Last updated: 02/11/2025

This Privacy Policy explains how CalmRider™ (“we”, “us”, or “our”) collects, uses, and protects your personal data in compliance with:

• the General Data Protection Regulation (GDPR – EU Regulation 2016/679)

• the Italian Personal Data Protection Code (Legislative Decree no. 196/2003, as amended)

• the California Consumer Privacy Act (CCPA)

• and other applicable international privacy laws.

1. Data Controller

Name: CalmRider™

Jurisdiction: Italy

Email: calmrider@outlook.it

The Data Controller is responsible for deciding how and why your personal data is processed.

2. Types of Personal Data Collected

We collect and process the following categories of data:

Identification data

• Name, email address.

Transaction data

• Order details, transaction ID, purchase confirmation.

• Payment information is processed by third-party checkout providers (e.g. Stripe, PayPal, Shopify, ThriveCart, Gumroad, or equivalent). We do not store credit card numbers.

Technical data

• IP address, browser type, device type, approximate location.

• Security and download logs, including timestamp of file access.

Usage data

• Pages visited, funnel steps completed, clicks on call-to-action buttons, engagement with marketing campaigns and ads.

We do not intentionally collect sensitive personal data unless you voluntarily provide it (for example, in a support email).

3. Legal Bases for Processing

We process your personal data based on:

Contractual Necessity

To deliver the product(s) you purchased (for example, CALM & CONTROL™ and related digital materials), send download links, and provide support.

Consent

For marketing communications, newsletters, and retargeting (only if you opt-in or accept tracking).

Legal Obligations

To comply with tax, accounting, or legal reporting duties.

Legitimate Interest

To prevent fraud, secure our website and digital downloads, improve product experience, and protect our intellectual property.

4. Purposes of Data Processing

Your data is processed in order to:

• Complete purchases of digital training materials and printable resources.

• Deliver download links and access instructions via email.

• Provide customer support and respond to questions about product use and safety.

• Monitor unauthorized sharing of paid content and protect our IP.

• Send product updates, safety improvements, and new resources (only if you’ve opted in).

• Improve our site performance, messaging clarity, and user experience.

We do not use your personal data to make automated decisions that produce legal or similarly significant effects for you.

5. Third-Party Services

CalmRider™ partners with trusted third parties to process payments, deliver digital files, and run analytics.

Core Services (examples):

• Stripe / PayPal / other payment processors → checkout and payment handling

• Email delivery platforms → sending download links, receipts, and product access instructions

• Cloud storage / file delivery platforms → secure hosting of PDFs, worksheets, and bonus materials

• Meta (Facebook / Instagram), Meta Ads Manager, Meta Pixel → advertising analytics, retargeting, conversion tracking

• Google Analytics / Google Tag Manager → performance tracking, traffic insights

Additional Services (examples):

• Domain and email hosting providers

• Session analytics and heatmap tools to understand page performance and conversion behavior

We do not sell or rent your personal data to third parties.

Where required, we sign Data Processing Agreements (DPAs) and use appropriate safeguards.

6. Cookies & Tracking Technologies

We use cookies, pixels, and similar tracking tools to:

• Keep the website and checkout flow functioning correctly

• Remember your choices (for example, currency, region)

• Analyze page performance and conversion

• Show relevant advertising, including retargeting ads on platforms like Facebook and Instagram

You can disable or manage cookies in your browser settings.

If you reject certain cookies, parts of the site or funnel may not function optimally.

A separate Cookie Policy may provide more detail on tracking technologies.

7. Data Retention

We keep your data only for as long as needed to:

• Deliver your order and provide ongoing access to your digital materials

• Offer support and respond to customer service requests

• Satisfy legal and tax obligations (typically up to 10 years for invoicing and accounting records)

• Maintain marketing permissions until you withdraw consent (unsubscribe)

Once data is no longer required, it is securely deleted or anonymized.

8. International Data Transfers

Your data may be transferred outside the EU/EEA (for example, if our email provider or payment processor stores data in the United States or other jurisdictions).

When data leaves the EU/EEA, we use appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)

• Adequacy decisions by the European Commission

• Vendor compliance with GDPR-level protections

9. Your Rights under GDPR (EU/EEA & Italy)

If you are located in the EU/EEA (including Italy), you have the right to:

• Access your personal data

• Correct inaccurate or incomplete data

• Request deletion (“right to be forgotten”), where legally applicable

• Restrict or object to certain processing

• Request data portability (receive your data in a structured, machine-readable format)

• Withdraw consent at any time for marketing communications

You also have the right to lodge a complaint with your local Data Protection Authority.

In Italy: Garante per la Protezione dei Dati Personali — www.garanteprivacy.it

10. Your Rights under CCPA (California, USA)

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

• Know what personal data we collect and how we use it

• Request deletion of your personal data (subject to legal limitations, e.g. tax records)

• Request correction of inaccurate data

• Opt out of certain data sharing practices

CalmRider™ does not sell personal data.

We will not discriminate against you for exercising your privacy rights.

11. Exercising Your Rights

To request access, deletion, correction, or to withdraw marketing consent, you can contact us at:

calmrider@outlook.it

Please include the email address you used at checkout, so we can locate your record securely.

For your protection, we may need to verify your identity before fulfilling certain requests.

12. Data Security

We take reasonable technical and organizational measures to protect your data, including:

• Encrypted payment processing by compliant third-party providers

• SSL/TLS secure transmission

• Access controls and monitoring to prevent unauthorized access

• Download protection and abuse monitoring for digital products

No online system is 100% risk-free. By purchasing and downloading digital materials, you acknowledge that transmission of data via the internet is not completely secure.

13. Children’s Privacy

Our products are intended for adult horse owners and handlers.

In the EU/EEA: we do not intentionally collect data from anyone under 16 years old.

In the US: we do not intentionally collect data from anyone under 13 years old.

If you believe a minor provided personal data without consent, contact us at calmrider@outlook.it and we will remove it.

14. Business Transfers

If CalmRider™ is involved in a merger, acquisition, asset sale, or similar business transfer, customer data may be transferred as part of that transaction.

In that event, you will be informed if your personal data will be handled under a different privacy policy.

15. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in law, business operations, or technology.

The “Last updated” date at the top of this page shows the most recent version.

If changes are material (for example, new data usage), we will make reasonable efforts to inform you.

16. Language and Jurisdiction

This Privacy Policy is provided in English.

For EU/Italian customers, an Italian version may also be provided to satisfy local legal requirements.

In case of conflict, the version required by applicable law in your jurisdiction will control.

© 2025 CalmRider™ — All Rights Reserved.