Privacy Notice & Data Protection

Who we are

BERUBE CAPITAL LLC ("Berube Capital", "we") is an independent commodities research firm based in Nairobi, Kenya. We are the data controller for the personal data described in this notice.

Contact for any privacy question or request: berubecapital@gmail.com.

What we collect, and why

Data	Why we hold it	Lawful basis
Name	To address you correctly in correspondence	Consent
Email address	To send the research you signed up for	Consent
Organisation (optional)	To understand which market segments our readers work in	Consent
Stated interest	To send relevant research rather than everything	Consent
Email correspondence	To answer your enquiry and keep a record of what we agreed	Legitimate interest

What we do not collect. We do not use advertising trackers, third-party analytics cookies, or behavioural profiling. We do not collect payment card details — card payments are handled entirely by PayPal, and we never see or store your card number. We do not collect special-category data, and we do not ask for identity documents unless a specific institutional contract requires it.

How we use it

To send the daily brief and research notes you asked for
To respond to enquiries and fulfil report or subscription orders
To keep records required for tax and accounting purposes

We do not sell, rent or trade personal data. We do not share it with advertisers. We do not use your data to train models.

Who else processes it

We use a small number of service providers who process data on our behalf:

Provider	Role	Data involved
Site hosting & form handling	Serves the site; receives sign-up form submissions	Name, email, organisation, interest
PayPal	Payment processing for subscriptions and reports	Payment details — held by PayPal, not by us
Email provider	Sends and receives our correspondence	Email address, message content

How long we keep it

Subscriber details: until you unsubscribe or ask for deletion, then removed within 30 days
Correspondence: up to 24 months, then deleted unless it forms part of a contract record
Accounting records: as long as Kenyan tax law requires

Your rights

Under the Kenya Data Protection Act 2019 — and the GDPR where it applies to you — you have the right to:

Be told what personal data we hold about you
Receive a copy of it
Have inaccurate data corrected
Have your data deleted
Object to processing, or ask us to restrict it
Withdraw consent at any time — every email we send carries an unsubscribe option
Lodge a complaint with the Office of the Data Protection Commissioner (Kenya) at odpc.go.ke

To exercise any of these, email berubecapital@gmail.com. We will respond within 30 days and will not charge you for it.

Security

Access to subscriber data is limited to the founder. Data is held in access-controlled accounts protected by strong authentication. We keep the volume of personal data we hold deliberately small — the most reliable protection is not collecting data we do not need.

International transfers

Our service providers may process data outside Kenya. Where that happens we rely on the providers' own contractual safeguards and their compliance frameworks. If you would rather we corresponded without using a third-party platform, tell us and we will arrange it.

Cookies

This site uses no advertising or tracking cookies. Any storage used is strictly functional — for example remembering a chart selection during your visit. There is nothing to opt out of, because we are not tracking you.

Changes to this notice

If we change how we handle personal data we will update this page and change the date at the top. Material changes will be notified to subscribers by email.

Separate note on our research. Everything Berube Capital publishes is general information and market research. It is not investment advice, not a personal recommendation, and not an offer or solicitation to trade. We are not a licensed investment adviser, we do not manage client funds, and we do not execute trades. See our methodology for how our data is produced and what it cannot tell you.

Privacy notice.