Privacy Policy

1. Data Controller

Bernstein Holding UG (haftungsbeschränkt)
Eschenlohmühle 2
86862 Lamerdingen, Germany
Email: briefing@bernstein-holding.com

2. Data Collection

We collect personal data solely in connection with subscriptions to The Memo. The following data is processed:

3. Legal Basis

Processing is based on Art. 6(1)(b) GDPR (performance of a contract) and Art. 6(1)(f) GDPR (legitimate interest in providing our service).

4. Payment Processing

Payments are handled by Stripe, Inc. (510 Townsend Street, San Francisco, CA 94103, USA). When subscribing, you will be redirected to Stripe's checkout page. Stripe's privacy policy applies: stripe.com/privacy

5. Email Delivery

The daily briefing is delivered by email via Resend, Inc. (a US-based email service provider operating under EU Standard Contractual Clauses). Your email address is used exclusively for briefing delivery and essential subscription communications. We do not send marketing emails and do not share your email address with third parties.

6. Cookies and Tracking

This website does not use cookies. No user profiles are created and no cross-site tracking takes place.

7. Website Analytics

We use Vercel Web Analytics and Vercel Speed Insights to collect anonymous, aggregated usage statistics (page views, referrers, country, device type) and page performance metrics (load times, interaction responsiveness). These services do not use cookies, do not store IP addresses, and do not create individual visitor profiles. Processing is based on Art. 6(1)(f) GDPR (legitimate interest in understanding how our website is used and improving its performance).

8. Hosting

This website is hosted by Vercel Inc. (440 N Barranca Ave #4133, Covina, CA 91723, USA). When accessing the site, technically necessary data (IP address, access time, browser type) may be processed in server log files pursuant to Art. 6(1)(f) GDPR. Vercel operates a global edge network and may serve content from European data centres.

9. PDF Watermarking

Each briefing PDF is individually watermarked with a subscriber-specific identifier derived from your email address. This is necessary to protect our intellectual property and enforce our Terms of Service. Processing is based on Art. 6(1)(f) GDPR (legitimate interest in preventing unauthorised redistribution).

10. Data Sharing

Personal data is not shared with third parties, with the exception of:

All service providers are contractually bound to comply with the GDPR.

11. International Data Transfers

Through the use of Stripe, Resend, and Vercel, data may be transferred to the United States. Stripe is certified under the EU-US Data Privacy Framework. Resend and Vercel operate under EU Standard Contractual Clauses for data transfers.

12. Data Retention

Personal data is stored for the duration of the subscription. After cancellation, your email address and name will be deleted within 30 days, unless statutory retention periods apply.

Invoice data is retained for 10 years in accordance with German tax law (§ 147 AO, § 257 HGB).

13. Your Rights

You have the right to:

To exercise your rights, please contact: briefing@bernstein-holding.com

14. Supervisory Authority

You have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18
91522 Ansbach, Germany
www.lda.bayern.de

15. Changes

We reserve the right to update this privacy policy as needed. The current version is always available on this page.

Last updated: March 2026

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