Privacy Policy

The Tech Rotation Letter

Last updated: 1 September 2026

1. Controller

Felix Faust, Kruppstraße 111, 40227 Düsseldorf, Germany Email: faust118@outlook.de

We have not appointed a data protection officer, as we are not required to under Section 38 of the German Federal Data Protection Act (BDSG).

2. Scope

This publication is hosted on Substack, which processes personal data for its own purposes as an independent controller under its own privacy policy. This policy covers the processing we carry out as the publisher, for our own purposes. Both apply alongside each other.

3. What we process and why

Newsletter delivery. Your email address, any name you provide, and your subscription status, in order to send the newsletter you subscribed to and administer your subscription. Basis: Article 6 (1) (b) GDPR, and Article 6 (1) (a) where consent is required under national law.

Paid subscriptions. In addition, your plan, billing period, transaction amounts and dates, country of residence for tax purposes, and payment status, in order to provide paid access, bill you, manage renewals and cancellations, and handle withdrawal and refund requests. Card details are handled by the payment provider and are not accessible to us. Basis: Article 6 (1) (b) GDPR.

Email statistics. The platform records whether emails are opened and whether links are clicked and makes this available to us. We use it to understand which content is read and to improve the publication. Basis: Article 6 (1) (f) GDPR, our legitimate interest in assessing reach and quality. You may object at any time (clause 6), and you can prevent open measurement by setting your email client not to load remote images.

Comments. If you comment, we process your profile name and your contribution in order to moderate and respond. Basis: Article 6 (1) (f) GDPR.

Accounting and tax. Transaction records including amounts, dates, and the country associated with each transaction, in order to prepare our accounts, determine and declare value added tax where it is due, and meet retention obligations. Basis: Article 6 (1) (c) GDPR.

Correspondence and legal claims. Your message and contact details if you write to us, and personal data where necessary to establish, exercise, or defend legal claims. Basis: Article 6 (1) (b) or (f) GDPR.

4. Recipients and transfers

We share personal data with Substack Inc. as platform operator and email deliverer, with our payment providers, with our external tax advisers under professional confidentiality for accounts, filings, and VAT, and with public authorities or courts where legally required or necessary for legal claims. We do not sell personal data and do not share it for third-party advertising.

Substack Inc. is established in the United States and is certified under the EU-U.S. Data Privacy Framework, so transfers rely on the European Commission’s adequacy decision under Article 45 GDPR. Where a recipient is not covered by an adequacy decision, transfers rely on the European Commission’s standard contractual clauses under Article 46 (2) (c) GDPR. You may request a copy of the safeguards in place.

5. Retention

Subscription data is kept while your subscription is active and afterwards for as long as needed to handle cancellations, refunds, and queries. Records relevant to accounting and tax are kept for the statutory periods under German commercial and tax law, generally between six and ten years from the end of the calendar year in which the record arose. Where data is kept only to meet a retention obligation, its processing is restricted to that purpose.

6. Your rights

You have the right to access your data (Article 15 GDPR), to have it corrected (Article 16), erased (Article 17), or its processing restricted (Article 18), to data portability (Article 20), and to withdraw consent at any time with effect for the future where processing is based on consent (Article 7 (3)).

Where we rely on legitimate interests under Article 6 (1) (f) GDPR, you may object at any time on grounds relating to your particular situation (Article 21). We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, or unless it serves legal claims. No particular form is required.

To exercise any of these rights, contact faust118@outlook.de. We will respond within one month.

You may lodge a complaint with a supervisory authority. Ours is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2 to 4, 40213 Düsseldorf, Germany. You may also complain to the authority where you live or work.

7. Unsubscribing

You can unsubscribe at any time using the link at the end of every email or through your account settings. This ends further delivery. Records we are legally required to retain, in particular accounting records for past paid subscriptions, are unaffected.

8. Is providing data required?

Your email address is necessary to receive the newsletter. For paid subscriptions, billing and country information is necessary to conclude the contract and determine the applicable value added tax. Without this we cannot provide the service. No other data is required.

9. Automated decision-making

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

10. Changes

We may update this policy where our processing or the legal requirements change. The current version is always available on this publication, with the date of the last update shown at the top.