Last updated: October 21, 2026
Privacy Policy
Draft template. Have it reviewed by a legal professional before going live and replace the placeholders in square brackets.
1. Who we are
The data controller is Andrea Marino, Via Ferdinando Palasciano 68, Rome, Italy. You can contact us atandreamarino756@gmail.com.
2. What data we collect
- Email address, when you start a free trial or subscribe to a plan.
- Your preferences (creators you would like to follow, intended use, role, plan preference, platforms, country), if you choose to tell us.
- Consent record: the version of the consent text you accepted and when.
- Where you came from: campaign parameters in the link you clicked (UTM, Meta click ID, referral code), the referring page, your browser language and your country, estimated from your IP address by our hosting provider. We do not store your IP address.
- Anonymous usage events (page views, button clicks) tied to a random identifier that lives only in your browser's memory for the current visit. These contain no personal data and use no cookies.
- Cookie choice: one technical cookie that remembers whether you accepted or rejected marketing cookies.
3. Why and on what legal basis
- Sending you emails about Followcap beyond your subscription, such as tips and news (your consent, art. 6(1)(a) GDPR). You can withdraw it at any time by unsubscribing from any email or writing to us.
- Delivering your paid subscription, including billing emails (performance of a contract, art. 6(1)(b) GDPR). Payments are processed by Stripe; we never see your card details.
- Understanding which messages and markets work, using the campaign parameters and anonymous events (our legitimate interest in validating the product, art. 6(1)(f) GDPR).
- Measuring our advertising with the Meta Pixel and Conversions API (your consent, given through the cookie banner). Without consent, nothing is sent to Meta.
4. Who we share data with
- Neon (database hosting, Frankfurt, European Union), as our processor.
- Vercel (website hosting), as our processor.
- Stripe Payments Europe Ltd. (payments and subscriptions), as an independent controller for payment data.
- Meta Platforms Ireland Ltd., only if you accepted marketing cookies: we send a hashed version of your email, your IP address and browser information, together with the event (signup or purchase), so Meta can attribute it to our ads. Meta acts as an independent controller for this processing; see Meta's privacy policy.
- An email provider, once we start sending the newsletter. We will update this policy when we choose one.
We never sell your data.
5. How long we keep it
For as long as you use Followcap. If you start a trial but never subscribe, we delete your email and preferences within 30 days of your request. If you cancel a paid plan, we keep billing records for the time required by tax law (10 years in Italy) and delete everything else within 12 months.
6. Your rights
You can ask us to access, correct, delete or export your data, to restrict or object to its processing, and to withdraw your consent at any time. Write toandreamarino756@gmail.com. You also have the right to lodge a complaint with your data protection authority.
7. Transfers outside the EU
Our database is hosted in the European Union. Some providers (Vercel, Meta) may process data in the United States under the EU-US Data Privacy Framework or standard contractual clauses.
8. Cookies
See our Cookie Policy.
9. Independence from Instagram and Meta
Followcap is an independent service and is not affiliated with, endorsed or sponsored by Instagram or Meta Platforms, Inc.