Privacy Policy

1. Who We Are

CiaoLorenzo is operated by Julian Ramirez, a sole proprietor based in California, United States. We are the data controller for the personal data described in this policy.

If you have any questions about how we handle your data, you can reach us at:

2. What Data We Collect

Data you provide

• Telegram user ID — automatically shared when you message Lorenzo through Telegram.
• Conversation messages — the text you send to Lorenzo during coaching sessions.
• Email address — if you join our waitlist, contact support, or receive purchase receipts via Paddle.

Data generated during use

• Coaching responses — Lorenzo's replies to your messages.
• Correction history — records of grammar and vocabulary corrections.
• Learning progress metrics — aggregated data about your improvement over time.

Data we do NOT collect

• Your real name (unless you choose to share it in conversation)
• Your phone number
• Your location
• Credit card or payment details — Paddle handles this entirely

3. How We Use Your Data

We only use your data for the purposes listed below, along with the legal basis for each:

• Managing waitlist updates — sending launch notifications and product updates to users who opt in via the website waitlist form.
  Legal basis: consent.
• Providing the coaching service — delivering conversation prompts, corrections, and lessons through Telegram.
  Legal basis: contract performance.
• Generating AI responses — processing your messages through AI models to create personalized coaching responses.
  Legal basis: contract performance.
• Improving the product — anonymized and aggregated analytics to understand how learners use CiaoLorenzo and make it better for everyone.
  Legal basis: legitimate interest.
• Responding to support requests — if you email us with questions or issues.
  Legal basis: legitimate interest.
• Processing payments — handled entirely by Paddle, who acts as an independent data controller for payment data.
  Legal basis: contract performance.

4. Who We Share Data With

We work with a small number of trusted partners to provide the CiaoLorenzo service. Here is every third party that may receive your data:

• Buttondown — waitlist email collection and delivery of launch notifications. Buttondown acts as a data processor for waitlist communications.
• Paddle.com Market Limited — payment processing, invoicing, and tax collection. Paddle acts as the merchant of record and is an independent data controller for payment data. See Paddle's Privacy Policy.
• Anthropic (Claude API) — processes your conversation messages to generate coaching responses and question prompts. Anthropic acts as a data processor on our behalf.
• Google — processes data for image and audio file generation used in coaching. Google acts as a data processor on our behalf.
• Telegram — the messaging platform through which CiaoLorenzo operates. Telegram is an independent data controller for its own platform data.

We do NOT sell your data. We do NOT share your data with advertisers.

5. International Data Transfers

CiaoLorenzo's data controller is based in the United States. If you are located in the EU or elsewhere outside the US, your data is transferred to the US for processing.

Anthropic and Google process data in the United States. Paddle has its own international transfer mechanisms in place. Where applicable, appropriate safeguards such as standard contractual clauses are used to protect your data during international transfers.

6. How Long We Keep Your Data

• Conversation history is retained while your account is active, so CiaoLorenzo can maintain coaching continuity and track your progress.
• Anonymized analytics are retained indefinitely to help us improve the product.
• Deletion requests are processed within 30 days of receiving your request.
• Account data is removed when your subscription ends and any applicable refund window has passed.

7. Your Rights

Under the GDPR, you have the right to:

• Access your personal data — request a copy of what we hold about you.
• Rectify inaccurate data — ask us to correct any errors.
• Erase your data — also known as the "right to be forgotten."
• Restrict processing — ask us to limit how we use your data.
• Data portability — receive your data in a structured, machine-readable format.
• Object to processing based on legitimate interest.

To exercise any of these rights, email us at legal@ciaolorenzo.com. We will respond to your request within 30 days.

8. Right to Lodge a Complaint

If you are unsatisfied with how we handle your data, you have the right to lodge a complaint with your local data protection supervisory authority.

For a list of EU data protection authorities, visit the European Data Protection Board (EDPB) website.

9. Cookies and Tracking

This is a static website built with Astro. We do not use cookies for tracking or analytics. There are no third-party tracking scripts on this site.

If you submit the waitlist form, Buttondown may set technical cookies or process metadata needed to prevent abuse and deliver emails.

Paddle may set cookies during the checkout process to facilitate payment. For details, refer to Paddle's Cookie Policy.

10. US State Privacy Rights

If you are a resident of certain US states (including California), you may have rights to know what personal information we collect, request deletion, and request correction of inaccurate personal information.

To submit a rights request, email legal@ciaolorenzo.com. We will verify your request and respond within the timeframe required by applicable law.

We do not sell personal information and we do not share personal information for cross-context behavioral advertising.

11. Children's Privacy

CiaoLorenzo is not directed at children under 16. We do not knowingly collect personal data from children. If we learn that we have collected data from a child under 16, we will delete it promptly.

12. Changes to This Policy

We may update this privacy policy from time to time. If we make material changes, we will notify you through the service.

The "Last updated" date at the top of this page reflects the most recent revision. Your continued use of CiaoLorenzo after changes take effect means you accept the updated policy.

13. Contact Us

If you have any questions about this privacy policy or how we handle your data, we'd love to hear from you.

See also our Terms of Service and Refund Policy.