Cirello
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Privacy Policy

Last updated: 19.07.2026

This Privacy Policy explains how Cirello ("Cirello," "we," "us," or "our") collects, uses, and protects information when you visit cirello.app (the "Site").

Cirello is operated by an individual based in Ukraine. If you have questions about this policy or how your data is handled, contact us at hello@cirello.app.

1. Who This Policy Applies To

This policy applies to visitors of the Site, including anyone who joins our waitlist. It does not cover the Cirello application itself, which will have its own privacy policy once launched.

2. Information We Collect

We collect the following categories of information:

  • Email address - when you sign up for our waitlist.
  • Usage and analytics data - such as pages visited, time on page, referring site, device and browser type, and approximate location (derived from IP address), collected automatically through analytics tools.
  • Cookies and similar technologies - see our Cookie Policy for full details.

We do not knowingly collect any other personal information through the Site (for example, we do not ask for your name, phone number, or payment details on the Site).

3. How We Use Your Information

We use the information we collect to:

  • Notify you when Cirello launches or when there are updates relevant to your waitlist signup.
  • Understand how visitors use the Site so we can improve it.
  • Maintain the security and proper functioning of the Site.
  • Comply with legal obligations where applicable.

We do not sell your personal information, and we do not use your email for purposes unrelated to the waitlist without your consent.

4. Legal Basis for Processing (EEA/UK Visitors)

If you are located in the European Economic Area or the United Kingdom, our legal bases for processing your data are:

  • Consent - for waitlist signups and non-essential cookies.
  • Legitimate interest - for basic analytics needed to understand and improve the Site.

You may withdraw consent at any time by contacting us or, where technically available, adjusting your cookie preferences.

5. Third-Party Services

We may use the following categories of third-party services, which may process data on our behalf:

  • Analytics providers: [ ]
  • Email service provider (for managing the waitlist): [ ]

Each provider processes data according to its own privacy policy. We choose providers that offer reasonable data protection commitments, and we will update this section as our stack is finalized.

6. Data Retention

We retain your email address for as long as you remain on our waitlist, or until you ask us to delete it. Analytics data is retained according to the retention settings of our analytics provider, typically no longer than [ ] months.

7. Your Rights

Depending on where you live, you may have rights to:

  • Access the personal data we hold about you.
  • Correct inaccurate data.
  • Request deletion of your data.
  • Object to or restrict certain processing.
  • Request a copy of your data in a portable format.
  • Withdraw consent at any time.

This includes rights under the GDPR (EEA/UK residents) and the CCPA/CPRA (California residents). To exercise any of these rights, email hello@cirello.app. We will respond within the timeframe required by applicable law.

California residents specifically have the right to know what personal information is collected, to request deletion, and to not be discriminated against for exercising these rights. We do not sell or share personal information as defined under the CCPA/CPRA.

8. Children's Privacy

The Site is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, contact us at hello@cirello.app and we will delete it.

9. International Data Transfers

Because we operate from Ukraine and may use service providers located in other countries, your information may be transferred to and processed in countries other than your own. We take reasonable steps to ensure such transfers comply with applicable data protection law.

10. Data Security

We take reasonable technical and organizational measures to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. Material changes will be communicated via email to waitlist subscribers where appropriate.

12. Contact

For questions about this Privacy Policy or your data, contact us at hello@cirello.app.