Privacy Policy
This policy explains what personal data Margin Moves collects, why, and what you can do about it. It's written to be read, so it's short. If anything is unclear, reply to any email or write to [email protected].
Who is responsible
The controller of your data is Technology Pro Bono S.L. · CIF B88502364 · Paseo de la Castellana 43, 28046 Madrid, Spain ("Margin Moves", "we", "I"). Contact: [email protected].
What we collect
- When you subscribe: your email address; your answer to the signup question about the kind of product you work on, if you give one; the date and time you subscribed; the page and link you came from (including campaign tags such as UTM parameters and the referring site); and the version of the consent text you agreed to when you ticked the box.
- When you read our emails: whether an email was delivered, opened and which links were clicked, plus basic technical data our email platform records (such as device type and approximate location derived from your IP address).
- When you reply to us: your message and anything you include in it.
- When you become a paid member: your name, billing address, company name and tax ID if you add them, and your subscription history. Card details are collected and processed by Stripe; we never see or store your full card number.
- If you join through a recommendation: the newsletter or network that recommended us.
Why we use it, and on what legal basis
- Sending the free emails, including promotion of the paid edition — Legal basis (GDPR): Your consent (art. 6.1.a), which you can withdraw at any time by unsubscribing
- Providing the paid membership, billing and invoices — Legal basis (GDPR): Performance of a contract (art. 6.1.b)
- Keeping invoices and accounting records — Legal basis (GDPR): Legal obligation (art. 6.1.c)
- Measuring which emails are opened and clicked and which sources bring readers, removing inactive subscribers, and keeping the service secure — Legal basis (GDPR): Our legitimate interest in running and improving the newsletter (art. 6.1.f). You can object at any time by writing to us, or stop it entirely by unsubscribing
- Answering your replies — Legal basis (GDPR): Legitimate interest, or the contract if you're a member
We don't sell your data, we don't use it for profiling with legal or similarly significant effects, and we never quote your replies in public without your permission.
Who we share it with
Only with providers who process it for us, and only what they need:
- beehiiv, Inc. (United States): our email and website platform, acting as our processor. beehiiv's data processing terms also describe functions in which beehiiv acts as an independent controller (its ad network and data-enrichment products); Margin Moves doesn't use them.
- Stripe (Stripe Payments Europe, Ltd. and its affiliates): payment processing. Stripe processes payment data for us as our processor, and as an independent controller for its own purposes, such as fraud prevention, managing financial risk and complying with anti-money-laundering and know-your-customer rules, under its own privacy policy (stripe.com/privacy).
- Google (Google Workspace): our email inbox for replies.
- Recommendation networks (such as SparkLoop and beehiiv's recommendations): only if you subscribe to us through their recommendation, or choose to subscribe to a newsletter we recommend. In that second case, your email address is passed to that newsletter only when you ask for it.
- Our tax adviser, and public authorities where the law requires it.
Transfers outside the EU
Some providers are in the United States. Transfers to Stripe rely on the EU–US Data Privacy Framework, with the European Commission's Standard Contractual Clauses as the fallback. Transfers to beehiiv rely on the Standard Contractual Clauses.
How long we keep it
- Free subscribers: while you're subscribed. When you unsubscribe, we delete your subscriber data, except your email address and the record of your consent and of your unsubscribe, which we keep for 3 years to be able to prove both and to make sure we don't email you again.
- Opens and clicks: we keep the detailed record of which emails you opened and which links you clicked for 12 months. After that we keep only totals that don't identify you.
- Inactive subscribers: if you don't click any link in our emails for 90 days, we send you one email asking whether you want to stay. If you still don't click, we remove you from the list.
- Paid members: your account data while your membership is active, and after that for as long as a claim about the membership could still be brought. Invoices and billing records: 6 years, as Spanish tax and commercial law requires.
- Replies: up to 2 years after the last exchange, unless we need them longer to handle a claim.
Your rights
You can ask for access to your data, correction, deletion, restriction, portability, or object to processing based on legitimate interest. You can withdraw consent at any time by unsubscribing from any email; that doesn't affect processing already done. Write to [email protected]. We'll answer within one month.
If you think we've handled your data badly, you can complain to the Spanish data protection authority, the Agencia Española de Protección de Datos (www.aepd.es), or the authority where you live.
Age
Margin Moves is for professionals. It isn't directed at anyone under 18, and we don't knowingly collect their data.
Changes
If this policy changes in a way that matters, we'll tell subscribers by email before the change applies. Older versions are available on request.