Privacy Policy

Section 1Who We Are

Crush-Debt is operated by Antonino Maisano, Via Benaco 26, 25017 Lonato del Garda (BS), Italy.

We are the data controller for the personal data described in this policy. That means we decide what is collected and why, and we are the ones you hold responsible for it.

Because we are established in Italy, the General Data Protection Regulation (GDPR) applies to everything we do, including our dealings with customers outside Europe.

You can reach us at any time at info@crush-debt.com.

Section 2What We Collect

We collect only what we need in order to sell you a digital file and deliver it.

When you buy something

• Your first and last name
• Your email address, which is where the product is delivered
• Your billing country, and any billing address details required by our payment provider
• A record of your order: what you bought, the amount, the date, and the transaction reference

When you visit the site

• Technical data your browser sends automatically, such as IP address, browser type and device type
• Cookie identifiers, described in Section 8

When you write to us

• The content of your message and the address you sent it from, so we can answer

Section 3Why We Use It, and on What Legal Basis

Under the GDPR we have to tell you not only what we do with your data but on what legal ground. These are ours.

• To deliver what you bought and to handle refunds and support. Legal basis: performance of our contract with you.
• To keep accounting and tax records of the sale. Legal basis: compliance with a legal obligation.
• To prevent fraud and keep the site working. Legal basis: our legitimate interest in not being defrauded.
• To send you marketing emails about our other products. Legal basis: your consent, or our legitimate interest in contacting an existing customer about similar products. You can withdraw at any time, as described in Section 9.

We do not sell your personal data, and we do not rent or trade your email address. No exceptions, and no separate arrangement with anyone.

Section 4Payment Data

Card details are entered directly into a form served by our payment provider and go straight to them. What comes back to us is limited to what we need to recognise the order: whether the payment succeeded, the amount, the currency, the date, and the last four digits with the card brand.

Our payment providers are Stripe and PayPal. Each of them is an independent data controller for the payment itself and applies its own privacy policy to that part.

Section 5Who Else Sees Your Data

We share your data only with the suppliers that make the sale possible, and only to the extent that they need it. Each of them acts on our instructions under a written agreement.

• Systeme.io, operated by ITACWT Limited (Ireland), which hosts our pages, processes checkout and sends our emails.
• Stripe and PayPal, which process payments.

Beyond that, we disclose personal data only where the law requires it, for example in response to a valid order from a public authority, or where it is necessary to establish or defend a legal claim.

Section 6Where Your Data Is Stored

Our site and customer records are hosted by Systeme.io, which states that customer data is stored on Amazon Web Services infrastructure in Ireland, encrypted, and not transferred outside the European Union.

Our payment providers operate internationally and may process data outside the European Economic Area. Where that happens, they are required to use a recognised legal transfer mechanism, such as the European Commission's Standard Contractual Clauses.

If you are writing to us from the United States, this means your data is held in Europe under European rules, which are generally stricter than those you are used to.

Section 7How Long We Keep It

• Order and payment records: for as long as tax and accounting law requires us to keep them, which in Italy is ten years from the end of the relevant financial year.
• Your email address on our mailing list: until you unsubscribe or ask us to delete it.
• Support emails: normally no longer than twenty four months after the matter is closed.
• Cookie and technical data: for the lifetime of the cookie, as set out in Section 8.

When a retention period ends, we delete the data or anonymise it so it can no longer be linked to you.

Section 8Cookies

A cookie is a small file a website stores in your browser. We use as few as we can.

Strictly necessary cookies

These are set by Systeme.io and by our payment providers. They keep your session alive, remember what is in your order while you complete it, and protect the checkout against fraud. The site cannot function without them, and they are not used to profile you.

Analytics and advertising cookies

If you consent, we may also use analytics and advertising cookies to understand how our pages perform and to measure our advertising. These are not strictly necessary, and you can refuse them without losing access to anything on this site.

You can delete cookies already stored, and block new ones, from your browser settings. Blocking strictly necessary cookies will stop the checkout from working.

Section 9Marketing Emails

If you buy from us or ask us to, we may email you about our other products.

Every marketing email we send carries an unsubscribe link. One click and it stops, with no reply needed and no reason asked. You can also write to info@crush-debt.com and we will remove you by hand.

Unsubscribing from marketing does not stop transactional messages, which are the emails that deliver what you bought, confirm a refund or answer a question you asked us.

Section 10Your Rights in the European Union and the United Kingdom

Because we are established in Italy, these rights are available to you under the GDPR:

• Access: to be told whether we hold data about you, and to receive a copy.
• Rectification: to have inaccurate data corrected.
• Erasure: to have your data deleted, except where we are legally required to keep it, which mainly concerns invoices.
• Restriction: to have us pause our use of your data while a dispute is resolved.
• Portability: to receive your data in a machine readable format.
• Objection: to object to processing based on legitimate interest, including direct marketing, which we always stop on request.
• Withdrawal of consent: at any time, without affecting what was lawful before you withdrew it.

Write to info@crush-debt.com to exercise any of these. We answer within one month. We do not charge for this.

If you believe we have mishandled your data you can complain to a supervisory authority. In Italy that is the Garante per la protezione dei dati personali. In the United Kingdom it is the Information Commissioner's Office.

Section 11Your Rights in California and Other US States

If you are a resident of California, or of another state with a comparable privacy law, you have the right to know what personal information we have collected about you, to request its deletion, to request correction, and not to be discriminated against for exercising any of these rights.

To make a request, write to info@crush-debt.com from the address you used at checkout, or tell us which address you used, so we can find your record. We may ask one follow up question to confirm it is really you, and nothing more.

Section 12Children

Our products are for adults. We do not knowingly collect personal data from anyone under 16. If you believe a child has given us their data, write to us and we will delete it.

Section 13Security

Our pages are served over an encrypted connection, and customer records sit with providers who encrypt data at rest and hold recognised security certifications. Access on our side is limited to the people who need it in order to run the business.

No system is perfectly secure, and we will not claim otherwise. What we can tell you is that the most sensitive data in an online purchase, the card number, is one we never hold.

Section 14Changes to This Policy

If we change how we handle your data we will update this page and change the date at the bottom. If a change is significant and affects data we already hold about you, we will tell you by email.