Privacy Policy
Last updated: [DATE] · Reviewed by: [LEGAL REVIEWER]
Who we are
The data controller is [FULL LEGAL NAME], [STREET ADDRESS], [CITY + POSTCODE], Italy, VAT [P.IVA], trading as chl.renders. You can reach us at hello@chlrenders.com for anything on this page.
We have not appointed a Data Protection Officer; we are not required to.
What this site is
This is a waitlist for a product that does not exist yet. There is no shop, no account, no payment. The only thing you can give us is an email address.
What we collect, and why
| Data | Why | Lawful basis | Kept for |
|---|---|---|---|
| Email address | To email you when the drop happens | Consent — GDPR art. 6(1)(a) | Until you unsubscribe, or 24 months of no drop |
| Age confirmation (that you ticked "14 or older") | Italian law sets the digital-consent age at 14 | Legal obligation — art. 8 GDPR, art. 2-quinquies Codice Privacy | Same as above |
| Timestamp of your consent | To be able to prove consent was given, and when | Legal obligation — art. 7(1) GDPR | Same as above |
| Waitlist position and referral code | To run the waitlist and the referral mechanic | Consent, as above | Same as above |
| Your IP address, briefly | Rate limiting, so the form cannot be spammed | Legitimate interest — art. 6(1)(f) | 60 seconds, then deleted automatically |
| Survey answer, if you write one | To find out what nearly put you off | Consent — you choose to type it | 24 months, not linked to your email |
| Aggregate page analytics | To know whether the page works | Legitimate interest — art. 6(1)(f) | See "Analytics" below |
Double opt-in
After you submit the form we email you a confirmation link. Until you click it you are not on the mailing list and we will not send you anything else. If you never click it, the record is deleted after 30 days.
Analytics
We run analytics in three layers, and they are deliberately different from one another.
1. Our own server logs
When you submit the form, our server records that a signup happened, which waitlist position it got, which copy variant you saw, and where the click came from. This is our own record of our own transaction with you. It does not involve cookies and is not shared.
2. Cookieless analytics — no cookies, no consent banner
We use PostHog (EU region) and Vercel Web Analytics to count page views and see how far people get through the page. Both are configured to store nothing at all on your device — no cookies, no local storage — and PostHog is set not to record your IP address. We do not use them to track you across other websites.
Because nothing is stored on or read from your device, the consent requirement in art. 5(3) of the ePrivacy Directive is not triggered, and we rely on legitimate interest for the processing itself. You can object to this at any time by emailing us, or by turning on "Do Not Track" / "Global Privacy Control" in your browser, which we honour.
3. Microsoft Clarity — only if you say yes
Clarity records anonymised session replays and heatmaps, and it does set cookies. It is switched off until you press "Allow" on the bar at the bottom of the page. If you press "No thanks", or ignore it, it never loads. You can change your mind any time via Cookie settings in the footer. Details are in the Cookie Policy.
Who else sees your data
- Brevo (Sendinblue SAS, France) — sends the emails and stores the list. EU-hosted.
- Vercel (Vercel Inc., USA) — hosts the site and the database. Transfers covered by Standard Contractual Clauses.
- PostHog — EU region (eu.i.posthog.com), data stays in the EU.
- Microsoft Clarity (Microsoft Corp., USA) — only if you consented. Transfers under the EU–US Data Privacy Framework.
We do not sell your data, and we do not share it with advertisers.
Your rights
You can ask us to show you, correct, delete, or export your data, and you can withdraw consent at any time — withdrawing does not affect anything we did before you withdrew. Every email we send has a one-click unsubscribe link. To exercise any right, email hello@chlrenders.com; we answer within 30 days.
If we get it wrong you can complain to the Italian supervisory authority, the Garante per la protezione dei dati personali.
Children
This site is not for under-14s. We ask you to confirm your age and we do not knowingly keep data from anyone younger. If you believe a child has signed up, email us and we will delete it.
Changes
If we change this policy we will update the date at the top. If the change is significant and you are on the list, we will email you.