Privacy Policy

Effective date: [Effective Date]

This Privacy Policy explains how Consigliere LLC ("the Company", "we", "us", or "our"), a Nevada limited liability company to be formed, collects, uses, and shares information in connection with The Consigliere, a paid subscription content product available at theaiconsigliere.com (the "Website") and delivered to subscribers (the "Service"). By using the Service, you acknowledge the practices described in this Policy.

1. Information We Collect

We aim to collect only the information we need to provide the Service.

• Account information. When you create an account, we collect your name and email address, and account details such as your subscription status and preferences.
• Billing information. When you subscribe, payment is processed by Stripe. Stripe collects and handles your payment details. We do not store full payment card numbers. We may receive limited billing-related information from Stripe, such as a confirmation of payment, the last four digits of a card, an expiration date, a billing name, and a billing country or postal code, as applicable.
• Communications. If you contact us or opt in to receive communications, we collect the information you provide and a record of our correspondence.
• Website usage information. When you visit the Website, we and our service providers may collect standard technical and usage information, such as IP address, device and browser type, pages viewed, and referring pages, through cookies and analytics as described below.

We do not require or solicit your own client data to deliver the Service, and we ask that you do not send us your clients' confidential or personal data.

2. How We Use Information

We use the information we collect to:

• provide, operate, and deliver the Service, including sending you subscription documents and special editions;
• create and manage your account and process your subscription and payments;
• respond to your inquiries and provide support;
• send you communications that you have agreed to receive, such as service-related messages and, where you have opted in, other updates;
• operate, maintain, secure, and improve the Website and the Service;
• detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms; and
• comply with legal obligations and enforce our agreements, where applicable.

We send only communications that you have agreed to. We do not engage in automated outreach.

3. Legal Bases for Processing (Where Applicable)

Where data protection laws such as the GDPR apply, we rely on the following legal bases, as applicable: performance of a contract with you (to provide the Service you subscribe to); your consent (for example, for certain communications or non-essential cookies), which you may withdraw at any time; our legitimate interests (such as securing and improving the Service), balanced against your rights; and compliance with legal obligations. Where we rely on consent, you may withdraw it without affecting the lawfulness of prior processing.

4. Sharing and Third-Party Processors

We do not sell your personal information. We share information only as described here.

• Payment processor. We share billing-related information with Stripe to process your subscription payments. Stripe handles your payment details under its own terms and privacy policy.
• Service providers. We may share information with vendors who help us operate the Service, such as hosting, email delivery, customer support, and analytics providers, who are permitted to use the information only to perform services for us.
• Legal and safety. We may disclose information where required to comply with applicable law, legal process, or a lawful request, or to protect the rights, property, or safety of the Company, our users, or others.
• Business transfers. If the Company is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a successor policy.

5. Cookies and Analytics

The Website may use cookies and similar technologies to operate the site, remember preferences, and understand usage. We may use analytics providers to help us measure and improve Website performance. Depending on your location and settings, some cookies may require your consent. You can usually control cookies through your browser settings, and where applicable we provide a cookie notice or preference mechanism. Disabling some cookies may affect how the Website functions.

6. Data Security

We maintain reasonable administrative, technical, and organizational measures designed to protect the information we hold against unauthorized access, use, alteration, or disclosure. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

7. Data Retention

We retain personal information for as long as needed to provide the Service, maintain your account, and fulfill the purposes described in this Policy. We retain account information for the duration of your subscription and for [Account Data Retention Period] after your account is closed. We retain billing-related records for [Billing Records Retention Period], where applicable, to meet tax, accounting, and legal requirements. We may retain limited information longer where required by law or to resolve disputes and enforce our agreements. When information is no longer needed, we delete or anonymize it using reasonable measures.

8. Your Rights

Depending on your location, you may have rights over your personal information, which we honor where applicable. These may include the right to access the information we hold about you; to request correction of inaccurate information; to request deletion; to object to or restrict certain processing; to data portability; and to opt out of certain communications or, where applicable, the sale or sharing of personal information (we do not sell personal information). You may also opt out of marketing communications at any time by using the unsubscribe mechanism in our emails or by contacting us.

For subscribers in the European Economic Area, the United Kingdom, or similar jurisdictions (GDPR style), you may exercise the rights described above and may lodge a complaint with your local data protection authority. For residents of California and similar jurisdictions (CCPA style), you may have the right to know, access, delete, and correct personal information, and to opt out of the sale or sharing of personal information, and we will not discriminate against you for exercising these rights.

To exercise any of these rights, contact us at privacy@theaiconsigliere.com. We will respond within the timeframe required by applicable law. We may need to verify your identity before acting on your request, and some rights may be subject to legal limits or exceptions.

9. Children's Data

The Service is intended for adults and is not directed to children. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected such information without appropriate consent, we will take reasonable steps to delete it. If you believe a child has provided us with personal information, please contact us at privacy@theaiconsigliere.com.

10. International Transfers

We are based in the United States, and the information we collect may be processed and stored in the United States or in other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your country. Where required by applicable law, we take steps to provide an appropriate level of protection for international transfers, such as using recognized transfer mechanisms.

11. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will take reasonable steps to notify you, such as by posting the updated Policy on the Website with a new effective date or, where appropriate, by sending a notice to the email associated with your account. Your continued use of the Service after the effective date indicates your acknowledgment of the updated Policy.

12. Contact

If you have questions about this Policy or our privacy practices, please contact us at privacy@theaiconsigliere.com, Consigliere LLC, [Mailing Address, pending entity formation].