Privacy Policy of CureComfort

CureComfort is a digital brand offering practical resources for everyday well-being, such as guides, eBooks, checklists, templates, self-support tools, organization materials, and mindfulness-inspired content.

CureComfort products are designed to provide practical and informational support, without miracle claims and without replacing professional medical, legal, psychological, financial, or other qualified advice.

The protection of personal data is important to CureComfort. For this reason, this Privacy Policy explains clearly what data is processed, for what purposes, on which legal bases, and what rights users may exercise.

1. Data Controller

The data controller responsible for the personal data collected through this website is:

Representative in the European Union / United Kingdom: not applicable, unless otherwise indicated

Data Protection Officer / DPO: not applicable, unless otherwise indicated

2. What Personal Data We Collect

CureComfort may collect different categories of personal data depending on how the user interacts with the website.

2.1 Data Provided Directly by the User

When a user makes a purchase, downloads a resource, fills out a form, subscribes to a communication, or contacts CureComfort, data such as the following may be collected:

• first and last name;
• email address;
• billing information;
• order-related information;
• messages sent to support;
• any information voluntarily entered into forms or communications.

Users are encouraged not to send sensitive data or unnecessary information, such as detailed health data, medical information, unnecessary financial information, or other particularly confidential data, unless strictly necessary for the specific request.

2.2 Data Related to Purchases and Digital Products

When a user purchases a digital product, CureComfort may process the data necessary to:

• process the order;
• confirm the payment;
• send receipts, confirmations, and transactional communications;
• deliver download links, digital materials, or reserved access;
• provide support related to the purchased product;
• manage any updates, technical issues, or post-purchase requests.

CureComfort sells digital products. Unless otherwise stated, no physical goods are shipped.

2.3 Payment Data

Payments may be handled through third-party providers, including Stripe and PayPal.

CureComfort does not store the full payment card number of the user. Payment data is processed directly by the payment providers according to their respective privacy policies, terms of service, and security measures.

Payment providers used:

• Stripe;
• PayPal;
• any other providers connected to the checkout system used.

2.4 Data Collected Automatically

When a user visits the website, certain technical information may be collected automatically, including:

• IP address;
• browser type;
• operating system;
• device type;
• pages visited;
• actions performed on the website;
• date and time of the visit;
• technical data related to browsing;
• information generated by cookies, pixels, tags, or similar technologies, where applicable.

This data may be used for security, website functionality, statistical analysis, improvement of the user experience and, only where permitted, marketing, retargeting, and advertising measurement activities.

3. Cookies, Pixels, and Similar Technologies

CureComfort may use cookies, pixels, tags, and similar technologies to:

• ensure the proper functioning of the website;
• remember the user’s technical preferences;
• analyze website usage;
• measure the performance of pages and campaigns;
• improve products, content, and communications;
• display or measure advertisements, where applicable and permitted.

Some cookies are necessary for the website to function. Others, such as analytics, marketing, advertising, or retargeting cookies, are used only where there is a valid legal basis, such as the user’s consent, where required by applicable law.

Where required by applicable law, non-essential cookies and similar technologies used for marketing, advertising, retargeting, or advanced measurement purposes are activated only after the user has given consent through the tools available on the website.

The user can manage preferences through:

• the cookie banner or preference center available on the website, where available;
• browser settings;
• any opt-out tools made available by third-party providers;
• the advertising settings of the platforms used.

For more information, please refer to the Cookie Policy:

https://www.curecomfort.com/cookie-policy

4. Meta/Facebook Ads, Meta Pixel, and Campaign Measurement

CureComfort currently promotes its digital products mainly through advertising campaigns on Meta, including Facebook and Instagram.

This means that many users may arrive on the CureComfort website after viewing or clicking on an advertisement on Facebook, Instagram, or other platforms belonging to Meta Platforms, Inc.

To measure the effectiveness of advertising campaigns, understand user behavior on the website, and optimize advertising, CureComfort may use tools provided by Meta, including Meta Pixel, conversion events, and, if configured, the Conversion API.

These tools may collect or receive information related to browsing and actions performed on the website, such as:

• viewing a page;
• visiting a sales page;
• visiting a checkout page;
• starting a purchase process;
• completing a purchase;
• interactions with content or buttons;
• technical data from the browser and device;
• IP address and online identifiers, according to the applicable technical settings;
• information needed to attribute a conversion to an advertising campaign.

