful way, subscribers and current participants are told by email before it takes effect.

A change never takes away a right you already have without asking you.

Privacy contact: Spencer James Dearing, The Primal Kodex, Nanaimo, British Columbia, Canada. spencer@primalkodex.com

Bring any concern here first. Most things get fixed in one reply.

If you are not satisfied, you can complain to the Office of the Information and Privacy Commissioner for British Columbia at oipc.bc.ca. Where federal law applies, the Office of the Privacy Commissioner of Canada is at priv.gc.ca.