Privacy Policy

1. Who We Are

Lemma Capital provides investment research, strategy notes, company analysis, market commentary, model portfolio materials, and related informational content.

For the purposes of applicable privacy laws, including the EU GDPR and UK GDPR, Lemma Capital is the controller of your personal information.

2. Information We Collect

We may collect:

• Information you provide, such as name, email address, account details, country or region, preferences, messages, and subscription information;
• Payment-related information, such as subscription plan, payment status, billing email, transaction details, and invoice information;
• Technical and usage information, such as IP address, device type, browser type, pages viewed, time spent on the website, email open and click data, cookies, analytics data, and approximate location;
• Information from third-party service providers, such as payment processors, email platforms, analytics tools, community platforms, and customer support tools.

We do not intentionally collect sensitive personal information unless you voluntarily provide it.

3. How We Use Information

We use personal information to:

• provide and operate the Services;
• manage accounts and subscriptions;
• process payments;
• send newsletters, research updates, product updates, and service communications;
• respond to questions and support requests;
• improve the Services;
• analyze usage and marketing performance;
• maintain security and prevent fraud or abuse;
• comply with legal, tax, accounting, and regulatory obligations;
• enforce our terms and protect our rights.

Where applicable, we process personal information based on one or more legal bases, including performance of a contract, consent, legitimate interests, and legal obligations.

Our legitimate interests include operating and improving the Services, communicating with users, protecting security, preventing abuse, and developing our business.

4. Cookies and Analytics

We may use cookies and similar technologies to operate the Services, remember preferences, analyze usage, improve performance, and measure marketing effectiveness.

Some cookies are necessary for the Services to function. Where required by law, we will ask for your consent before using non-essential cookies, such as analytics or advertising cookies.

You can manage cookies through your browser settings or, where available, through our cookie consent tool.

5. How We Share Information

We may share personal information with:

• Service providers who help us operate the Services, such as hosting providers, payment processors, email platforms, analytics tools, authentication providers, customer support tools, and security providers;
• Professional advisers, such as lawyers, accountants, auditors, insurers, tax advisers, and compliance consultants;
• Authorities, courts, regulators, or other parties where required by law or necessary to protect our rights;
• Parties involved in a merger, acquisition, financing, reorganization, sale of assets, or similar transaction;
• Other parties with your consent.

We do not knowingly sell personal information.

6. International Transfers

We may process and store personal information in countries other than your country of residence.

If you are located in the European Economic Area, the United Kingdom, or Switzerland, and your information is transferred outside your jurisdiction, we will use appropriate safeguards where required by law. These may include adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, or other legally recognized safeguards.

7. Data Retention

We keep personal information for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, maintain records, and protect our rights.

In general:

• account information is kept while your account is active;
• billing and transaction records are kept as needed for tax, accounting, and legal purposes;
• marketing information is kept until you unsubscribe or request deletion, unless we have another lawful basis to retain it;
• security logs may be kept for a limited period to protect the Services.

8. Security

We use reasonable technical, administrative, and organizational measures to protect personal information.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security.

9. Your Rights

Depending on your jurisdiction, you may have the right to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• restrict or object to processing;
• withdraw consent where processing is based on consent;
• receive a portable copy of your information;
• opt out of marketing communications;
• lodge a complaint with a data protection authority.

If you are in the EEA, UK, or Switzerland, you may contact your local data protection authority. We encourage you to contact us first so we can try to resolve your concern.

To exercise your rights, contact us at: a.pisanov@lemmacap.com

10. Marketing Communications

You can unsubscribe from marketing emails by using the unsubscribe link in our emails or by contacting us.

Even if you unsubscribe, we may still send administrative, transactional, legal, security, or subscription-related messages.

11. Children’s Privacy

The Services are not intended for children under 18.

We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us.

12. Third-Party Services

The Services may contain links to third-party websites, platforms, or tools.

We are not responsible for the privacy practices, content, or security of third-party services. You should review their privacy policies separately.

13. Automated Processing

We may use analytics, automation, artificial intelligence, or similar tools to support internal operations, research workflows, security, fraud prevention, product improvement, and content recommendations.

We do not use personal information to make solely automated decisions that produce legal or similarly significant effects on users.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be marked with a new “Last Updated” date.

If we make material changes, we may notify you by email or through the Services.

15. Contact Us

For questions about this Privacy Policy or our privacy practices, contact us at: