Privacy notice

Who is responsible

The data controller is Karol Francesco Iacoe Turo, a self-employed individual, trading under the name "CHES", established in Italy, contact: email ches@ches-consistency-programme.com. Write to that address for anything about your data. There is no data protection officer: the business is one person.

What we collect, why, and the legal basis

• Website visits. Pages viewed, sections seen, how far you scroll, which buttons you click, which step of the free Score or of checkout you reached, and where the visit ended, plus your device type, the site you came from and any campaign tag in the link (utm_source and similar). This is tied to one random session ID that lives in your browser's session storage and disappears when you close the tab. It is never joined to your name, email or IP address (we do not store your IP), and we only use it in aggregate to improve the site. Legal basis: our legitimate interest in knowing how the site is used, in a way that does not identify you.
• The free Consistency Score. Your answers and scores, your first name and email, and your Discord handle if you give one. We store them so you can see your result and so Ches can follow up. Your answers are only linked to you from the moment you submit the contact step. Marketing emails go out only if you tick the separate box, and you can withdraw that with the unsubscribe link in any email. Legal basis: your consent.
• Email list and the giveaways. Your full name and Gmail address (checked against our student list to stop duplicate or alt-account entries), when and how you agreed, and which emails you've been sent. Used to send you Ches's emails and to run the draw. Legal basis: your consent, which you can withdraw any time with the unsubscribe link in every email.
• Call bookings. When you book through Cal.com: your name, email, the time, and anything you write in the notes (including the cards you picked on the homepage, if you came from there). Used to hold the call. Legal basis: the steps you asked for before a contract.
• WhatsApp and Discord. If you message Ches on WhatsApp or join the Discord, WhatsApp (Meta) and Discord handle those conversations under their own terms and privacy policies.
• The free-call form (/apply). Your first name, email and your answers, so Ches can prepare the call. Marketing emails only if you tick the separate box. Legal basis: the steps you asked for before a contract, and your consent for marketing.
• Checkout. When you press Continue in the checkout, we save your name, email and the plan you picked, paid or not, plus your two ticks (that you are 18 or over and agree to the Terms, and your request to start straight away with its 14-day acknowledgement), the version of their wording and the time, as the record of what you agreed. If you do not finish paying, we only email you about it if you ticked the marketing box. Legal basis: the steps you asked for before a contract, and our legal duty to be able to prove that record.
• Purchases. When you buy the Course, coaching or a session: your name, email, what you bought, the amount, the date and a payment reference. Used to deliver what you bought, to send your order confirmation, to keep accounts and to open your student portal. Legal basis: the contract with you and our legal duty to keep accounting records. Without these details we cannot sell you a plan.
• Withdrawals and complaints. If you use the withdrawal page or email us, what you send and when we received it. Legal basis: our legal duty to handle withdrawals and to keep a record of them.
• Students. Student accounts, journals, homework, roadmap progress, which version of the Terms you accepted or saw, and payment records (no card details) are kept to run the plan you signed up for. Legal basis: the contract with you.
• Assessment. Your trading-psychology assessment results (top priority areas and completion date). Legal basis: the contract with you.
• Referrals and partners. If you refer a friend, the friend's name and email that you give us, used only to match their purchase to you so you get the reward; we do not email them because of it. Only give us a friend's details if they are happy for you to do so. If you apply as a partner or clipper: your details, socials and payout email, used to run the programme (payout details are encrypted). Legal basis: the programme terms you accept, and for the friend's details our legitimate interest in paying the right reward.

Nothing on this site makes decisions about you by automated means that have legal or similarly significant effects.

Call recordings and AI

Coaching calls may be recorded only if the student agrees at the start of the call (legal basis: your consent, which you can withdraw at any time). Audio is kept for 24 hours, transcribed on Ches's own computer, then deleted. Ches's AI assistant uses Anthropic's Claude to summarise coaching notes and website statistics. No other AI service is used for student data.

Who processes it for us

• Supabase: database, logins and website functions (EU, Ireland)
• Cloudflare: website hosting and delivery (USA, global network)
• Resend: sending email (USA)
• Cal.com: call booking (USA)
• Anthropic: AI summaries (USA)
• Stripe: card payments and the billing portal (Stripe Payments Europe, Ireland, with transfers to the USA). Stripe handles your card details; we never see or store them. Bank transfers go straight to Ches's bank account.
• Discord and TikTok: only if you join the Discord or open a video, under their own terms
• Google Fonts (Google, USA): the Library and the assessment pages load fonts from Google, which receives your IP address and browser details when those pages open
• jsDelivr (a public code network): the assessment page loads its PDF tool from it, which receives your IP address
• Meta (Facebook and Instagram, Meta Platforms Ireland): only if you tap Accept on the cookie bar, to measure our ads (see Browser storage below)

Where data goes to the USA, the transfer relies on the EU-US Data Privacy Framework where the provider is certified, or on the European Commission's Standard Contractual Clauses.

How long we keep it

• Website visit data: 13 months, then deleted.
• Email list: until you unsubscribe. After that only the unsubscribe record is kept, so you aren't emailed again by mistake.
• Draw records: 2 years.
• Your checkout ticks, order confirmation and any withdrawal: with the purchase record, as long as tax and consumer law require (in Italy, generally 10 years).
• Call recordings: 24 hours (audio). Student records: for as long as your plan runs and then as long as the law requires. Payment records: as long as tax law requires.
• Score answers, free-call answers and unfinished checkouts of people who never bought: until you ask us to delete them. A fixed deletion period for these is being set up; until it is, ask at any time and we delete them.

Your rights

You can ask to access, correct, delete or export your data, to restrict its use, to object to its use (including at any time to direct marketing), or to withdraw your consent, by emailing the address above. Withdrawing consent does not affect what was done before. We answer within one month. You can also complain to the Italian data protection authority, the Garante per la protezione dei dati personali, or to the authority where you live.

Under 18s

CHES sells only to adults (18 or over) and the site is not meant for children. If you are under 14, please do not give us your email; if we learn we hold the details of someone under 14, we delete them.

Browser storage and cookies

The site stores a few small values in your browser: a random session ID for the statistics above (cleared when you close the tab), your portal login, whether you've closed or completed the email popup or a notice, your progress on the swipe cards, your cookie choice, and, if you arrived through a partner's link (?ref=CODE), that code for this visit (for 60 days only if you tap Accept) so the partner is credited if you buy. The full list is on the cookie page.

If you tap Accept on the cookie bar, the site also loads the Meta Pixel. It sets Meta cookies and tells Meta that this browser viewed the Score, saved a Score, opened checkout or paid, with the price, so we can see which ads help people and show them to similar people. It does not send your name, email or answers. Tap No thanks and it never loads. Only if you tapped Accept, our server may also send Meta the same events (Score saved, checkout opened, paid) through Meta's Conversions API, with your email address as a one-way hash and the Meta click ID from your ad link, so each event is counted once. Without Accept, nothing is sent to Meta. For collecting and sending these events, Ches and Meta Platforms Ireland are joint controllers under Meta's Controller Addendum; what Meta does with them afterwards is Meta's own responsibility, described in Meta's privacy policy. Legal basis: your consent. Change your mind any time with Cookie settings (also in every page's footer).

Changes

If this notice changes, the date at the top changes too.