Privacy Policy

1. Controller

Lukas Köppl — EllTec Analysis, Kolpingstraße 24, 84030 Ergolding, Germany
Email: info@elltecanalysis.com
See the Legal Notice for full contact details.

2. Hosting and server log files

This website is hosted by Cloudflare, Inc. (San Francisco, USA). When it is accessed, Cloudflare, as our processor, automatically collects technical information the browser transmits (IP address, date and time of the request, page requested, referrer URL, browser type, among others). This data is used solely to operate the website securely and reliably (Art. 6(1)(f) GDPR) and is deleted automatically after a short period. The account database (Cloudflare D1) and the cache for content and translations (Cloudflare KV) are also hosted with Cloudflare. As a global network, Cloudflare processes requests at data centers distributed worldwide. A data processing agreement is in place with Cloudflare; transfers to the US may rely on the EU Standard Contractual Clauses.

3. Cookies

This website uses only strictly necessary cookies (Art. 6(1)(f) GDPR) — no tracking or marketing cookies:

• elltec_lang — stores the selected language (English/German).
• elltec_user_session — keeps a visitor with an account signed in.
• elltec_admin_session — keeps the site owner signed in to the admin panel.

This cookie data is not shared with third parties.

4. User accounts and paid subscriptions

Registering stores your email address, a hashed password (bcrypt), an optional name, and your subscription status, to provide the account and access to Premium content (Art. 6(1)(b) GDPR). Paid subscriptions are processed by the payment provider Stripe, Inc. (San Francisco, USA), which receives the data required for payment (e.g. email address, payment details); EllTec Analysis never receives full card details. A data processing agreement is in place with Stripe; transfers to the US may rely on the EU Standard Contractual Clauses. The legal basis is performance of the subscription contract (Art. 6(1)(b) GDPR).

5. Migrating existing subscribers

EllTec Analysis was previously run on the Substack platform. Email addresses and subscription status of existing subscribers from that earlier offering may be carried over into an account on this website, so existing access (including an already-active paid subscription) continues without requiring them to register again. The legal basis is continuation of the existing business relationship (Art. 6(1)(b) and/or (f) GDPR). Affected individuals are notified by email when their account is created and set their own password via a one-time, time-limited link; the account cannot be used before that. Objecting to this migration, or deleting the account, is possible at any time via the contact email address above.

6. Getting in touch

Data provided when contacting us by email (such as the email address and message content) is processed and stored solely to handle the request (Art. 6(1)(b) GDPR).

7. Translation feature

When the translation feature is used on an analysis, the text of that analysis is sent to our external translation provider, DeepL SE, to produce the German version (Art. 6(1)(f) GDPR). No personal data of visitors is transmitted in that process.

8. Newsletter (Marktbriefing and EllTec Analysis Updates)

Signing up for the Marktbriefing or EllTec Analysis Updates newsletter stores your email address, the time you confirmed the subscription (double opt-in), and the IP address at the time of signup, to send the newsletter and to be able to prove the consent given in a dispute. The legal basis is consent (Art. 6(1)(a) GDPR). Consent can be withdrawn at any time, with effect for the future, via the unsubscribe link included in every newsletter email. The data is kept until consent is withdrawn. For account holders: signing up for EllTec Analysis Updates happens automatically on registration (creating the account is itself the consent) and can be withdrawn at any time via a toggle in the account area or the unsubscribe link. Emails are sent through our provider Resend (Resend, Inc., San Francisco, USA); a data processing agreement is in place with Resend, and transfers to the US may rely on the EU Standard Contractual Clauses.

9. Retention

Personal data is kept only as long as necessary for the purpose it was collected for, or as required by statutory retention obligations (e.g. commercial or tax law). Account data is deleted on request unless a legal retention obligation applies. Invoice and accounting-related data (in particular relating to payments for the Premium subscription) is retained for ten years under German statutory retention obligations (§ 147 German Fiscal Code (AO), § 257 German Commercial Code (HGB)).

10. Your rights

You have the right to access, rectify, erase and restrict the processing of your personal data, to data portability, and to object to processing. Contact the email address above to exercise these rights.

11. Right to complain to a supervisory authority

You have the right to lodge a complaint with a data protection supervisory authority. The competent authority is the Bavarian State Office for Data Protection Supervision (BayLDA), Promenade 27, 91522 Ansbach, Germany, www.lda.bayern.de.