PRIVACY POLICY
ClarityFrameworkCo
Last updated: September 21, 2026
1. Introduction
Welcome to ClarityFrameworkCo.
This Privacy Policy explains how information may be collected, used, and processed when you visit our website, https://clarityframeworkco.com.
ClarityFrameworkCo provides information about digital workout tracking and personal trainer client management products.
Our website serves as a product information and brand presentation platform. Purchases, payments, and digital product downloads are handled separately through Etsy.
We are committed to respecting your privacy and providing clear information about how your personal data is processed.
2. Data Controller and Contact Information
This website is operated by Gabriel Giardino under the brand name ClarityFrameworkCo, based in Italy.
For questions, privacy-related requests, or concerns regarding the processing of your personal data, please contact:
Email: clarityframeworkco@outlook.it
Website: https://clarityframeworkco.com
3. Information We Collect
Our website does not currently provide user account registration, contact forms, newsletter subscriptions, or direct checkout functionality.
However, certain information may be processed automatically when you visit the website.
This may include:
- Technical information, such as your IP address, browser type, device information, and operating system.
- Website usage information, including pages visited, page views, and information associated with your interactions with the website.
- Information collected through cookies and similar technologies used by the website's hosting infrastructure.
Our hosting platform also provides website analytics, including visitor counts, page views, and information about the pages accessed.
If you contact us directly by email, we may process your email address, name, and any personal information you voluntarily include in your message.
We ask that you do not send sensitive personal information unless it is necessary for your request.
4. How We Use Information
Personal data may be processed for the following purposes:
Website operation and security
To deliver website content, maintain technical functionality, protect the website against malicious activity, and support its security and reliability.
Website analytics
To understand how visitors use the website, review general traffic patterns, and identify opportunities to improve the website's content and usability.
Communication
To respond to questions, provide assistance, and address requests sent to our contact email address.
Legal obligations
To comply with applicable legal requirements and respond to lawful requests where necessary.
5. Legal Basis for Processing
Where the General Data Protection Regulation (GDPR) applies, we rely on the following legal bases, as appropriate to the processing activity:
Legitimate interests — Article 6(1)(f)
For processing necessary to operate and secure the website, prevent abuse, respond to general inquiries, and improve the website through proportionate statistical analysis, where permitted by applicable law.
Our legitimate interests include maintaining a secure and functional website, providing relevant information to visitors, and understanding the general performance of our website.
Legal obligation — Article 6(1)(c)
Where processing is necessary to comply with applicable legal requirements.
Where consent is required for a particular processing activity or technology, that processing must be subject to the applicable consent requirements.
6. Cookies and Similar Technologies
Our website uses cookies and similar technologies associated with its hosting infrastructure.
The following cookies have been observed on the website:
__cf_bm
A Cloudflare security cookie used to help identify automated traffic and protect the website against malicious activity.
cf_clearance
A Cloudflare security cookie used to retain information about completed security checks and help visitors access the website without unnecessarily repeating those checks.
__Host-appgarden-visitor
A visitor identifier associated with the website's hosting platform. Its precise technical purpose and retention period are subject to confirmation with the hosting provider.
The website also uses the analytics functionality provided by ChatGPT Sites to display website traffic statistics.
The cookies and other technologies used by the website may change if additional functionality or services are introduced.
We will update this Privacy Policy and implement any consent mechanisms required by applicable law before introducing technologies that require such consent.
7. Service Providers
We use external service providers to operate the website and manage communications.
OpenAI / ChatGPT Sites
Our website is hosted using ChatGPT Sites, provided by OpenAI.
OpenAI may process technical information, usage data, and other information collected through the website as necessary to host, maintain, secure, and support the service.
Cloudflare
Cloudflare provides infrastructure and security services associated with the website, including protection against automated traffic and malicious activity.
Microsoft Outlook
We use Microsoft Outlook to receive and respond to email communications. If you contact us, the personal information included in your message may be processed through this email service.
Personal data may also be disclosed where required by applicable law or where necessary to establish, exercise, or defend legal claims.
8. External Links and Etsy
Our website contains links to third-party websites, including Etsy.
When you follow a link to Etsy, you leave the ClarityFrameworkCo website and interact with Etsy's platform.
Purchases, payments, digital downloads, and order-related services are handled through Etsy.
Etsy processes personal information in accordance with its own applicable privacy policies and terms.
We encourage you to review the privacy information provided by Etsy before using its services.
This Privacy Policy covers the operation of clarityframeworkco.com. It does not replace the privacy policies of third-party websites.
9. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy or to comply with applicable legal obligations.
Information received through email is retained for the period necessary to respond to the relevant request and manage any necessary follow-up, subject to applicable legal requirements.
Technical information and website usage data processed through our hosting infrastructure are subject to the applicable retention arrangements of the hosting service.
The relevant retention periods and the technical details of the hosting platform's visitor identifier are being reviewed and will be reflected in updates to this notice.
10. International Data Processing
Our website is operated from Italy, but some service providers may process information in other countries.
Where personal data is transferred outside the European Economic Area, the applicable transfer arrangements and safeguards must comply with relevant data protection legislation.
Further information about the processing arrangements applicable to ChatGPT Sites is available in OpenAI's ChatGPT Sites Data Processing Addendum.
11. Your Privacy Rights
Depending on the laws applicable to you, including the GDPR, you may have the right to:
- Request access to your personal data.
- Request correction of inaccurate personal data.
- Request deletion of your personal data where applicable.
- Request restriction of processing.
- Object to processing based on legitimate interests.
- Request data portability where applicable.
- Withdraw consent where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
To exercise your rights or submit a privacy-related request, contact:
You also have the right to lodge a complaint with a competent data protection authority.
In Italy, the relevant supervisory authority is the Garante per la protezione dei dati personali.
Website: https://www.garanteprivacy.it
12. Changes to This Privacy Policy
We may update this Privacy Policy when our website, service providers, data processing activities, or applicable legal requirements change.
Any updates will be published on this page, together with a revised "Last updated" date.
We encourage visitors to review this page periodically.
13. Contact
For any questions regarding this Privacy Policy or the processing of personal data through the ClarityFrameworkCo website, please contact:
ClarityFrameworkCo
Gabriel Giardino — Website Operator and Data Controller
Italy
Email: clarityframeworkco@outlook.it
Website: https://clarityframeworkco.com