Privacy Policy

This notice explains what personal data we process when you use apri-advisory.com, why we do it and what rights you have. It follows Articles 13 and 14 of the General Data Protection Regulation (GDPR).

1. Controller

Dr. Olumide Abimbola
Prinzenstraße 85D, 10969 Berlin, Germany
Telephone +49 30 33909525, email insight@apri-advisory.com

We have not appointed a data protection officer; we are below the thresholds at which German law requires one. Questions about this notice go to the address above.

2. What happens when you visit the site

This website is hosted by Squarespace, Inc., 225 Varick Street, New York, NY 10014, USA, and for visitors in the European Economic Area by its affiliate Squarespace Ireland Ltd. When you open a page, your browser sends technical data to Squarespace's servers: your IP address, the date and time, the page requested, the referring page, browser type and version, operating system and screen size. Squarespace stores this data in server logs and uses it to deliver the site, keep it secure and detect abuse. We use it to see that the site works. The legal basis is our legitimate interest in operating a secure website (Article 6 (1) (f) GDPR). Squarespace processes the data on our behalf under a data processing agreement; transfers to the United States rest on the EU-US Data Privacy Framework, under which Squarespace is certified, and on the European Commission's standard contractual clauses.

3. Cookies and similar technologies

Squarespace sets a small number of cookies that the site needs in order to work, for example a session cookie that protects forms against cross-site request forgery ("crumb") and cookies that remember whether you have dismissed a banner or given consent. These are used on the basis of § 25 (2) of the German Telecommunications Digital Services Data Protection Act (TDDDG) and Article 6 (1) (f) GDPR and cannot be switched off.

Squarespace also offers analytics cookies ("ss_cid", "ss_cpvisit", "ss_cvisit", "ss_cvr", "ss_cvt") that count unique visitors and sessions. We use Squarespace Analytics and nothing else: no Google Analytics, no advertising pixels. Analytics cookies are set only after you accept them in the cookie banner (Article 6 (1) (a) GDPR, § 25 (1) TDDDG). You can withdraw your consent at any time through the "Cookie Preferences" link in the footer or by deleting the cookies in your browser. Our separate Cookies page lists each cookie with its purpose and lifetime.

The Daily Pulse page stores a copy of the issues it has just loaded in your browser's session storage for ten minutes so that it does not reload them on every click. This is stored on your device only, is deleted when you close the tab and is not sent anywhere.

If you register for the archive of the Daily Pulse or the Strategic Insight, the page also saves a short note in your browser's local storage that you have registered, so that earlier issues stay open on that device. The note contains no personal data, is not sent anywhere and stays until you clear your browser data. It is needed to provide the archive you asked for (§ 25 (2) no. 2 TDDDG).

4. The Daily Pulse feed

The Daily Pulse page and the latest-issue panel on our home page load their content in your browser from a web service that we run on Google Apps Script, part of Google Workspace, which Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland, provides to us. That request transmits your IP address and the technical data described in section 2 to Google, which uses it to answer the request and to keep its service secure. Google processes the data on our behalf under its data processing terms for Google Workspace. It may be processed in the United States by Google LLC; those transfers rest on the EU-US Data Privacy Framework, under which Google LLC is certified, and on the European Commission's standard contractual clauses. The legal basis is our legitimate interest in publishing the briefing without operating our own servers (Article 6 (1) (f) GDPR).

5. Fonts

The typefaces on this site are delivered from Squarespace's own content delivery network or embedded in the page itself. No fonts are loaded from Google or other third-party servers.

6. Contact form and email

If you write to us through the contact form or by email, we process the data you provide (name, organisation, email address, your message) to answer you. The legal basis is Article 6 (1) (b) GDPR where your enquiry concerns a contract, and otherwise our legitimate interest in handling enquiries (Article 6 (1) (f) GDPR). Form submissions are stored by Squarespace and forwarded to our mailbox. We keep correspondence for as long as the matter is open and thereafter as commercial records require (section 9).

The contact form is protected against automated abuse by Google reCAPTCHA Enterprise, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. reCAPTCHA analyses your interaction with the page (mouse movements, time on page, IP address, browser data) to tell people from bots and may transfer that data to Google LLC in the United States on the basis of the EU-US Data Privacy Framework and standard contractual clauses. We use it on the basis of our legitimate interest in keeping spam out of our inbox (Article 6 (1) (f) GDPR). Google's own notice is at policies.google.com/privacy. If you would rather not use reCAPTCHA, email us directly instead.

7. Subscriptions, trial access and client relationships

If you subscribe to the Daily Pulse or the Strategic Insight, take up trial access or commission work from us, we process your name, organisation, role, email address, postal address and, for paying clients, billing details, in order to perform the contract (Article 6 (1) (b) GDPR). We keep a record of which issues were sent to which address. Contract and invoice data are retained for the statutory periods (section 9).

8. Email delivery through Mailchimp

We send the Daily Pulse, the Strategic Insight and occasional service messages through Mailchimp, a service of The Rocket Science Group LLC (an Intuit company), 675 Ponce de Leon Avenue NE, Suite 5000, Atlanta, GA 30308, USA. Your email address, name and organisation are stored on Mailchimp's servers in the United States; the transfer rests on the EU-US Data Privacy Framework and standard contractual clauses, and Mailchimp acts as our processor. Mailchimp records whether an email was delivered, opened and which links were clicked, using a tracking pixel and tracked links. We use this only to see whether issues arrive and are read.

Subscriptions that are part of a paid or trial contract rest on Article 6 (1) (b) GDPR. Free sign-ups, where offered, rest on your consent (Article 6 (1) (a) GDPR) confirmed by double opt-in: you receive a confirmation email and are added only after you click the link in it. You can unsubscribe at any time using the link at the foot of every email or by writing to insight@apri-advisory.com; this ends the processing for the future. After unsubscribing we keep your address on a suppression list so that it is not written to again.

9. How long we keep data

Server logs held by Squarespace are deleted on Squarespace's standard schedule. Enquiry correspondence is deleted once the matter is closed unless it becomes part of a client relationship. Contract, invoice and accounting records are kept for the periods required by German commercial and tax law (six and ten years under § 257 HGB and § 147 AO). Subscriber records are deleted when the subscription ends and the retention periods have run.

10. Recipients

Apart from the processors named above (Squarespace, Google for the Daily Pulse feed and for reCAPTCHA, Mailchimp), we do not pass your data to third parties, except where the law requires it or where you have asked us to. We do not sell personal data.

11. Your rights

You have the right to obtain confirmation of whether we process your personal data and access to it (Article 15 GDPR), to have inaccurate data rectified (Article 16), to have data erased (Article 17), to have processing restricted (Article 18), to receive the data you gave us in a portable format (Article 20) and to object to processing that rests on our legitimate interests (Article 21). Where processing rests on your consent you can withdraw it at any time with effect for the future. To exercise these rights, write to insight@apri-advisory.com. You also have the right to lodge a complaint with a supervisory authority; for us that is the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit, Alt-Moabit 59-61, 10555 Berlin, datenschutz-berlin.de).

12. No automated decision-making

We do not use your data for automated decisions or profiling within the meaning of Article 22 GDPR.

13. Changes

We update this notice when the site or our services change. The current version is always the one published here.

Last updated: 19 October 2026