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Privacy Policy

by admin

Last updated: 09.06.2026

This Privacy Policy explains how Vitaliy Katsenelson (“I,” “me,” or “my”) collects, uses, and shares information when you visit soulinthegame.net (the “Site”), subscribe to my newsletter, contact me, request the bonus chapters, or otherwise interact with me online.

soulinthegame.net is the promotional site for my book Soul in the Game: The Art of a Meaningful Life. It is my personal project and is separate from my work as an investment adviser. Nothing on this Site constitutes investment advice.

1. Who I am

The Site is operated by Vitaliy Katsenelson as a personal project.

Contact: privacy@soulinthegame.net

2. Information I collect

2.1 Information you give me directly

  • Newsletter subscription: your email address, and optionally your name, when you sign up to receive my weekly reflections on investing, life, and classical music. Signups on this Site are captured through OptinMonster (Retyp, LLC) and managed in Mailchimp (Intuit Inc.). This is the same newsletter offered on my other websites; subscribing here means your email is added to the same Mailchimp audience.
  • Contact form: your name, email address, and the content of your message when you submit the contact form. The form is protected by Google reCAPTCHA, which Google uses to distinguish humans from bots (see Section 2.2).
  • Bonus chapters request: if you email bonus@soulinthegame.net with a link to or screenshot of your Amazon review of the book to claim the 6 bonus chapters, I receive your email address, the contents of your message, and the review you sent. The review you link to or screenshot may include your public Amazon display name.
  • Correspondence: if you email me or message me on social media, I receive whatever information you choose to share.

2.2 Information collected automatically

When you visit the Site, I and my service providers may automatically collect:

  • Device and browser data: IP address, browser type, operating system, device type, screen size, referring URL, language preference.
  • Usage data: pages visited, time on page, clicks, scroll depth, downloads, dates and times of access. This is collected primarily through Google Analytics (Google LLC).
  • Advertising and conversion data: I use the Meta Pixel (Meta Platforms, Inc.) to measure how visitors interact with the Site, including page views and other events. The Meta Pixel allows Meta to associate your activity on the Site with your Facebook or Instagram account if you are logged into Meta services. This information is used by Meta to deliver advertising, build audiences (including “Custom Audiences” and “Lookalike Audiences”), and measure ad performance. Meta acts as a separate controller for some of this processing. For more information, see Meta’s Privacy Policy at https://www.facebook.com/privacy/policy.
  • Bot-detection data: Google reCAPTCHA (Google LLC) is used on the contact form to detect and prevent automated abuse. reCAPTCHA collects information about your interaction with the Site, including hardware and software information, and sends it to Google. For more information, see Google’s Privacy Policy at https://policies.google.com/privacy.
  • Cookies and similar technologies: see Section 6 below.

2.3 Information from third parties

  • Mailchimp engagement data: Mailchimp tells me whether and when newsletter emails are delivered, opened, and clicked, and whether they bounce or are marked as spam.
  • Meta advertising data: Meta may share aggregated audience insights and ad performance data with me.
  • Amazon affiliate data: links to Amazon on the Site are affiliate links (Amazon Associates tag myfavoritec08-20). When you click them, Amazon’s affiliate network may report back whether a purchase was made attributable to my referral. I do not receive your name, payment details, or the items you bought.
  • Social media: if you engage with my content on Facebook, Twitter/X, LinkedIn, or YouTube, those platforms may share information with me in accordance with their own settings and policies.

3. How I use your information

I use the information described above to:

  • Send you the newsletter and other communications you have requested.
  • Send you the bonus chapters and respond to bonus-chapter requests.
  • Respond to your questions and contact requests.
  • Operate, maintain, and improve the Site and promote the book.
  • Understand which content visitors find most useful.
  • Measure and improve the performance of my marketing, including advertising on Meta platforms.
  • Build audiences for advertising on Meta platforms, including audiences based on your interaction with the Site.
  • Detect and prevent spam, abuse, and security incidents.
  • Comply with legal obligations.

I do not sell your personal information. I do “share” information for cross-context behavioral advertising within the meaning of California law, through the Meta Pixel. See Section 9 for how to opt out.

I do not use your information for automated decisions that produce legal or similarly significant effects.

