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DEMO — Headline Grader / Template test, not a real product
Last updated 9 October 2026

Privacy policy

Plain English, no surprises. What we collect when you use demo-mvp.holtrane.com, why, and how to get it deleted.

01Who we are

DEMO — Headline Grader is a product by Holtrane. The data controller responsible for your personal data is:

Controller
Placido Falqueto
Address
Via Roma 16, 31050 Ponzano Veneto (TV), Italy
Contact
hello@holtrane.com

02What we collect

When you start a trial or buy, Stripe collects your name, email address, billing country and card details on its own checkout page. We never see or store your card details. In our own database we keep only:

  • your Stripe customer and subscription identifiers, plan, status (trial, active, canceled, refunded) and the relevant dates;
  • the language you used and the campaign that brought you (UTM parameters and, if you arrived from an ad, the ad click identifier such as gclid, msclkid or fbclid);
  • a random checkout reference that links these records together.

We can look up your name and email in Stripe when we need to (for example to answer a support request or send a legally required notice). We do not store your IP address or browser details with these records.

What you enter in the app is processed only to provide the feature you asked for.

03Why, and on what legal basis

  • Providing the service, billing and account access — performance of the contract with you (Art. 6(1)(b) GDPR).
  • Invoices and accounting records — our legal obligations (Art. 6(1)(c) GDPR).
  • Measuring which campaigns bring customers (UTM parameters and ad click identifiers, aggregated) — our legitimate interest in knowing what works (Art. 6(1)(f) GDPR). We do not send your data back to ad platforms. You can object at any time by emailing us.

04How long we keep it

Account and campaign records are kept while you are a customer and deleted at the latest 24 months after your trial or subscription ends. Invoices and payment records are kept for as long as tax and accounting law requires (in Italy, 10 years).

05Cookies and analytics

After checkout we set one strictly necessary cookie (hl_s, HttpOnly, up to 90 days) that keeps you signed in. It contains a signed reference to your account, nothing else. Strictly necessary cookies don’t require consent, so there is no cookie banner. There are no advertising or tracking cookies.

We measure visits with PostHog (EU cloud) in cookieless mode: no cookies, no local storage identifiers and no cross-site tracking; IP addresses are not stored. Checkout events (trial started, payment, cancellation) are counted in PostHog without your name, email or Stripe identifiers. The campaign source of your visit is kept in your browser’s session storage until you close the tab.

We may show you another language version of this site based on the country your connection comes from. This is decided on each visit and nothing is stored about it.

06Who processes data for us

  • Stripe Payments Europe, Ltd. — checkout, payments, subscriptions, invoices and the billing portal. Stripe processes payment data for us and, for its own legal duties (such as fraud prevention and anti-money-laundering), as an independent controller: see stripe.com/privacy.
  • Cloudflare, Inc. — website and app hosting, and the database with the records above.
  • PostHog Inc. (EU cloud, Frankfurt) — cookieless, aggregated analytics.

We do not sell your data and we do not share it with anyone else.

07International transfers

Some of these providers are US companies or may process data outside the EU/EEA. Where that happens, transfers rely on the EU–US Data Privacy Framework and/or the European Commission’s Standard Contractual Clauses.

08Your rights

Under the GDPR you can at any time access your data and get a copy, have it corrected or deleted, restrict or object to processing, ask for portability, and lodge a complaint with a supervisory authority — in Italy the Garante per la protezione dei dati personali (garanteprivacy.it), or the authority where you live. Deleting your data ends your access; invoices we must keep by law are retained until their legal period expires.

09Contact and deletion

Email hello@holtrane.com from the address you used at checkout. We act on requests within 30 days, usually much sooner.

10Changes

If we change this policy we’ll update the date at the top of this page and, for material changes, tell customers by email before they take effect.