California Privacy Notice (CCPA)

Introduction and Scope

This California Privacy Notice supplements the Capitalnuvio Privacy Policy and applies solely to visitors, users, and others who reside in the State of California ("California consumers" or "you"). We provide this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (collectively, the "CCPA"). Terms defined in the CCPA have the same meaning when used in this notice.

Categories of Personal Information Collected

The categories of personal information that Capitalnuvio has collected from California consumers during the past twelve months are: (a) identifiers such as IP addresses and email addresses; (b) personal-records information you submit voluntarily (name and message text in our forms); (c) commercial information (newsletter subscription history); (d) internet or other network activity information (browsing on our site, referring URL); (e) geolocation data of coarse precision; and (f) inferences drawn from the foregoing for the purpose of audience analytics. We do not knowingly collect biometric information, sensory data, professional or employment information, or education information.

Sources of Personal Information

We obtain the personal information described above directly from you (when you fill in a form or interact with the site), automatically from your device (when your browser requests pages and sends standard HTTP headers), and from a limited set of service providers that operate Capitalnuvio on our behalf (such as our hosting provider, edge security provider, and email-delivery vendor). We do not buy personal information from data brokers.

Business and Commercial Purposes

We use the personal information identified above for the following business or commercial purposes, in each case as described to you at the point of collection: providing the editorial product (rendering pages, sending newsletters you have opted into); responding to your messages and inquiries; operating, maintaining, securing, and improving the site; producing aggregated readership analytics; serving advertising in a non-personalized form by default and, where applicable, with your consent; detecting and responding to security incidents; and complying with our legal obligations.

Disclosure to Service Providers and Third Parties

We disclose personal information to service providers under written contract for the business purposes outlined above. These currently include: our cloud hosting provider; our content-delivery network and edge security provider; our email-delivery vendor (for newsletter distribution); our web-analytics provider; and our advertising network (where ads are displayed). Each service provider is contractually prohibited from retaining, using, or disclosing the personal information for any purpose other than the specific services it provides to us.

Sale and Sharing of Personal Information

We do not sell or share personal information in the manner described by the CCPA — that is, we do not exchange personal information for monetary or other valuable consideration with third parties, and we do not disclose personal information to third parties for the purpose of cross-context behavioral advertising. This has been true for the entire preceding twelve-month period and remains our standing policy.

Sensitive Personal Information

We do not collect or process sensitive personal information as defined by the CCPA for the purpose of inferring characteristics about you. To the extent any sensitive personal information is incidentally collected (for example, if you voluntarily disclose it in a message), we use that information only for the business purpose for which it was provided and not for any additional uses requiring further consent under the CCPA.

Your California Privacy Rights

Under the CCPA, California consumers have the following rights: (1) the right to know what personal information we have collected about you, including the categories of information, the sources, the purposes, and the categories of third parties to which we disclose it; (2) the right to access the specific pieces of personal information we hold; (3) the right to correct inaccurate personal information; (4) the right to request deletion of personal information; (5) the right to opt out of any sale or sharing of personal information (we do not sell or share, but the right exists); (6) the right to limit the use of sensitive personal information; and (7) the right to non-discrimination for exercising any of these rights.

How to Exercise Your Rights

Requests to exercise CCPA rights should be sent to Capitalnuvio via the Contact form or the email address listed on the Contact page. Because we hold only a limited amount of personal information about each consumer, verification is usually straightforward (we typically confirm access to a registered email). We aim to acknowledge requests within ten days and to substantively respond within the 45-day statutory deadline; a single 45-day extension is available when reasonably necessary and we will tell you if we need to use it.

You may also designate an authorized agent to submit a request on your behalf. We will require the agent to provide written permission from you (or a power of attorney) and may verify your identity directly to confirm the request. Agents acting on behalf of multiple consumers under a single permission must still meet the verification standards required by the CCPA for each consumer represented.

Consumers Under 16 Years of Age

California consumers under the age of 16 are entitled to additional protection under the CCPA. Capitalnuvio does not sell or share the personal information of such consumers, and we do not knowingly collect personal information from children under 13. Parents or guardians who believe their child has submitted personal information through a form on the site can contact us via our Contact form and we will delete the information promptly.

Right to Non-Discrimination

Capitalnuvio will not discriminate against you for exercising any of your CCPA rights. We will not deny you our service, charge you a different price, provide a different level or quality of service, or retaliate against you in any other way because you submitted a request under the CCPA. Because the service is free and the same for all visitors, there is no financial incentive or differential pricing structure for you to opt into or out of.

Retention of Personal Information

We retain each category of personal information only for as long as needed to fulfill the purpose for which it was collected, plus any retention required by applicable law. Specifically: newsletter subscribers' email addresses are retained until you unsubscribe (and then moved to a minimal suppression list); contact-form messages are retained for up to 24 months; server access logs are retained for up to 90 days; aggregated analytics data is retained indefinitely in non-identifying form.

Changes to This Notice and How to Reach Us

We may update this California Privacy Notice from time to time to reflect changes in our practices or in applicable law. The current version is always the one published on this page, with the "Last updated" date indicating when it became effective. For questions about this notice, or to exercise any of your CCPA rights, please contact Capitalnuvio through the Contact form linked in the site footer — that is the canonical privacy-correspondence channel for California consumers.