4. Legal bases (for visitors in the EEA, UK, and Switzerland)

If you are in the European Economic Area, the United Kingdom, or Switzerland, I rely on the following legal bases under the GDPR / UK GDPR:

  • Consent, for newsletter subscriptions and for non-essential cookies and trackers, including Google Analytics and the Meta Pixel. If you visit the Site from the European Economic Area, the United Kingdom, or California, I obtain this consent through a cookie consent banner displayed on your first visit. Non-essential cookies and trackers are not set on your browser until you make a choice in the banner.
  • Legitimate interests, for operating and securing the Site, answering your inquiries, and similar core purposes. I have assessed that these interests are not overridden by your rights and freedoms.
  • Performance of a contract, where I am responding to a request you have made (such as a bonus-chapters request).
  • Legal obligation, where I am required to retain certain records.

You can withdraw consent at any time without affecting the lawfulness of processing before the withdrawal. To withdraw consent or change your choices, visit the Your Privacy Choices page, available from the link in the Site footer.

For transfers of personal information from the EEA, UK, or Switzerland to the United States, I rely on Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), and on the EU-U.S. Data Privacy Framework and its UK and Swiss extensions where my service providers are certified.

5. How I share information

I share information only as described below. I do not rent or sell personal information.

Service providers that operate the Site on my behalf, including:

  • Mailchimp (Intuit Inc.) — newsletter delivery and email engagement analytics
  • OptinMonster (Retyp, LLC) — email capture forms and popups
  • Google Analytics (Google LLC) — Site analytics
  • Google reCAPTCHA (Google LLC) — bot detection on the contact form
  • Meta Platforms, Inc. — advertising measurement, retargeting, and audience building via the Meta Pixel

Each of these providers is permitted to use the data only to deliver services to me, except for Meta, which acts as an independent controller for some advertising-related processing as described in Section 2.2.

Legal and safety: I may disclose information when I believe in good faith that disclosure is required to comply with a legal obligation, lawful request from authorities, court order, or to protect my rights, your safety, or the safety of others.

Business transfers: if the Site is transferred to another operator, information may be transferred as part of that transaction, subject to standard confidentiality protections.

6. Cookies and tracking technologies

The Site uses cookies and similar technologies, including:

  • Strictly necessary cookies that enable core functionality (e.g., recording your cookie consent choices, protecting forms from spam).
  • Analytics cookies set by Google Analytics to help me understand how visitors use the Site in aggregate.
  • Advertising cookies set by the Meta Pixel to measure ad performance, retarget visitors with ads on Facebook and Instagram, and build advertising audiences.
  • Functionality cookies set by embedded third-party content, including any video embeds, social media widgets, and Google reCAPTCHA. These third parties set their own cookies that I do not control.

How I ask for your consent and how you can change it

If you visit the Site from the European Economic Area, the United Kingdom, or California, I display a cookie consent banner on your first visit asking for your permission to set non-essential cookies and trackers (analytics and advertising). Your location is determined automatically based on your IP address. Non-essential cookies and trackers are not loaded until you make a choice in the banner. Strictly necessary cookies are always set.

If you visit the Site from anywhere else, the banner is not displayed and non-essential cookies and trackers may be set when you visit the Site, in accordance with applicable law. You can manage your cookie preferences and opt out of non-essential cookies and trackers at any time by visiting the Your Privacy Choices page, accessible from the link in the Site footer. The link is available to all visitors regardless of location.

If you are traveling or using a VPN, the banner’s behavior follows your detected location rather than your residence. You can always exercise the rights described in Section 9 regardless of where you are when you visit the Site.

Global Privacy Control

I honor the Global Privacy Control (GPC) browser signal as an opt-out of the “sale” and “sharing” of personal information under California law and similar US state laws. When I detect a GPC signal from your browser, I automatically treat it as a request to opt out of cross-context behavioral advertising (including the Meta Pixel) for your browser and device, without you needing to take any further action.

7. Email newsletter and communications

If you subscribe to the newsletter, I will send you regular emails containing my reflections on investing, life, and classical music via Mailchimp. This is the same newsletter offered on investor.fm and imausa.com; if you are already subscribed there, you will not receive duplicates.

