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⚠ Provisional draft. This is a working draft for the pre-launch phase and is not final legal text. It will be reviewed and updated before the public campaign. Fields marked [TO COMPLETE] require the operator's details.

Privacy Policy

Last updated: [TO COMPLETE — date]

This Privacy Policy explains how we collect and process your personal data when you join the CoolCup founder list at official-cool.com. We are committed to protecting your data in line with the EU General Data Protection Regulation (GDPR).

1. Who we are (Data Controller)

The data controller responsible for your personal data is:

2. What data we collect

When you join the founder list, we collect:

3. Why we process it (Purpose and Legal Basis)

We process your data to:

The legal basis for this processing is your consent (Art. 6(1)(a) GDPR), which you provide by submitting the form and confirming your subscription via the double opt-in email. You can withdraw your consent at any time (see Section 7).

4. How we collect consent (Double Opt-In)

After you submit the form, we send a confirmation email to the address you provided. Your subscription becomes active only once you click the confirmation link. This ensures we only email people who have genuinely requested to hear from us.

5. Who has access to your data (Processors)

We use trusted third-party services to operate the founder list. These act as data processors on our behalf:

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

6. How long we keep it

We keep your data for as long as you remain subscribed to the founder list, or until you ask us to delete it. If you unsubscribe, we may retain a minimal record (such as your email in a suppression list) solely to ensure we do not contact you again.

7. Your rights

Under the GDPR, you have the right to:

You can exercise these rights by emailing hello@official-cool.com, or unsubscribe instantly using the link at the bottom of any email we send. You also have the right to lodge a complaint with your local data protection authority (in Italy, the Garante per la protezione dei dati personali).

8. Changes to this policy

We may update this Privacy Policy as the project evolves toward launch. The current version will always be available at this address, with the "last updated" date shown above.