Privacy policy
Approved by Sergio López Fuentes on 20/09/2026, without legal review and with him taking that risk. This is not legal advice. The wording is the store team's. It is approved so the waiting list can open, which is the only thing collecting data today: an email address and a consent. It does not authorise selling; that still needs the terms of sale, the shipping terms and the legal notice, which remain drafts (D-LEG-02). What is still unreviewed, written here rather than left implied: the representative in the European Union is not appointed —explained inside, where it belongs— and the retention periods are the ones the code enforces, checked byAC-LEG-22, but nobody external has said they are right. The day a lawyer reviews it, this block is replaced by their opinion. Until then it records who decided to publish it, when, and knowing what.
1. Who processes your data
Circle Club IO, a limited liability company incorporated in Delaware (United States), registered in Delaware under no. 7,839,520, with registered address at 1210 Washington Ave, suite 213, Miami Beach, FL 33139, United States, referred to below as "RaroFc". Contact: atencion@rarofc.club.
Representative in the European Union: not yet appointed. RaroFc is established outside the European Union and offers goods to people inside it, which normally requires appointing a representative in the EU. It is being arranged, and this page will be updated with their name and address as soon as it is. We say so here instead of leaving it out, because it is information you are entitled to have.
2. What data we process, why, and on what basis
| What | Why | Legal basis | For how long |
|---|---|---|---|
| Email address and purchase details (model, size, edition number, amount) | to manage the order, ship it and deal with any problems | performance of the contract | for as long as the relationship lasts and, after that, for as long as tax and accounting obligations require |
| Shipping address, name and phone number | to deliver the order | performance of the contract | same as above |
| Email address and sign-up preferences | to send you your code, tell you about launches and give you early access | consent | until you withdraw it |
| Email address from an unverified sign-up | to complete the verification | consent | 30 days, then deleted |
| Verified sign-up with no consent to news and no purchases | nothing beyond being recorded as verified | consent | 24 months |
| Random session identifier and browsing data within the store (which model, which size, which channel you came from) | to understand what works and what does not | legitimate interest in measuring our own site | 13 months |
| A copy of the emails we send you (recipient, subject and content) | to be able to show what was sent to you and when, and to sort out a «it never arrived» | legitimate interest in evidencing our own communications | 18 months from sending |
We do not use third-party cookies or external tracking tools. The session identifier is a random number that lives in your browser while the tab is open, does not identify you and is not cross-referenced with any other data.
3. Who else sees it
Only those needed to make the store work, each one under its own contract:
| Who | What for | Where |
|---|---|---|
| Stripe | taking payment. Your card details go directly to Stripe; RaroFc neither sees nor stores them | USA / EU |
| GoDaddy | hosting the website and the store | Strasbourg, France (European Union) |
| Cloudflare | DNS and the anti-bot check on the forms | global network |
| Google Workspace | the atencion@rarofc.club mailbox we reply to you from and, once email sending is switched on, the emails about your order and the news | EU |
Transfers outside the European Union. RaroFc is a US company, so the controller sits outside the EU even though the servers are inside it. The specific safeguards for those transfers —standard contractual clauses or an equivalent framework— are pending formalisation and will be detailed here. We say so instead of leaving it out.
We never sell or pass your data on to third parties for their own advertising.
4. Emails: the ones you always get and the ones you can stop
- Order emails (confirmation, dispatch, delivery, problems): they are part of the purchase and are sent even if you have not subscribed to anything. They cannot be switched off without giving up the information about your own order.
- News, launches and codes: only if you accepted by ticking a separate box, never simply because you bought something. You can unsubscribe in one click from any of those emails or from
/baja/, without giving reasons and without signing in.
Consent to the news is separate from consent to this policy: accepting one does not imply the other.
5. Your rights
You can ask us to give you access to your data, rectify it, erase it, restrict it, object to its processing or take it elsewhere. Write to atencion@rarofc.club from the address concerned.
If you ask for erasure and you have purchases, we keep the amount and the date of those purchases because tax law requires it, and we delete the rest: name, phone number, address and the email address itself, which is replaced by a value with no way back. That is: we can no longer link you to your order, but the order still exists in the accounts.
You can also complain to the Agencia Española de Protección de Datos (the Spanish Data Protection Agency, www.aepd.es).
6. Security
Everything travels encrypted (HTTPS). Payments are processed by Stripe and RaroFc does not store card details. The links we send by email — confirming your sign-up, seeing your order, unsubscribing — carry a random identifier that is single-use or has an expiry date, and the database stores only its fingerprint, not the link.
The server's technical logs do not store email addresses, phone numbers or postal addresses: only internal identifiers.
7. Minors
The store is not aimed at children under 14 and we do not knowingly collect their data.
8. Changes
If this policy changes, it is published here with a new version. The version you accepted is recorded alongside your consent and alongside each order, so that it is always possible to know which text applied to you.
---
Version of this text: 2026-09-19.