Privacy Policy

Last updated: 22nd January 2026

This Privacy Policy explains how ACCE Investments (”we”, “us”, “our”) collects, uses, discloses, and protects personal data in connection with the ACCE Investments Substack publication (the “Publication”) and related services (collectively, the “Services”).

We are committed to protecting your privacy and handling personal data in a transparent and compliant manner in accordance with the EU General Data Protection Regulation (GDPR) and applicable Spanish data protection laws.

By accessing or subscribing to the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for the processing of your personal data is:

ACCE Investments
Location: Spain
Contact:

2. Personal Data We Collect

We only collect personal data that is necessary for the operation of the Services.

Depending on how you interact with the Publication, this may include:

2.1 Information You Provide Directly

• Email address

• Name or username (if provided)

• Subscription status (free or paid)

• Communications you send to us (emails, messages, comments)

2.2 Information Collected Automatically

• IP address

• Device and browser information

• General location data (country or region level)

• Usage data (opens, clicks, interaction with content)

Automatic data collection is primarily handled by Substack and its service providers.

3. How We Use Your Personal Data

We process personal data for the following purposes:

• To provide and operate the Services

• To manage subscriptions and deliver content

• To communicate with subscribers

• To improve content quality and user experience

• To comply with legal and regulatory obligations

We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal Bases for Processing

Under GDPR, we rely on the following legal bases:

• Contractual necessity: to provide subscription-based Services

• Legitimate interests: to operate, improve, and secure the Publication

• Consent: where required for specific communications

• Legal obligation: to comply with applicable laws and regulations

5. Cookies and Tracking Technologies

Substack may use cookies and similar technologies to operate the platform, ensure security, and analyse usage.

ACCE Investments does not directly set or control cookies. For detailed information, please refer to Substack’s Cookie Policy.

6. Data Sharing and Third Parties

We do not sell personal data.

Personal data may be shared only with:

• Substack, Inc., as the platform provider

• Payment processors (e.g. Stripe), where applicable

• Service providers necessary to operate the Services

• Public authorities, where required by law

Third parties process personal data under their own privacy policies and contractual obligations.

7. International Data Transfers

Substack and its service providers may process personal data outside the European Economic Area (EEA).

Where such transfers occur, appropriate safeguards are applied, including Standard Contractual Clauses (SCCs) or equivalent mechanisms, in accordance with GDPR requirements.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, including legal, accounting, or reporting obligations.

When personal data is no longer required, it is securely deleted or anonymised.

9. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of access

• Right to rectification

• Right to erasure (”right to be forgotten”)

• Right to restriction of processing

• Right to data portability

• Right to object to processing based on legitimate interests

• Right to withdraw consent at any time

To exercise your rights, please contact us using the details above. You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD).

10. Data Security

We implement reasonable technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration.

However, no method of transmission or storage is completely secure, and absolute security cannot be guaranteed.

11. Communications and Emails

Subscribers may receive emails related to content delivery, account management, or important updates.

You may unsubscribe from non-essential communications at any time using the unsubscribe link provided in emails or via your Substack account settings.

12. Children’s Data

The Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be effective upon publication. Continued use of the Services constitutes acceptance of the revised Privacy Policy.

14. Contact

For any questions about this Privacy Policy or how personal data is handled, please contact:

ACCE Investments

By using or subscribing to the Services, you acknowledge that you have read and understood this Privacy Policy.