This data may be used to:

• measure the performance of Facebook and Instagram campaigns;
• understand which ads, creatives, or pages generate better results;
• optimize ad delivery;
• avoid showing irrelevant ads;
• create, where permitted, custom or similar audiences;
• improve the purchase journey and advertising communication.

Where required by applicable law, the use of cookies, pixels, or similar technologies for marketing, advertising, or retargeting purposes takes place only after the user has given consent.

Main legal basis for non-essential advertising cookies, pixels, and tools: user consent.

For certain technical activities, aggregate statistics, security, or essential measurement of website functionality, CureComfort may rely on other legal bases, such as legitimate interest, within the limits permitted by applicable law.

Meta may process certain personal data according to its own terms, settings, and privacy policy. The user may also manage part of their advertising preferences through the settings of their Facebook or Instagram account, as well as through the consent tools available on the CureComfort website, where available.

The sale of CureComfort digital products takes place through the pages, funnels, or checkout systems used by CureComfort. Meta/Facebook Ads is used as an advertising and campaign measurement channel, unless expressly stated otherwise.

5. How We Use Personal Data

CureComfort uses personal data for the following purposes.

5.1 Order Management and Delivery of Digital Products

User data is used to process purchases, confirm orders, send digital materials, manage access, and provide support related to purchased products.

Legal basis: performance of a contract or pre-contractual measures.

5.2 Customer Support

Data provided by the user may be used to respond to requests, resolve technical issues, provide clarification about products, and manage post-purchase communications.

Legal basis: performance of a contract, legitimate interest, and/or consent, depending on the request.

5.3 Transactional Communications

CureComfort may send emails related to purchases, confirmations, receipts, access, downloads, technical updates, or essential information about the purchased product.

Legal basis: performance of a contract and/or legal obligation.

5.4 Email Marketing and Promotional Communications

If the user subscribes to the newsletter, downloads a free resource, or consents to receive promotional communications, CureComfort may send emails containing content, offers, updates, free resources, or information about CureComfort products.

The user may unsubscribe at any time by using the unsubscribe link included in the emails or by contacting CureComfort at:

support@curecomfort.com

Legal basis: user consent, unless another applicable legal basis is permitted by law for existing customers.

5.5 Improvement of the Website, Products, and User Experience

CureComfort may analyze aggregated, technical, or statistical data to improve:

• website navigation;
• sales pages;
• checkout;
• digital products;
• content;
• email communications;
• customer support;
• advertising campaigns.

Legal basis: legitimate interest or consent, depending on the type of data and the tool used.

5.6 Security and Abuse Prevention

CureComfort may process technical data and logs to protect the website, prevent fraud, unauthorized access, spam, misuse of services, or unlawful activities.

Legal basis: legitimate interest and/or legal obligation.

5.7 Legal, Tax, and Accounting Obligations

CureComfort may store and process data necessary to comply with tax, accounting, regulatory, or authority-related obligations.

Legal basis: legal obligation.

6. Sharing of Personal Data

CureComfort does not sell or rent users’ personal data.

Personal data may be shared only where necessary and proportionate with:

• hosting and technical infrastructure providers;
• ecommerce platforms, funnel builders, or checkout systems;
• payment providers;
• email marketing and automation tools;
• analytics services;
• advertising and measurement platforms, including Meta Platforms, Inc., when tools such as Facebook Ads, Instagram Ads, Meta Pixel, conversion events, or Conversion API are used;
• technical assistance or customer support providers;
• professional, tax, legal, or accounting consultants;
• public authorities, where required by law.

Third-party providers process data according to their respective roles: processors, independent controllers, or joint controllers, depending on the service and the specific configuration.

Main providers and tools used:

• Website / funnel platform: Systeme.io
• Checkout / ecommerce: Systeme.io
• Payments: Stripe / PayPal
• Email marketing / automations: Systeme.io
• Advertising / tracking: Meta Platforms, Inc.
• Analytics and internal statistics: Systeme.io
• Hosting / infrastructure: Systeme.io
• Customer support: CureComfort

7. Data Retention

CureComfort retains personal data only for as long as necessary for the purposes for which it was collected, unless legal obligations or legitimate needs require longer retention.

