Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on the topic of data protection, please refer to our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section "Notice Regarding the Responsible Party" in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us. This may include, for example, data you enter in a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other inquiries.

What rights do you have regarding your data?

You have the right at any time to obtain information free of charge about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the topic of data protection.

2. Hosting and Content Delivery Networks (CDN)

We host the contents of our website with the following provider:

External Hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website access, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). If a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfill their service obligations and will follow our instructions regarding this data.

We use the following host(s):

Fly.io, Inc.
2045 W Grand Ave Ste B, PMB 69587
Chicago, Illinois 60612-1577
USA

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details and further information on data protection at Fly.io can be found here: https://fly.io/legal/privacy-policy/.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the service processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Cloudflare

We use the service "Cloudflare." The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter "Cloudflare").

Cloudflare offers a globally distributed content delivery network with DNS. Technically, the information transfer between your browser and our website is routed through Cloudflare's network. This enables Cloudflare to analyze the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. Cloudflare may also use cookies or other technologies for recognizing internet users, which are used solely for the purpose described herein.

The use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6(1)(f) GDPR).

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

Data Processing Agreement

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice Regarding the Responsible Party

The responsible party for data processing on this website is:

Thorsten Dunker Investment GmbH
Ohmoor 95C
22455 Hamburg

Phone: +49-40-57148643
Email: [email protected]

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, deletion will take place after these reasons cease to apply.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your terminal device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, the transmission of personal data to these external parties is also necessary. We only pass on personal data to external parties if this is necessary in the context of fulfilling a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the disclosure, or if another legal basis permits the data transfer. When using data processors, we only pass on personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can revoke consent that has already been given at any time. The lawfulness of data processing carried out prior to the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable legal provisions, you have the right at any time to obtain information free of charge about your stored personal data, its origin and recipient, and the purpose of data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and other questions on the topic of personal data.

Right to Restriction of Processing

You have the right to request the restriction of processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of processing of your personal data.
If the processing of your personal data was/is carried out unlawfully, you may request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it for the exercise, defense, or assertion of legal claims, you have the right to request the restriction of processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock icon in your browser bar.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Encrypted Payment Transactions on This Website

If there is an obligation to transmit your payment data (e.g. account number for direct debit authorization) to us after the conclusion of a paid contract, this data is required for payment processing.

Payment transactions via common means of payment (Visa/MasterCard, direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock icon in your browser bar.

With encrypted communication, your payment data that you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Inquiries by Email, Phone, or Fax

If you contact us by email, phone, or fax, your inquiry including all personal data derived from it (name, inquiry) will be stored and processed by us for the purpose of handling your request. We will not share this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact inquiries will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your request has been fully processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.

Registration on This Website

You can register on this website to use additional features on the site. We use the data entered for this purpose only for the use of the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.

For important changes, such as changes to the scope of the offering or technically necessary changes, we use the email address provided during registration to inform you in this way.

The processing of data entered during registration is carried out for the purpose of implementing the user relationship established by the registration and, if applicable, for the initiation of further contracts (Art. 6(1)(b) GDPR).

The data collected during registration is stored by us for as long as you are registered on this website and is subsequently deleted. Statutory retention periods remain unaffected.

Registration with Google

Instead of registering directly on this website, you can register with Google. The provider of this service is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

To register with Google, you only need to enter your Google name and password. Google will identify you and confirm your identity to our website.

When you sign in with Google, we may be able to use certain information from your account to complete your profile with us. Whether and which information this is, you decide within the framework of your Google security settings, which you can find here: https://myaccount.google.com/security and https://myaccount.google.com/permissions.

The data processing associated with Google registration is based on our legitimate interest in providing our users with the simplest possible registration process (Art. 6(1)(f) GDPR). Since the use of the registration function is voluntary and users can decide on the respective access options themselves, no overriding rights of the data subjects are apparent.

5. Newsletter

Newsletter Data

If you wish to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. For the processing of the newsletter, we use newsletter service providers, which are described below.

Brevo

This website uses Brevo for sending newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.

Brevo is a service that can be used, among other things, to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter is stored on the servers of Sendinblue GmbH in Germany.

Data Analysis by Brevo

With the help of Brevo, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links were clicked. In this way, we can determine, among other things, which links were clicked particularly often.

We can also see whether certain predefined actions were performed after opening/clicking (conversion rate). For example, we can see whether you made a purchase after clicking the newsletter.

Brevo also enables us to divide newsletter recipients into different categories ("clustering"). For example, newsletter recipients can be segmented by age, gender, or place of residence. In this way, the newsletters can be better tailored to the respective target groups.