Every email contains an unsubscribe link. You can also unsubscribe at any time by emailing me at privacy@soulinthegame.net. After you unsubscribe I keep a suppression record so I do not accidentally re-subscribe you.

8. Data retention

I keep personal information only as long as needed for the purposes described above:

  • Newsletter subscribers: for as long as you remain subscribed, plus a suppression record after you unsubscribe.
  • Contact-form submissions and bonus-chapter requests: typically for up to 3 years after our last interaction with you, unless a longer period is required by law.
  • Google Analytics data: retained for 14 months in identifiable form (configurable in my Analytics settings).
  • Meta Pixel data: retention is governed by Meta’s own policies.

9. Your choices and rights

General rights

Depending on where you live, you may have some or all of the following rights:

  • Access the personal information I hold about you.
  • Correct information that is inaccurate or incomplete.
  • Delete your personal information.
  • Restrict or object to certain processing, including direct marketing.
  • Data portability, for information you have provided to me.
  • Withdraw consent at any time.
  • Lodge a complaint with a data protection authority. In the EEA, that is your local supervisory authority; in the UK, the Information Commissioner’s Office (ICO).

To exercise any of these rights, email me at [privacy contact email]. I may need to verify your identity before responding. I will respond within the timeframes required by applicable law (typically 30 days under GDPR/UK GDPR, 45 days under CCPA, extendable where permitted). You may authorize an agent to make a request on your behalf.

California residents (CCPA/CPRA)

In addition to the rights listed above, California residents have the right to:

  • Know the categories and specific pieces of personal information I collect, the sources, the business purposes, and the categories of third parties with whom I share it.
  • Opt out of “sale” and “sharing” of personal information. I do not sell personal information for money, but I do “share” it for cross-context behavioral advertising through the Meta Pixel. You can opt out by any of the following methods:
    • Visiting the Your Privacy Choices page, accessible from the link in the Site footer, and selecting the option to opt out of the sale and sharing of personal information,
    • Enabling Global Privacy Control in your browser — I automatically honor this signal as an opt-out, or
    • Emailing me at [privacy contact email] with your request.
  • Limit the use of sensitive personal information. I do not use or disclose sensitive personal information for purposes that require an opt-out right.
  • Non-discrimination for exercising these rights.

EEA, UK, and Swiss residents

You have the additional right to withdraw consent for any processing based on consent, and the right to object to processing based on legitimate interests, including profiling for direct marketing.

10. International transfers

I am based in the United States. If you access the Site from outside the United States — including from the EEA, UK, Switzerland, or California — your information will be transferred to, processed in, and stored in the United States and other countries where my service providers operate. For transfers from the EEA, UK, and Switzerland, I rely on EU Standard Contractual Clauses, the UK International Data Transfer Addendum, and the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) where applicable.

11. Security

I use reasonable administrative, technical, and physical safeguards designed to protect personal information from loss, misuse, and unauthorized access. No internet transmission or electronic storage is ever fully secure, however, so I cannot guarantee absolute security.

12. Children’s privacy

The Site is intended for adults. I do not knowingly collect personal information from children under 16. If you believe a child has provided me with personal information, please contact me and I will delete it.

13. Third-party links and content

The Site links to and embeds content from external sites, including Amazon (book purchases — see Section 14), Facebook, Twitter/X, LinkedIn, YouTube, investor.fm, myfavoriteclassical.com, imausa.com, and others. I am not responsible for the privacy practices of those sites. Please review their policies separately.

14. Amazon affiliate disclosure

soulinthegame.net is a participant in the Amazon Services LLC Associates Program, an affiliate advertising program designed to provide a means for sites to earn advertising fees by advertising and linking to Amazon.com. Links on the Site to purchase Soul in the Game (and any other Amazon products) use my affiliate tag myfavoritec08-20. If you click an affiliate link and make a purchase, Amazon may pay me a small commission at no additional cost to you. This does not affect what you pay or the recommendations I make.

15. Changes to this policy

I may update this policy from time to time. When I do, I will revise the “Last updated” date above. If changes are material, I will provide a more prominent notice — for example, by email to newsletter subscribers or a banner on the Site.

16. How to contact me

Questions, requests, or complaints about this policy or my handling of your personal information:

Vitaliy Katsenelson Email: privacy@soulinthegame.net