By way of example:

• data relating to purchases, orders, receipts, billing, and accounting documentation: up to 10 years, unless different obligations apply under applicable tax and accounting laws;
• data relating to customer support: up to 24 months from the last communication, unless longer retention is necessary to protect rights or manage disputes;
• data relating to email marketing and promotional communications: until consent is withdrawn, the user unsubscribes, or deletion is requested;
• technical and security data: for the time reasonably necessary to ensure security, prevent abuse, perform technical diagnostics, and maintain website integrity;
• data collected through cookies, pixels, or similar tools: according to the duration indicated in the Cookie Policy or cookie preference center, where available.

After the applicable retention period has expired, personal data is deleted, anonymized, or retained only to the extent necessary to comply with legal obligations, manage disputes, or protect legitimate rights.

8. International Data Transfers

Some providers used by CureComfort, including Systeme.io, Meta Platforms, Inc., Stripe, and PayPal, may process personal data in countries other than the user’s country of residence, including countries outside the European Economic Area, the United Kingdom, or Switzerland.

Where this occurs, CureComfort requires that the transfer take place on the basis of appropriate safeguards provided by applicable law, such as:

• adequacy decisions adopted by the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• data processing agreements;
• possible participation by providers in recognized frameworks, such as the EU-U.S. Data Privacy Framework, where applicable;
• supplementary technical and organizational measures, where necessary;
• other lawful mechanisms provided by applicable law.

The user may request further information about the applicable transfer mechanisms by contacting CureComfort at:

support@curecomfort.com

9. Data Security

CureComfort adopts reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or unauthorized disclosure.

These measures may include, depending on the tools used:

• secure connections;
• protected access to administrative accounts;
• limiting access to authorized persons only;
• use of providers with appropriate security measures;
• technical monitoring and incident management procedures;
• protection of accounts used to manage the website, orders, and communications.

No online system can be considered 100% secure. For this reason, CureComfort cannot guarantee absolute protection, but is committed to using measures proportionate to the type of data processed and the reasonably foreseeable risks.

10. User Rights

Depending on the applicable law, the user may have the right to:

• access their personal data;
• request correction of inaccurate or incomplete data;
• request deletion of data, where applicable;
• request restriction of processing;
• object to processing, including objection to direct marketing;
• request data portability;
• withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
• lodge a complaint with a competent supervisory authority.

To exercise their rights, the user may contact CureComfort at:

support@curecomfort.com

CureComfort may request additional information to verify the user’s identity before responding to the request.

The user may also lodge a complaint with the competent supervisory authority. For Italy, the competent authority is:

11. Email Marketing and Unsubscribing

If the user receives promotional communications from CureComfort, they may unsubscribe at any time by:

• clicking the unsubscribe link included in the emails;
• contacting CureComfort at support@curecomfort.com.

Unsubscribing from marketing communications does not prevent the sending of necessary transactional emails, such as order confirmations, receipts, access to purchased products, download links, or essential technical communications.

12. Sensitive Data and Health Information

CureComfort offers digital resources for informational and practical support purposes. The website and products are not intended to collect sensitive health data or detailed medical information.

Users should avoid sending health data, clinical information, or other sensitive data through forms, emails, or support communications, unless strictly necessary for the specific request.

If the user voluntarily sends sensitive information, such data will be processed only to the extent necessary to manage the communication received, in compliance with applicable law.

CureComfort content does not constitute medical advice, diagnosis, treatment, or a substitute for the relationship with qualified professionals.

13. Minors

The website and CureComfort products are not intended for individuals under the age of 18.

CureComfort does not knowingly collect personal data from minors. If CureComfort believes it has collected personal data from a minor without appropriate consent or legal basis, it will delete or restrict the processing of such data, where required by applicable law.

14. Links to Third-Party Websites

The website may contain links to third-party websites, platforms, or services. CureComfort is not responsible for the privacy practices, content, or security measures adopted by such third parties.

Users are encouraged to read the privacy policies of the third-party websites and services they visit or use.

15. Changes to This Privacy Policy

CureComfort may update this Privacy Policy to reflect legal, technical, organizational, or service-related changes.

The updated version will be published on this page with the date of the last update. In the event of significant changes, CureComfort may provide an additional notice, where appropriate.

16. Contact

For questions, requests, or concerns regarding this Privacy Policy or the processing of personal data, users may contact CureComfort at:

17. Final Note

This Privacy Policy describes how CureComfort processes users’ personal data.

Use of the website does not automatically constitute consent to processing activities based on consent, such as non-essential cookies, direct marketing, retargeting, or advertising tracking.

Such processing activities must be managed according to the methods required by applicable law and through the consent tools available on the website, where required.