Privacy Policy

Last Updated: February 12, 2026

1. Introduction

Welcome to micheletrani.com (the "Website"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

2. Data Controller

The data controller responsible for your personal information is:

  • Name: Icaro Holding, LLC
  • Address: 99 Wall Street #763, New York, NY 10005, United States
  • EIN: 36-5052776
  • Email: info@icaroholding.com
  • Website: https://www.micheletrani.com

3. Information We Collect

3.1 Information You Provide Directly

We collect information that you voluntarily provide to us when you:

Newsletter Subscription

  • Data collected: Name and email address
  • Purpose: To send you periodic newsletters and updates
  • Legal basis: Consent (GDPR Art. 6(1)(a))
  • Service provider: Resend (email delivery service)

Contact Form / Lead Collection

  • Data collected: Name, email address, phone number, and topic of inquiry
  • Purpose: To respond to your inquiries and provide requested information
  • Legal basis: Consent (GDPR Art. 6(1)(a)) and legitimate interest (GDPR Art. 6(1)(f))
  • Service provider: Resend (email delivery service)

AI Chat Assistant

  • Data collected: Chat conversation content
  • Purpose: To provide interactive assistance and answer questions
  • Legal basis: Consent (GDPR Art. 6(1)(a))
  • Service provider: OpenAI (AI processing)
  • Note: Conversations are not permanently stored on our servers but are processed by OpenAI

3.2 Automatically Collected Information

Technical Data

When you visit our website, our servers and third-party services may automatically collect certain technical information, including:

  • IP address
  • Browser type and version
  • Operating system
  • Referring website
  • Pages visited and time spent on pages
  • Device information

Analytics Data (Consent-Based)

When you consent to analytics cookies, we may collect data about how you use our website to improve our services and user experience. This may include page views, click patterns, and navigation paths.

4. Cookies and Tracking Technologies

4.1 Essential Cookies

These cookies are necessary for the website to function properly and cannot be disabled. They include:

  • Session cookies: Required for Next.js functionality and basic site operations
  • Cookie consent preferences: To remember your cookie choices

4.2 Analytics Cookies (Optional)

With your consent, we may use analytics cookies to understand how visitors interact with our website. These cookies help us improve the website experience. You can accept or decline these cookies through our cookie consent banner.

4.3 Managing Cookies

You can manage your cookie preferences through our cookie consent banner at the bottom of the page. You can also configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features may not function properly without cookies.

5. How We Use Your Information

We use the collected information for the following purposes:

  • To provide, maintain, and improve our services
  • To respond to your inquiries and provide customer support
  • To send you newsletters and updates (with your consent)
  • To process and complete your requests
  • To analyze website usage and improve user experience (with your consent)
  • To prevent fraud and enhance security
  • To comply with legal obligations

6. Third-Party Service Providers

We share your information with third-party service providers who perform services on our behalf:

6.1 Resend (Email Services)

6.2 OpenAI (AI Chat Processing)

  • Purpose: AI-powered chat assistance
  • Data shared: Chat conversation content
  • Location: USA
  • Privacy Policy: https://openai.com/policies/privacy-policy
  • Note: OpenAI may use conversations to improve their models unless you opt out through their settings

6.3 Analytics Services (Consent-Based)

With your consent, we may use analytics services to track website usage and performance. Any analytics provider will be clearly disclosed through our cookie consent banner.

7. Data Retention

We retain your personal information for the following periods:

  • Newsletter subscribers: Until you unsubscribe or request deletion
  • Contact form/lead data: Up to 2 years or until you request deletion
  • Chat conversations: Not permanently stored on our servers; processed in real-time by OpenAI
  • Analytics data: Typically 12-26 months, depending on the service used
  • Cookie consent preferences: 12 months

8. Your Rights Under GDPR (EU Users)

If you are located in the European Economic Area (EEA), you have the following rights:

  • Right to access: Request a copy of your personal data
  • Right to rectification: Request correction of inaccurate data
  • Right to erasure: Request deletion of your personal data
  • Right to restrict processing: Request limitation of how we use your data
  • Right to data portability: Request transfer of your data to another service
  • Right to object: Object to processing based on legitimate interests
  • Right to withdraw consent: Withdraw consent at any time for consent-based processing

To exercise any of these rights, please contact us at info@icaroholding.com. We will respond to your request within 30 days.

9. Your Rights Under CCPA (California Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

  • Right to know: Request information about the categories and specific pieces of personal information we collect
  • Right to delete: Request deletion of your personal information
  • Right to opt-out: Opt-out of the sale of your personal information (Note: We do not sell personal information)
  • Right to non-discrimination: We will not discriminate against you for exercising your CCPA rights

To exercise your CCPA rights, please contact us at info@icaroholding.com.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that are different from the laws of your country.

When we transfer personal data from the EEA to other countries, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses approved by the European Commission
  • EU-US Data Privacy Framework participation (where applicable)
  • Other legally approved transfer mechanisms

11. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit using SSL/TLS
  • Secure server infrastructure
  • Regular security assessments
  • Access controls and authentication
  • Use of reputable third-party service providers with strong security practices

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

12. Children's Privacy

Our website is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us, and we will delete such information from our records.

13. Do Not Track Signals

Some browsers have a "Do Not Track" feature that lets you tell websites you do not want to have your online activities tracked. We currently do not respond to Do Not Track signals.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. We encourage you to review this Privacy Policy periodically for any changes.

For material changes, we may provide additional notice (such as adding a statement to our homepage or sending you an email notification).

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at:

  • Email: info@icaroholding.com
  • Address: Icaro Holding, LLC, 99 Wall Street #763, New York, NY 10005, United States

16. Supervisory Authority

If you are located in the EEA and have concerns about our data processing practices that we have not resolved, you have the right to lodge a complaint with your local data protection supervisory authority.