PRIVACY POLICY

Effective Date: June 2025

1. Introduction

– 221 Circle (“we”, “us”, or “our”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal data when you visit our website and subscribe to our private Telegram circle. We ensure full compliance with the European Union General Data Protection Regulation (GDPR) and applicable Italian privacy laws.

2. Data Controller

The data controller responsible for your personal data is:
221 Circle
Registered Address: //
Contact Email: support@221gmail.com

3. Personal Data We Collect

We collect personal data that you voluntarily provide to us, including but not limited to:

Full name
Email address
Social media usernames (if provided)

Data is collected only when you choose to provide it, such as subscribing to our Telegram circle or contacting us.

4. Purposes and Legal Basis for Processing

We process your personal data for the following purposes:

To manage and provide access to the private Telegram circle (contractual necessity)
To send newsletters, updates, and promotional communications (based on your consent)
To respond to your inquiries and provide customer support

Your consent is obtained where required, and you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

5. Data Retention

We retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. Upon your request, or if you unsubscribe or withdraw consent, your personal data will be securely deleted or anonymized, except where retention is required by law.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. Our security practices are regularly reviewed and updated.

7. Data Sharing and Transfers

We do not sell, rent, or share your personal data with third parties for their marketing purposes. Personal data will only be shared if required by law or with trusted service providers who assist in operating our services under strict confidentiality agreements.

Currently, no third-party tracking or analytics tools are used on our website.

8. Your Rights Under GDPR

You have the following rights regarding your personal data:

Right of access: Request a copy of your personal data we hold.
Right to rectification: Request correction of inaccurate or incomplete data.
Right to erasure: Request deletion of your personal data under certain conditions.
Right to restriction: Request limitation of processing under certain conditions.
Right to data portability: Receive your data in a structured, commonly used format.
Right to object: Object to processing based on legitimate interests or direct marketing.
Right to withdraw consent: Withdraw consent at any time without affecting prior processing.

To exercise your rights, please contact us at [Insert contact email]. We will respond within the timeframes prescribed by law.

9. Marketing Communications and Unsubscribing

If you have consented to receive marketing emails from us, you can opt-out at any time by clicking the unsubscribe link in any email or by contacting us directly. We respect your preferences and will not send further marketing communications once you unsubscribe.

10. Cookies and Tracking Technologies

Currently, we do not use cookies or other tracking technologies on our website.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We encourage you to review this page periodically. Any material changes will be communicated prominently.

12. Contact Information

This website is protected by reCAPTCHA. The Google Privacy Policy and Terms of Service apply.

For questions about this Privacy Policy or to exercise your rights, please contact:

Data Protection Officer
Email: [support@221circle.com]