Privacy Policy

1. Data Controller
Eric Spera, Libero Professionista
VAT: 02003100936
Address: Via Martiri della Libertà, 36 - 33082 Azzano Decimo (PN), Italy
Email: [email protected]

2. Data Collected
When you request a Raven Nightwatch (a service currently offered as a free promotion for new clients) or subscribe to one of the xRayvn plans (Brief, Growth, Mastery, under the Raven Flow umbrella), we collect the following information:

• For Raven Nightwatch: Name, Company, Industry, Website (URL), Social profiles (URL or handle), Email address.
• For subscriptions: Name, Company, URLs (yours and your competitor's), Industry, Email, and Payment data (processed securely by Stripe; we do not store full card details).

3. Purposes of Processing
Your data is processed for the following purposes:

• To generate and deliver your Raven Nightwatch (free promotion) or the strategic brief for your subscribed plan.
• To manage your subscription, billing, and automatic renewals (for paid plans).
• To send service-related communications (reports, alerts, updates, testimonial reminders).
• To improve service quality and for internal analytics.
• To comply with legal and tax obligations.

4. Legal Basis
Processing is based on:

(a) Your explicit consent for the free Raven Nightwatch and service communications.
(b) The performance of a contract for paid subscriptions.
(c) Legitimate interest for service improvement and system security.

5. Data Retention
Your data is retained for 24 months from your last interaction (Raven Nightwatch request) or subscription cancellation, unless otherwise required by law.

Data is stored on a password-protected local hard drive and on the controller's personal cloud storage, both accessible exclusively by the Data Controller.

You may request earlier deletion at any time by contacting us via email.

6. Your Rights (GDPR)
Under Regulation (EU) 2016/679 (GDPR), you have the right to:

• Access – know what data we hold about you.
• Rectification – correct inaccurate data.
• Erasure – request deletion of your data ("right to be forgotten").
• Restriction – request restriction of processing.
• Objection – object to processing on legitimate grounds.
• Portability – receive your data in a structured format.

To exercise these rights, email [email protected]. We will respond within 30 days.

7. Cookies
xRayvn uses only essential technical cookies required for site functionality (e.g., to remember your region/language preference).

We do not use tracking, profiling, or marketing cookies. No third-party cookies are installed for advertising or analytics purposes.

Therefore, no consent banner is required under GDPR or the Italian Privacy Authority guidelines.

8. Third-Party Services
We use the following third-party services to deliver our service:

• Stripe – payment processing (PCI-DSS compliant). Payment data is transmitted directly to Stripe; we do not store card details.
• Formspree – secure form handling for contact requests and Raven Nightwatch submissions.
• Cloudflare Pages – hosting and CDN (content delivery network).

We do not sell, rent, or share your data with third parties for marketing purposes.

All data processors comply with the GDPR and Standard Contractual Clauses (SCCs) where applicable.

9. Governing Law
This Privacy Policy is governed by Italian law.

The competent court for any disputes shall be the Court of Pordenone (Italy), unless otherwise required by applicable consumer protection laws.

10. Updates
We may update this Privacy Policy to reflect legal or operational changes. The latest version will always be published at this URL.

We encourage you to review this page periodically for any changes.