Privacy Policy

1. Data Controller

The data controller responsible for processing your personal data is:

Felix Zinsmeyer
Gerhart Hauptmann Ring 9, 16F
81737 Munich, Germany
Email: info@zinscapital.com

2. Data We Collect

We may collect the following categories of personal data:

• ›Contact data: Name, email address, phone number, organisation — when you submit the contact form or subscribe.
• ›Account data: Name, email, encrypted password — when you register for the Macro Terminal.
• ›Usage data: IP address, browser type, pages visited, time spent — collected automatically via server logs.
• ›Communication data: Content of messages, enquiries, or emails you send to us.
• ›Financial context data: Investment objectives, approximate asset size — provided voluntarily during client onboarding discussions.

3. Legal Basis for Processing

We process your personal data on the following legal bases (Art. 6 GDPR):

• ›Consent (Art. 6(1)(a)): When you voluntarily provide data via forms or subscribe to our newsletter.
• ›Contract performance (Art. 6(1)(b)): When processing is necessary to provide services you have requested.
• ›Legal obligation (Art. 6(1)(c)): Where processing is required by applicable law.
• ›Legitimate interests (Art. 6(1)(f)): For website security, fraud prevention, and service improvement.

4. How We Use Your Data

• ›Responding to enquiries and providing requested services
• ›Operating and improving the Zinscapital Macro Terminal
• ›Sending research newsletters and updates (with consent)
• ›Processing course enrolments and managing subscriptions
• ›Ensuring website security and preventing misuse
• ›Complying with legal and regulatory obligations

5. Data Sharing and Transfers

We do not sell, rent, or trade your personal data. We may share data with:

• ›Hosting and infrastructure providers (servers located in the EU/EEA)
• ›Resend Inc. — transactional email delivery for contact form submissions (data processed under GDPR-compliant DPA)
• ›Stripe Inc. — payment processing for subscriptions (PCI-DSS compliant)
• ›Google LLC — anonymised analytics (only with your consent; data processed under Google's EU Standard Contractual Clauses)
• ›Legal or regulatory authorities — if required by law

All third-party processors are bound by data processing agreements in accordance with GDPR Art. 28.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• ›Contact form data: 2 years from last contact
• ›Account data: Duration of account + 1 year after deletion request
• ›Newsletter subscribers: Until unsubscription + 6 months
• ›Financial/client data: 7 years (statutory retention under commercial law)
• ›Server logs: 30 days (security purposes)

7. Your Rights Under GDPR

As a data subject, you have the following rights (Arts. 15–22 GDPR):

• ›Right of access (Art. 15): Obtain a copy of your personal data we hold.
• ›Right to rectification (Art. 16): Correct inaccurate or incomplete data.
• ›Right to erasure (Art. 17): Request deletion of your personal data ('right to be forgotten').
• ›Right to restriction (Art. 18): Restrict how we process your data.
• ›Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
• ›Right to object (Art. 21): Object to processing based on legitimate interests or for direct marketing.
• ›Right to withdraw consent: Withdraw consent at any time without affecting prior processing.

To exercise any of these rights, contact us at info@zinscapital.com. You also have the right to lodge a complaint with a supervisory authority (e.g., the German Federal Commissioner for Data Protection, BfDI).

8. Cookies and Consent

When you first visit this website, a cookie consent banner is displayed. No non-essential cookies are set before you have given explicit consent. Your choice is stored locally in your browser and can be changed at any time via the "Cookie Settings" link in the footer.

Categories of cookies we use:

• ›Essential cookies (always active): Required for the platform to function — session authentication, security tokens, and login state. Legal basis: Art. 6(1)(b) GDPR (contract performance) and Art. 6(1)(f) GDPR (legitimate interest).
• ›Analytics cookies (consent required): Anonymous usage statistics via Google Analytics 4. Helps us understand how the site is used. No personal data is sold or shared for advertising. Legal basis: Art. 6(1)(a) GDPR (consent). You may withdraw consent at any time.

We do not use advertising cookies, retargeting pixels, or any third-party tracking for marketing purposes. You may also disable cookies entirely via your browser settings, though this may affect platform functionality.

9. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. These include HTTPS encryption, access controls, and regular security reviews. However, no internet transmission is 100% secure, and we cannot guarantee absolute security.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top of this page reflects the most recent revision. We will notify registered users of material changes via email.

11. Contact

For privacy-related questions, requests, or complaints, contact our data protection contact:
Email: info@zinscapital.com
Address: Gerhart Hauptmann Ring 9, 16F, 81737 Munich, Germany