Privacy Policy

Last Updated: 15th July 2025

This Privacy Policy describes how Triple 8 S.à r.l.-S, a société à responsabilité limitée simplifiée incorporated in Luxembourg, with its registered office at 56, rue de Mondercange, L-4381 Ehlerange, Luxembourg ("we," "us," "our" or the "Company"), collects, uses, processes, and discloses your personal data when you access or use any of our websites (including www.kyrabolzan.com), digital programs, services, online content, and affiliated tools or platforms, including Kajabi and Stripe (collectively referred to as the “Services”).

By using the Services, you agree to the terms of this Privacy Policy.

1. PERSONAL DATA WE COLLECT

When you interact with our Services, we may collect the following categories of data:

Information you provide to us directly:

  • Full name

  • Email address

  • Billing address

  • Payment details (processed via Stripe)

  • Account login credentials (Kajabi platform)

  • User-generated content or feedback

  • Questionnaire or form responses

Automatically collected data:

  • IP address

  • Device identifiers

  • Browser type

  • Usage activity on our site or platform (Kajabi analytics)

  • Referral source

Sensitive data:
We do not intentionally collect sensitive personal data (e.g., health data, biometric data, religious beliefs). If such data is shared voluntarily, it will be handled in accordance with applicable data protection laws.

2. HOW WE USE YOUR INFORMATION

We use your personal data for the following purposes:

  • To deliver purchased digital products, programs, and services

  • To manage your account and user access via Kajabi

  • To process payments securely through Stripe

  • To send transactional and marketing communications (via Kajabi’s email system)

  • To provide customer support and technical assistance

  • To improve the performance and usability of our Services

  • To comply with legal obligations

We only process your data based on lawful bases under Article 6 of the GDPR, including your consent, contractual necessity, legal obligations, and our legitimate interests (e.g., fraud prevention, marketing, business analytics).

3. SHARING OF YOUR INFORMATION

We do not sell or rent your personal data to third parties. We may share your information in the following circumstances:

  • Service Providers: Kajabi (course delivery), Stripe (payment processor), Google Meet (live calls), and other GDPR-compliant processors we may work with.

  • Legal Requirements: If required by law, subpoena, or legal proceeding.

  • Business Transfers: In case of a merger, acquisition, or sale of assets.

All processors are contractually obligated to adhere to the GDPR and process data only under our instruction.

4. DATA RETENTION

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, including legal, accounting, or reporting requirements. Client purchase and engagement history may be stored for up to 7 years to comply with commercial and tax regulations.

5. INTERNATIONAL DATA TRANSFERS

Some of our service providers (e.g., Kajabi, Stripe) may transfer data outside the European Economic Area (EEA), including to the United States. In such cases, we ensure that appropriate safeguards (such as Standard Contractual Clauses or adequacy decisions) are in place to protect your data in accordance with GDPR.

6. YOUR RIGHTS UNDER GDPR

As a data subject in the EEA, you have the following rights:

  • Right to access – Request a copy of your personal data

  • Right to rectification – Correct inaccurate or incomplete data

  • Right to erasure – Request deletion of your data (where lawful)

  • Right to restrict processing – Temporarily block the processing of your data

  • Right to data portability – Receive your data in a structured, machine-readable format

  • Right to object – Object to processing, including for direct marketing

  • Right to withdraw consent – Revoke previously granted permissions at any time

To exercise these rights, please email us at [email protected]. We will respond within 30 days, as required by law.

7. SECURITY MEASURES

We implement appropriate technical and organizational security measures to protect your personal data, including:

  • Encrypted payment processing (via Stripe)

  • Secure access controls for Kajabi account portals

  • Two-factor authentication on business systems

  • Restricted access to sensitive data

While we do our best to protect your data, no system is entirely secure. Please take reasonable precautions to safeguard your login credentials and notify us immediately of any unauthorized access.

8. COOKIES & TRACKING TECHNOLOGIES

Our Website uses cookies and similar technologies to improve user experience, analyze traffic, and deliver personalized content. You may control cookie preferences via your browser settings or consent banners provided at first use.

We use:

  • Kajabi’s built-in analytics

  • Google Analytics (if applicable)

  • Email tracking pixels (inside Kajabi campaigns)

9. CHILDREN’S PRIVACY

Our Services are not intended for children under 18. We do not knowingly collect personal data from individuals under this age. If we become aware of such collection, we will delete the data promptly.

10. THIRD-PARTY LINKS

Our Services may include links to third-party websites. We are not responsible for the privacy practices of such sites. Please review their policies before submitting personal data.

11. CHANGES TO THIS POLICY

We reserve the right to update this Privacy Policy at any time to reflect changes in our Services, legal obligations, or best practices. The "Last Updated" date at the top of this page will be revised accordingly.

12. CONTACT

If you have any questions about this Privacy Policy, your data, or your rights, please contact:

Triple 8 S.à r.l.-S
56, rue de Mondercange
L-4381 Ehlerange, Luxembourg
📧 Email: [email protected]
🌐 Website: www.kyrabolzan.com