Privacy Policy

This policy explains what personal data we collect when you use www.elquibondresearch.com, why we collect it, and what you can do about it.

We are a one-person research firm. We collect what we need to run a subscription and nothing else. We do not sell personal data and we do not use it for advertising.

1. Who is responsible

Elqui Bond Research S.à r.l.-S is the controller of the personal data described here.

We have not appointed a data protection officer. We are not required to. Write to the address above with any question about your data and Marco Lantermo will answer.

2. What we collect and why

When you contact us or request a call

Your name, your firm, your email address, your telephone number if you give it, and whatever you write in the message.

We use it to answer you. The legal basis is our legitimate interest in responding to people who approach us, and where you ask for a quote or a call it is also the steps taken at your request before entering a contract.

When you start a trial or subscribe

Your name, your firm, your business email address, your billing address, your VAT number where you give one, and the professional client declaration you make at checkout, including the date and time you made it.

We use it to open your account, to give you access, to invoice you and to keep the record that you declared yourself a professional client. The legal basis is performance of the contract, and for the declaration record and the invoices it is compliance with our legal obligations.

When you pay

Stripe processes your card. We receive the last four digits, the card brand, the expiry date, the country and whether the payment succeeded. We never receive the full card number.

The legal basis is performance of the contract.

When you use the service

Which documents you open and when, your login times, and the count of documents used against your trial allowance.

We use it to enforce the trial allowance and the plan entitlements, to detect shared logins and to know which research is read. The legal basis is performance of the contract and our legitimate interest in preventing misuse of the licence.

When you cancel

The date you cancelled and, if you choose to answer, the reason you give.

Answering is optional and the cancellation happens whether you answer or not. Where you do answer, the legal basis is our legitimate interest in understanding why subscribers leave so that we can improve the service. We use the answers in aggregate. We do not use them to contact you again, to offer you a retention discount or to try to talk you out of leaving. You can tell us at any time to delete your answer.

Technical data

Your IP address, browser type, device type and the pages you visit, collected by our hosting provider in server logs.

We use it to keep the site running and secure. The legal basis is our legitimate interest in the security and availability of the service.

Email about the service

If you subscribe, we email you about your account, your invoices, changes to these documents and new research relevant to your plan. The legal basis for account and billing email is performance of the contract. For research notifications to existing subscribers it is our legitimate interest in providing the service you bought, and you can turn them off in your account.

If you are not a subscriber, we send you marketing email only if you asked for it. You can unsubscribe from any such email in one click.

3. Who else sees your data

We use a small number of service providers. They process data on our instructions and under a contract that meets Article 28 of the GDPR.

Bookkeeping is done in house by Marco Lantermo. No external accountant has access to your data. If we appoint one we will add them to this table before they receive anything.

We update this list when it changes. Ask us at any time for the current version.

We also disclose data where the law requires it, for example to the Luxembourg tax authorities, or where we need to establish or defend a legal claim.

Nobody else receives your data. We do not share it with advertisers, data brokers or the issuers we cover.

4. Transfers outside the European Economic Area

Stripe transfers some data to the United States. Those transfers rely on the standard contractual clauses adopted by the European Commission, together with the additional safeguards Stripe applies. You can ask us for a copy of the relevant terms.

We do not otherwise transfer personal data outside the EEA.

5. How long we keep it

We keep the professional client declaration for as long as we could need to show that we sold to a professional. That is the reason for the ten-year period.

6. Your rights

Under the GDPR you may ask us to:

• give you a copy of the personal data we hold about you
• correct it if it is wrong
• delete it, where we have no further reason to keep it
• restrict what we do with it while a dispute about it is resolved
• send it to you or to another provider in a machine-readable format, where we hold it on the basis of your consent or of a contract
• stop processing it where we rely on legitimate interest, by objecting on grounds relating to your situation
• stop sending you marketing, at any time and without giving a reason

Where we rely on your consent, you can withdraw it at any time. Withdrawing consent does not affect what we did before you withdrew it.

Write to marco@elquibondresearch.com. We answer within one month. If your request is complex we may take up to two further months and we will tell you why.

We may ask you to confirm your identity before we act, so that we do not disclose your data to somebody else.

7. Complaints

If you think we have handled your data badly, tell us first and we will try to fix it.

You also have the right to complain to the Luxembourg supervisory authority:

Commission nationale pour la protection des données (CNPD)
15, Boulevard du Jazz, L-4370 Belvaux
www.cnpd.lu

If you live or work in another EU member state, you may complain to the authority there instead.

8. Cookies

We use cookies that are strictly necessary to run the site: keeping you logged in, remembering your cookie choice and protecting against fraud during payment. These do not need your consent.

We do not use advertising cookies and we do not track you across other websites.

If we add analytics, we will ask for your consent first through a banner that lets you refuse as easily as accept, and we will update this policy before we do.

Stripe sets its own cookies during checkout to detect fraud. Stripe's privacy policy explains them.

9. Automated decisions

We do not make decisions about you by automated means that produce legal effects or similarly significant effects.

10. Security

Access to the research is behind a login. Data in transit is encrypted. Card data never reaches our systems. Access to the administration side of the service is limited to Marco Lantermo.

No system is completely secure. If a breach occurs that is likely to put your rights at risk, we will tell you and the CNPD as the GDPR requires.

11. Changes to this policy

We will post any change here and update the date at the top. If a change is significant we will email subscribers before it takes effect.

Questions about your data: marco@elquibondresearch.com