Privacy policy

01Who we are

Answerwell is a product in development by Holtrane. The data controller responsible for your personal data is:

Controller

Placido Falqueto

Address

Via Roma 16, 31050 Ponzano Veneto (TV), Italy

Contact

[email protected]

02What we collect

Only when you join the waitlist for Answerwell, we store:

• Your email address.
• Your answer to “Security questionnaires you answer per quarter”, if you give one (optional).
• Campaign source (UTM parameters such as utm_source) if you arrived through a tagged link — this tells us which channel brought you, not who you are.
• The language of the page you signed up on (for example English or Italian), so we can write to you in that language.
• A record of your consent: the exact consent text you agreed to, in the language it was shown, and the date and time you agreed.

We do not store your IP address or browser details with your signup.

03Why, and on what legal basis

We use your email address only to inform you about the launch of Answerwell (for example: early access, availability and pricing). The legal basis is your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time; withdrawal does not affect processing that happened before.

04How long we keep it

We keep waitlist data until we decide whether to launch Answerwell and inform you about it, and in any case for no longer than 24 months after you sign up — or until you withdraw consent, whichever comes first. Then we delete it.

05Analytics without cookies

We measure visits with PostHog (EU cloud) in cookieless mode: no cookies, no local storage identifiers and no cross-site tracking. Visits are counted with an anonymised, short-lived hash; IP addresses are not stored. We keep the campaign source of your visit in your browser’s session storage only until you close the tab, so it can be attached to a signup.

This site sets no cookies, so there is no cookie banner.

06Who processes data for us

• Cloudflare, Inc. — website hosting and the database that stores the waitlist.
• PostHog Inc. (EU cloud, Frankfurt) — cookieless, aggregated website analytics; no IP addresses stored.
• Stripe Payments Europe, Ltd. — payment processing for pre-orders (only if you choose to pre-order; Stripe handles your card details directly, we never see them).

We do not sell your data and we do not share it with anyone else.

07International transfers

Some of these providers are US companies or may process data outside the EU/EEA (for example Cloudflare’s global network). Where that happens, transfers rely on the EU–US Data Privacy Framework and/or the European Commission’s Standard Contractual Clauses.

08Your rights

Under the GDPR you can at any time:

• access the data we hold about you, and get a copy;
• have it corrected (rectification);
• have it deleted (erasure);
• withdraw your consent;
• object to or restrict processing, and ask for data portability;
• lodge a complaint with a supervisory authority — in Italy the Garante per la protezione dei dati personali (garanteprivacy.it), or the authority where you live.

09Unsubscribe or delete your data

To unsubscribe, or to have your data deleted at any time, email [email protected] from the address you signed up with. We act on requests within 30 days, usually much sooner.

10Changes

If we change this policy we’ll update the date at the top of this page. For material changes affecting how we use your email, we’ll ask for your consent again.