Privacy Policy

This Privacy Policy explains how TUTTOPASSA LLC ("we", "us", "our") collects, uses, and shares information when you visit thecoology.com (the "Site") and subscribe to our newsletter.

1) What we collect (Notice at Collection)

We collect:

• Email address — provided by you when subscribing.
• Technical data — basic information your browser sends (e.g., IP address and device/browser information) necessary to operate and secure the Site.

Purpose:

• To send you our weekly newsletter and manage your subscription.
• To operate and secure the Site (performance, fraud prevention).

Providing your email is optional, but we cannot send you the newsletter without it.

2) Sources

• Directly from you: when you enter your email.
• Automatically: via your browser/device when you use the Site.

3) How we use information

• Deliver and manage the newsletter (subscribe, confirm, unsubscribe).
• Provide, maintain, protect, and improve the Site (debugging, security).
• Comply with legal obligations and enforce our Terms.

4) Disclosures to service providers

We share information with trusted service providers who process it on our behalf under contracts that restrict their use:

• Email Service Provider (ESP): ConvertKit (newsletter delivery, list management).
• Hosting/CDN: Vercel (site hosting, security).

We do not authorize service providers to use your information for their own marketing.

5) "Sale"/"Sharing" and targeted advertising

We do not sell or share personal information as defined by California law and we do not engage in cross-context behavioral advertising. If this changes, we will update this Policy and provide a prominent "Do Not Sell or Share My Personal Information" link.

6) Financial incentives

We do not offer financial incentives or price/service differences in exchange for personal information. If we later offer an incentive (e.g., access to a paid-value asset), we will publish a Notice of Financial Incentive describing the material terms, estimated value, and your right to opt out without penalty.

7) Cookies and similar technologies

We do not use third-party analytics or advertising cookies. Only essential technologies are used to operate and secure the Site. If we later adopt analytics, we will update this Policy and provide appropriate disclosures and choices.

8) Data retention

• Email address: retained while you remain subscribed and then deleted or placed on a suppression list to honor your opt-out.
• Technical data: retained only as needed for security and operations and then deleted or aggregated.

9) Security

We use reasonable technical and organizational measures (e.g., TLS encryption in transit, access controls). No method of transmission or storage is 100% secure.

10) Children

This Site is not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe a child provided information, contact us and we will delete it.

11) Your rights (U.S. state privacy laws)

Residents of California, Colorado, Connecticut, Virginia, and Utah may have rights to:

• Access/know the categories and/or specific pieces of personal information we collected.
• Delete personal information.
• Correct inaccuracies (where applicable).
• Opt out of certain processing (e.g., sale/sharing/targeted ads) — not applicable here because we don't sell/share or run targeted ads.
• Not receive discriminatory treatment for exercising rights.

How to exercise your rights

Email us at privacy@thecoology.com with the subject "Privacy Request" and indicate your state of residence. We may need to verify your identity. Authorized agents may act on your behalf where the law allows.

Global Privacy Control (GPC)

We honor GPC signals as an opt-out preference where applicable by law.

12) International transfers

We may process and store information in countries outside your state or country of residence (e.g., the United States and the European Union). Where required, we use appropriate safeguards (such as Standard Contractual Clauses) with our providers.

13) Third-party links

The Site may link to third-party websites or services. Their privacy practices are governed by their own policies.

14) Changes to this Policy

We may update this Policy from time to time. The "Last updated" date reflects the latest changes. Material changes will be posted on this page.

15) Additional information for users in the EEA/UK

Controller

For the purposes of the EU/UK data protection laws, TUTTOPASSA LLC is the controller of personal data collected through thecoology.com.

Legal bases

We process personal data on the following legal bases:

• Consent (Art. 6(1)(a) GDPR) — to send you the newsletter when you subscribe.
• Legitimate interests (Art. 6(1)(f) GDPR) — to operate, secure, and improve the Site (e.g., basic security/anti-fraud, debugging). We balance our interests against your rights and expect minimal impact due to the limited scope of processing.

Cookies and similar technologies

We currently do not use non-essential cookies (e.g., advertising or analytics cookies). If we later adopt analytics or advertising technologies that require consent under EU/UK law, we will obtain prior consent via a cookie banner and honor your choices (including Global Privacy Control where applicable).

International data transfers

We may transfer your personal data to the United States (e.g., to our email service provider ConvertKit and our hosting/CDN). Where required, we rely on Standard Contractual Clauses (SCCs) and, where applicable, on providers' participation in recognized transfer frameworks. You can request a copy of the relevant safeguards using the contact details below.

Your rights

Subject to conditions and exemptions under EU/UK law, you have the right to request: access, rectification, erasure, restriction, portability, and to object to processing based on legitimate interests. Where we rely on consent, you can withdraw it at any time (this does not affect processing prior to withdrawal).

How to exercise your rights

Email privacy@thecoology.com with the subject "EU/UK Privacy Request". We may ask for information to verify your identity and country of residence.

EU/UK representative

We do not currently appoint an EU/UK representative because we do not specifically target individuals in the EEA/UK and we do not monitor their behavior through tracking technologies. If this changes (e.g., we run targeted advertising or analytics that monitors behavior of users in the EEA/UK), we will appoint a representative and update this notice accordingly.

Supervisory authority

You also have the right to lodge a complaint with your local data protection authority (for the EEA) or the UK Information Commissioner's Office.

16) Contact