Privacy Policy

The controller responsible for the processing of personal data on this website is:

Vandamme GmbH

[Street and number], [Postal code] [City], Germany

Email: hello@terra-eluma.com

Phone: +49 157 77689490

Terra Eluma is a brand operated by Vandamme GmbH.

This policy applies to www.terra-eluma.com and every subpage, including the private Investment Circle reading room. Where a third party provides an integrated service, we name it and describe what it receives.

When you visit the site, our hosting provider records technical data in server logs: IP address (shortened where feasible), date and time, the page requested, referring page, browser, and operating system. This is necessary to operate the site securely.

Legal basis: Art. 6 (1)(f) GDPR (legitimate interest in a stable, secure website). Retention: up to 30 days, then deleted or fully anonymised.

If you write to us — via the access request form, the contribution form, or by email — we process the information you provide (name, email address, message content) to answer you.

Legal basis: Art. 6 (1)(b) GDPR (steps prior to entering into a relationship) or Art. 6 (1)(f) GDPR (legitimate interest in responding to your enquiry). Retention: as long as needed to answer you and to keep a record of the correspondence, then deleted in line with statutory retention periods.

We do not currently operate a general marketing newsletter. When a newsletter is introduced, subscription will use double opt-in on the basis of your consent (Art. 6 (1)(a) GDPR). You will be able to unsubscribe at any time via a link in every message.

The site uses only what is strictly necessary until you tell us otherwise. Essential cookies keep the site working — including the record of your cookie choice. Any non-essential cookies (for example, analytics) are loaded only after your consent (Art. 6 (1)(a) GDPR).

You can revisit your choice at any time via Cookie Policy or the “Cookie Settings” link in the footer.

No analytics is active today. When we introduce a privacy-respecting analytics tool, it will be listed here with provider, purpose, data categories, retention, and legal basis, and it will only load after you accept the “Analytics” category in the cookie banner.

The Investment Circle is a private area accessible only to invited members. To provide it, we process account data (email, name, role), authentication data (session tokens), and activity records (documents viewed, actions taken) for security and audit purposes.

Authentication is handled by our authentication provider on our behalf as a processor under Art. 28 GDPR. Legal basis: Art. 6 (1)(b) GDPR (performance of the relationship with the invited member) and Art. 6 (1)(f) GDPR (legitimate interest in the security of the space). Retention: for the duration of membership plus statutory retention periods.

Where we make an AI assistant available inside the Investment Circle, the questions you ask and the context provided are sent to a language-model provider on our behalf to produce a response. We do not use your inputs to train third-party models. Please do not enter sensitive personal data. Detail is on the AI Disclaimer page.

Our operational email is provided by Microsoft 365 (Microsoft Ireland Operations Ltd.) as a processor. Where transfers to Microsoft group companies outside the EU/EEA are necessary, Microsoft relies on the EU–US Data Privacy Framework and the EU Standard Contractual Clauses as its transfer mechanism.

The website and the Investment Circle are hosted in the European Union with reputable cloud providers acting as processors under Art. 28 GDPR. Any onward transfer outside the EU/EEA uses lawful transfer mechanisms (EU Standard Contractual Clauses, adequacy decisions).

Under the GDPR, you have the right to:

• access your personal data (Art. 15 GDPR);
• correction (Art. 16 GDPR);
• erasure (Art. 17 GDPR);
• restriction of processing (Art. 18 GDPR);
• data portability (Art. 20 GDPR);
• object to processing based on legitimate interest (Art. 21 GDPR);
• withdraw any consent you have given, at any time, without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with a supervisory authority, e.g. the data-protection authority of the German federal state in which we are established.

Write to hello@terra-eluma.com. We answer by hand and reply within statutory deadlines.

We may update this policy to reflect changes in our practices or in the law. The date at the top of the page shows when it was last revised. Material changes will be signalled in advance where appropriate.