Summary
This Privacy Policy applies to tvpispectrum.com.
The Portfolio TVPI Spectrum® Generator runs entirely in your browser. The portfolio data, investment names, and amounts you enter never leave your device. We do not operate a backend that receives or stores your inputs. JSON Save/Load happens locally via your browser's file dialog. (Of course, if you then save that JSON file to a network share, a cloud drive, or your CRM, it can travel as far as your network reaches — but that's your decision, not ours.)
Controller
AQAL Capital GmbH
Cuvilliésstraße 14, 81679 München, Germany
E-mail: tvpi-contact@tvpispectrum.com
Data We Do Not Collect
- No account, sign-up, or login.
- No fund or investment data is transmitted to our servers.
- No cookies are set by this application.
- No third-party advertising, tracking pixels, or social plug-ins.
Hosting (Cloudflare)
This site is hosted on Cloudflare Pages / Workers (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA). Cloudflare processes the request data technically required to deliver the page (IP address, timestamp, requested URL, user agent) in short-lived server logs for security and abuse prevention. Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in providing and securing the service). A Data Processing Addendum with Cloudflare is in place.
Cloudflare Web Analytics
We use Cloudflare Web Analytics, a cookieless, privacy-friendly analytics service that aggregates page-view and performance metrics without fingerprinting visitors and without setting cookies or storing IP addresses beyond the request itself. No personal profiles are built. Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in measuring site usage to improve the service). Cloudflare's privacy policy: cloudflare.com/privacypolicy.
We also count a small number of anonymous interaction events (for example: opening the generator, generating a diagram, exporting an image) using Cloudflare Workers Analytics Engine. These counts are aggregate and carry no cookies, no IP address, no device fingerprint, and no information that could identify you — only the event name, the page path, the referring site's domain, and a coarse country code. They exist solely to tell us which features are used. Legal basis: Art. 6 (1) (f) GDPR (legitimate interest in improving the service).
If you arrive from one of our tagged marketing links (for example a post on LinkedIn or X), we also note the campaign label carried in that link — a short, non-personal tag such as essay1-why-tvpi — so we can tell which post led to which actions. That label is held briefly in your browser's session storage (not a cookie; it is erased automatically when you close the tab) and is sent only with the anonymous interaction events described above. It contains no personal data.
Web Fonts
We load Inter and Merriweather from Google Fonts (fonts.googleapis.com / fonts.gstatic.com). Your browser transmits its IP address to Google when fetching these fonts. If you prefer fonts to be self-hosted, please contact us. Legal basis: Art. 6 (1) (f) GDPR.
Your Rights (GDPR)
You have the right to information (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and objection (Art. 21). You may lodge a complaint with a supervisory authority — for Bavaria: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA).
To exercise your rights, e-mail tvpi-legal@tvpispectrum.com.
Changes
We may update this policy to reflect changes to the service or legal requirements. The current version is always available at this URL.