Privacy Policy

Mailing address: [ADDRESS — TBD].
Privacy contact: privacy@italianresetmethod.com.

Scope

This Policy applies to italianresetmethod.com and any related pages, quizzes, email communications and online services we operate (the “Services”). It does not apply to third-party sites we link to.

Categories of personal information we collect

In the past 12 months we may have collected these categories of personal information (mapped to the California Consumer Privacy Act, as amended by the CPRA):

• (A) Identifiers — name, email, IP, device IDs, cookie IDs (Meta _fbp, Google _ga), and our first-party _irm_uid.
• (B) Customer records — email and any contact details you submit.
• (F) Internet or other electronic network activity — pages viewed, referrer, quiz answers, clicks, time on page, browser/OS.
• (G) Geolocation — coarse, IP-derived (country and US state) only. No precise GPS.
• (K) Inferences — your wellness ritual archetype (Morning, Midday, Evening, Sensory).

We do not collect Social Security numbers, financial account numbers, driver's license numbers, biometric information, or precise geolocation. We do not knowingly collect information from children (see “Children” below).

Sensitive personal information & Right to Limit

Some quiz answers describe how you feel in your body (e.g. tension, sleep, mood). To the extent this constitutes “sensitive personal information” under the CPRA or similar laws, we use it only to deliver the personalized ritual you requested and for security and fraud prevention. We do not use sensitive PI to infer characteristics about you and we do not sell or share it for cross-context behavioral advertising.

Because our use already falls within Cal. Civ. Code §1798.121(d), the CPRA “Right to Limit” notice and link are not required. You may still email privacy@italianresetmethod.com to request restriction.

Sources

• Directly from you (forms, quiz, email).
• Automatically from your device (cookies, pixels, server logs).
• From advertising and analytics partners (Google, Meta) when you click an ad or visit referred pages.

Purposes

• Provide and personalize the Services (deliver your ritual, send the email you requested).
• Measure and improve marketing performance (analytics, conversion attribution).
• Show relevant advertising on Google, Facebook and Instagram (only with consent where required).
• Security, fraud prevention, debugging, legal compliance.

How we share — disclosures, “sales” and “sharing”

We do not sell personal information for money. However, our use of advertising cookies and pixels from Google Ads and Meta (Facebook/Instagram) qualifies as a “sale” and/or “sharing” for cross-context behavioral advertising under the CCPA/CPRA and similar laws.

In the past 12 months we disclosed:

• Identifiers, internet activity, inferences — to Google LLC and Meta Platforms, Inc. for measurement and advertising (“sharing”).
• Identifiers, internet activity — to Google LLC for analytics (service-provider basis).
• Identifiers, customer records — to our email service provider, hosting provider and backend (service-provider basis).

Opt out of “sale” and “sharing” at Do Not Sell or Share My Personal Information. We also honor the Global Privacy Control (GPC) browser signal as a valid opt-out.

Retention

Notice of Financial Incentive (California)

When you submit your email at the end of the quiz, we offer you a free personalized ritual and access to future subscriber-only content, promotions and discounts. Under Cal. Civ. Code §1798.125, this is a “financial incentive.”

• Categories of PI involved: identifiers (email), inferences (ritual archetype).
• Material terms: you give us your email and consent to receive marketing emails; we deliver your ritual and may include promotional offers. You can withdraw at any time via the unsubscribe link.
• Good-faith value estimate: approximately US $5–$15 per email subscriber, based on (i) blended cost-per-lead from our paid media over the trailing 12 months and (ii) industry benchmarks for email-subscriber LTV in the wellness category. The value of the incentive is reasonably related to this estimate.
• Right to withdraw: you can opt out at any time without losing your free ritual. No discrimination for exercising any right.

California rights (CCPA / CPRA)

If you are a California resident, you have the right to:

• Know / access categories and specific pieces of PI, sources, purposes and recipients.
• Delete PI we collected, subject to exceptions.
• Correct inaccurate PI.
• Opt out of sale or sharing (see Do Not Sell or Share).
• Limit use of sensitive PI (see above).
• Non-discrimination for exercising any right.
• Data portability in a readily usable format.

Email privacy@italianresetmethod.com from the address associated with your data, or use the form on the Do Not Sell or Share page. We verify with two data points we already hold (e.g. email + most recent quiz archetype) and respond within 45 days (extendable by another 45 days where permitted). Authorized agents may submit requests with written, signed authorization and proof of identity.

California “Shine the Light”

Under Cal. Civ. Code §1798.83, California residents may request, once per year, a notice describing categories of PI shared with third parties for their direct marketing in the prior calendar year. We do not currently share PI with third parties for their own direct marketing.

Other US state privacy rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), Iowa, Indiana, Tennessee (TIPA), Florida (FDBR), Delaware (DPDPA), New Hampshire, New Jersey, Minnesota, Maryland (MODPA), Kentucky, Rhode Island and Nebraska have the right to:

• Confirm whether we process their personal data and access it.
• Correct inaccuracies and delete their data.
• Obtain a portable copy.
• Opt out of targeted advertising, sale, and certain profiling.
• Appeal a refusal within 60 days. Reply to our decision email or write to privacy@italianresetmethod.com with “Appeal” in the subject.

We honor universal opt-out signals such as Global Privacy Control where required.

EU / UK rights (GDPR)

If you are in the EU, EEA, UK or Switzerland, our legal bases are: your consent (analytics/advertising cookies, marketing emails), the performance of a contract (delivering your ritual), our legitimate interests (security, fraud prevention, service improvement) and legal obligations.

You have the right to access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. International transfers to the United States rely on the EU Standard Contractual Clauses (and the UK IDTA / Addendum). You may lodge a complaint with your local supervisory authority.

Children (COPPA & CA)

The Services are not directed to children. We do not knowingly collect PI from anyone under 13 (US COPPA). For California residents, we do not knowingly sell or share PI of consumers under 16 without opt-in. Contact us to request deletion.

Global Privacy Control

Our Services detect Sec-GPC / navigator.globalPrivacyControl and automatically treat it as a request to opt out of sale and sharing for California, Colorado, Connecticut and any jurisdiction that recognizes it.

Cookies & tracking

See our Cookie Policy. Change your preferences any time: Cookie Settings.

Security & breach

We use industry-standard administrative, technical and physical safeguards. No method of transmission over the Internet is 100% secure. We will notify affected users and authorities of a personal data breach as required by applicable law.

Do Not Track

Our Services do not respond to browser DNT signals because there is no industry standard for how to interpret them. We do honor Global Privacy Control.

Changes

We will post material changes here and update the “Effective date.” Continued use of the Services after changes take effect constitutes acceptance.

Contact

[ENTITY NAME — TBD]
[ADDRESS — TBD]
privacy@italianresetmethod.com