Privacy policy
Last updated:
In short: this site has no user accounts and no registration form. Subscribing to The Decision happens on Substack, not here, so jcrinvestment.com neither receives nor stores your email address. Vercel provides the infrastructure and the analytics, which run without cookies. If you choose to write to the contact email, we will process the data needed to reply to you.
1. Data controller
The data controller is Juan Carlos Rodríguez Sánchez.
- Contact email: contact@jcrinvestment.com
- Website: jcrinvestment.com
2. What data may be processed
The site does not request personal data through forms and does not create accounts or profiles. Depending on how you use the site, the following categories may be processed:
Technical browsing data: IP address, browser and device information, date and time, resources requested, and the data needed to deliver the site, protect it and detect abuse.
Data you send by email: your email address, the content of the message and any data you choose to include when writing to contact@jcrinvestment.com.
When you follow a subscribe link you leave this site. Your subscription to The Decision, free or paid, is taken and held by Substack: jcrinvestment.com neither receives nor stores your email address, and no payment for a paid subscription to The Decision passes through this site. Substack Inc. processes that data in accordance with its own terms and privacy policy.
3. Purposes and legal bases
Providing and protecting the site: managing the delivery of the pages, maintaining their security, preventing abuse and resolving incidents. The legal basis is the legitimate interest in operating a secure, functional site and, where applicable, compliance with legal obligations.
Aggregate measurement: Vercel Web Analytics and Vercel Speed Insights make it possible to understand general use of the site and its performance without using cookies. What is recorded is the date and time, the page visited, the referring page, the approximate country, region and city, the operating system, the browser and the device type. The visitor is assigned a value derived from the request itself, which is discarded after twenty-four hours and cannot be used to recognise them across sessions or across different sites. No individual profiles are built and no automated decisions are taken about visitors. The legal basis is the legitimate interest in understanding, in aggregate, how the site is used.
Answering enquiries: using the data you send by email to deal with your message, follow up on the conversation where necessary and comply with any obligations that may apply.
Google Analytics is not active as of the date of this policy. If it is added in future, this policy will be updated and the appropriate consent mechanism will be enabled before any of its cookies or identifiers are activated.
4. Retention
Technical data will be retained for as long as necessary to provide the service, protect it, analyse incidents and comply with applicable legal obligations.
Email messages will be retained for as long as necessary to handle the enquiry and, afterwards, for the periods that any legal liabilities may require. They are not used to build a subscriber list, nor to send you marketing without an appropriate legal basis.
5. Recipients and providers
We do not sell or transfer your data for commercial purposes. To provide and protect the site we use Vercel Inc., which supplies hosting, the distribution network, security and the aggregate analytics described in section 3.
The Decision is delivered through Substack Inc., which hosts the subscriber list, sends The Decision and, for paid subscriptions, handles the payment through its own payment provider. Signing up and paying happen on Substack’s own site, under its terms and its privacy policy, and this site is not involved in either.
The technical handling of the contact email may involve the mail provider used for that mailbox. Data may also be disclosed to public authorities where there is a legal obligation to do so.
Where a provider processes data outside the European Economic Area, the safeguards required by data protection law for such transfers will be applied.
6. External links and services
The site links to Substack, social networks, YouTube and information sources. Those services are independent of jcrinvestment.com and may process data, use cookies or record your activity when you interact with them. Check their own policies before using them.
7. Your rights
You can request access to, rectification of, erasure of, restriction of or objection to the processing of your data, and exercise the right to portability where applicable. To do so, write to contact@jcrinvestment.com.
You can also lodge a complaint with the Spanish Data Protection Agency (aepd.es).