Privacy Policy

Last updated: April 2nd, 2025

This Privacy Policy describes how Triple 8 S.à r.l.-S, a company registered in Luxembourg with its registered office at 56, rue de Mondercange, L-4381 Ehlerange (“we”, “us”, “our”), collects, uses, and protects your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Luxembourg laws.

1. Data Controller

The data controller responsible for your personal data is Triple 8 S.à r.l.-S. You may contact us at: contact@kyrabolzan.com.

2. Types of Data Collected

We collect personal data you provide when interacting with our website, making purchases, or contacting us. This may include:
- Name and contact details
- Billing and payment information
- Login credentials and Circle.so membership activity
- IP address and browser data
- Preferences and responses to marketing emails

3. Legal Basis for Processing

We process personal data based on one or more of the following:
- Your consent (e.g., newsletter opt-in)
- Performance of a contract (e.g., product purchase)
- Legal obligations (e.g., tax compliance)
- Legitimate interests (e.g., improving services, fraud prevention)

4. Use of Data

Your data is used to:
- Fulfill orders and provide services
- Communicate important updates
- Deliver marketing emails (if consented)
- Ensure secure access to programs via Circle.so
- Analyze site traffic and usage via cookies and analytics tools

5. Data Sharing

We may share your data with trusted third-party service providers such as:
- Stripe (payment processing)
- Circle.so (community platform)
- Email marketing providers (e.g., MailerLite, ConvertKit)
These parties may store data outside the EU, in which case appropriate safeguards (like Standard Contractual Clauses) are applied.

6. Data Retention

We retain your data only as long as necessary for the purposes for which it was collected, including legal, accounting, or reporting requirements.

7. Your Rights

You have the right to:
- Access your personal data
- Correct or update inaccuracies
- Request deletion of your data (“right to be forgotten”)
- Restrict or object to processing
- Withdraw consent at any time
- Lodge a complaint with the CNPD (Luxembourg Data Protection Authority)

8. Cookies

We use cookies to improve your experience and analyze website usage. You can manage cookie settings in your browser or through the cookie banner on our site.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse.

10. International Transfers

Data may be transferred outside the EU/EEA, including to the U.S., through third-party providers. All such transfers comply with GDPR safeguards.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in law or our services. Updates will be posted on this page with the revised effective date.

12. Contact

If you have any questions about this policy or wish to exercise your data rights, contact us at contact@kyrabolzan.com.