If you do not want analysis by Brevo, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

Detailed information on the functions of Brevo can be found at the following link: https://www.brevo.com/de/newsletter-software/.

Legal Basis

Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time. The lawfulness of data processing operations already carried out remains unaffected by the revocation.

Storage Duration

The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored by us for other purposes remains unaffected.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if necessary, to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is not limited in time. You may object to the storage if your interests outweigh our legitimate interest.

For further details, please refer to the data protection provisions of Brevo at: https://www.brevo.com/de/datenschutz-uebersicht/ and https://www.brevo.com/de/legal/privacypolicy/.

Data Processing Agreement

6. eCommerce and Payment Providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the purpose of establishing, structuring, and amending our contractual relationships. We collect, process, and use personal data on the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill the user. The legal basis for this is Art. 6(1)(b) GDPR.

The collected customer data will be deleted after completion of the order or termination of the business relationship and expiration of any existing statutory retention periods. Statutory retention periods remain unaffected.

Data Transmission upon Contract Conclusion for Services and Digital Content

We transmit personal data to third parties only if this is necessary in the context of contract processing, for example to the credit institution responsible for payment processing.

No further transmission of the data takes place, or only if you have expressly consented to the transmission. Your data will not be passed on to third parties without explicit consent, for example for advertising purposes.

The basis for data processing is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual measures.

Payment Services

We integrate payment services from third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The use of payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment process (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent can be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Paddle

The provider is Paddle Payments Ltd., The Academy, 42 Pearse Street, Dublin, D02 YX88, Ireland (hereinafter "Paddle").

Paddle acts as Merchant of Record and handles payment, invoicing, and value-added tax on our behalf. In doing so, your payment data (e.g. name, email address, payment method) is processed directly by Paddle.

Details can be found in Paddle's privacy policy at the following link: https://www.paddle.com/legal/privacy.

7. Additional Information for US Residents

This section provides additional disclosures required under US state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), the Virginia Consumer Data Protection Act (VCDPA), the Colorado Privacy Act (CPA), and similar state laws. This section applies to residents of those states and supplements the information provided above.

Categories of Personal Information We Collect

In the preceding 12 months, we have collected the following categories of personal information:

Identifiers: Name, email address, IP address, account ID
Commercial Information: Subscription plan, payment history, transaction records
Internet or Network Activity: Browser type, pages visited, interactions with our service
Professional Information: Company name, domain names (as provided by you for DMARC monitoring)
Account Credentials: Hashed password, two-factor authentication data, OAuth tokens

Sources of Personal Information

Directly from you: When you register, configure domains, or contact us
Automatically: Through your use of our service (e.g. IP address, browser data)
From third-party services: Google or Microsoft (if you use OAuth sign-in), Paddle (payment data)

Business Purposes for Collecting Personal Information

Providing and maintaining our DMARC monitoring service
Processing payments and managing subscriptions
Sending service-related communications (e.g. weekly DMARC reports, verification emails)
Ensuring the security and integrity of our service
Complying with legal obligations

Sale and Sharing of Personal Information

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes. We have not sold or shared personal information in the preceding 12 months.

Third Parties Receiving Personal Information

We disclose personal information to the following categories of third parties solely for business purposes:

Hosting providers: Fly.io (application hosting), Turso (database)
Payment processor: Paddle (subscription billing, acts as Merchant of Record)
Infrastructure providers: Cloudflare (CDN, security), Upstash (caching)
Email service provider: SMTP provider for transactional emails
Error tracking: Sentry (application error monitoring)
Authentication providers: Google, Microsoft (only if you use OAuth sign-in)

Your Privacy Rights

Depending on your state of residence, you may have the following rights:

Right to Know: You can request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collecting, and the categories of third parties to whom we disclose it.
Right to Delete: You can request deletion of the personal information we have collected about you, subject to certain exceptions (e.g. completing a transaction, legal obligations).
Right to Correct: You can request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information, so no opt-out is necessary.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

How to Exercise Your Rights

To exercise your privacy rights, you may:

Email us at [email protected]
Delete your account through the account settings in the application

We will verify your identity before processing your request. We will respond to verifiable requests within 45 days. If we need more time (up to an additional 45 days), we will inform you of the reason and the extension.

Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with our services. DMARC report data is retained according to your subscription plan (30 days to 3 years). When you delete your account, we delete your personal information within 30 days, except where retention is required by law.

Children's Privacy

Our service is not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information.

Contact for Privacy Inquiries

For questions or concerns about this privacy policy or our data practices, please contact us at:

Email: [email protected]
Thorsten Dunker Investment GmbH
Ohmoor 95C
22455 Hamburg, Germany

Last updated: February 2026