Privacy Policy
1. Who processes your data
The controller of your personal data is Newport Group USA Inc, owner of racowski.com and of the products and services offered on it.
You can contact us about anything relating to your data at jose@racowski.com.
This policy explains what data we collect, what we use it for, who we share it with and what you can require from us. It applies to racowski.com and our associated domains and platforms.
2. What data we collect
Data you give us
- Identification and contact: first name, surname, email address and, where you provide them, phone number, country, job title and organisation.
- Purchase data: products bought, amount, currency, date and transaction status. We do not receive or store your full card details: these are processed entirely by the payment platforms.
- Content you post: messages, comments and contributions in the community or in live sessions.
- Communications: emails and messages you send us, including those sent via social media or WhatsApp.
- Form responses: surveys, diagnostics, pre-work questionnaires and satisfaction reviews.
Data collected automatically
- Device and browsing data: IP address, browser and device type, operating system, language, time zone and pages visited.
- Usage data: how you reached the site, which links you click, how long you stay and which content you consume.
- Campaign data: tracking parameters (utm) and advertising identifiers that tell us which ad or channel brought you.
- Email interaction: whether you open an email and whether you click its links.
3. Why we use it and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Process your purchase and give you access | Identification, contact, purchase | Performance of a contract |
| Provide support and answer your questions | Contact, communications, purchase | Contract and legitimate interest |
| Run the membership and the community | Identification, posted content | Performance of a contract |
| Send you the newsletter and educational emails | Email, name, interaction | Consent, withdrawable at any time |
| Tell existing customers about related products | Email, purchase history | Legitimate interest, with opt-out always available |
| Measure site usage and improve content | Browsing, usage | Consent for analytics cookies |
| Measure and optimise our advertising | Usage, advertising identifiers | Consent for advertising cookies |
| Prevent fraud and misuse | Device, purchase, usage | Legitimate interest |
| Meet accounting, tax and legal obligations | Purchase, identification | Legal obligation |
Where the legal basis is consent, you can withdraw it at any time, without affecting the lawfulness of processing before withdrawal. For the newsletter, the unsubscribe link in every email is enough.
4. Who we share it with
We do not sell your personal data. We share it only with providers who deliver services we need in order to operate, each with access limited to what they need:
| Provider | Purpose | Data processed |
|---|---|---|
| Hotmart | Payment processing and product delivery | Identification, contact, purchase |
| Stripe | Payment processing | Identification, contact, purchase |
| MailerLite | Email delivery and list management | Email, name, email interaction |
| Substack | Editorial newsletter delivery | |
| Resend | Transactional access and support emails | Email, name |
| Mighty Networks | Hosting the community and its content | Identification, posted content |
| Supabase | Customer and sales database | Identification, contact, purchase |
| Google Analytics | Site usage statistics | Browsing, usage, identifiers |
| Meta (Facebook and Instagram) | Advertising measurement and targeting | Usage, advertising identifiers |
| ManyChat | Automated conversations on Instagram | Platform identifier, messages |
| Hostinger | Website hosting | Technical connection data |
| Zoom, Google Meet or equivalent | Live sessions and mentoring | Name, email, image and voice if you turn on camera or microphone |
We may also disclose data to accounting or legal advisers, and to authorities where there is a legal obligation, a court order, or a need to defend our rights.
If a merger, acquisition or sale of assets were to occur in the future, your data could be transferred to the acquiring entity, which would remain bound by this policy.
5. Cookies and tracking technologies
A cookie is a small file stored on your device when you visit a site. We use three kinds:
- Necessary: these make the site work and remember your basic preferences. The site cannot operate properly without them, so they do not require consent.
- Analytics: these tell us which pages are visited and how people navigate, in aggregate, so we can improve the content. We use Google Analytics.
- Advertising: these let us measure how well our ads work and show relevant advertising. We use the Meta pixel.
You can manage or delete cookies from your browser settings, and enable a do-not-track signal. Note that blocking necessary cookies may affect how the site works.
To opt out of Google Analytics generally, there is a Google opt-out browser add-on. For Meta advertising, you can adjust your preferences in your account settings.
6. International transfers
We are a United States company and several of our providers operate in the United States, Brazil and the European Union. This means your data may be processed outside your country of residence, in jurisdictions whose data protection law may differ from yours.
Where the law requires it, those transfers rely on recognised mechanisms, such as the standard contractual clauses approved by the European Commission or the equivalent safeguards set out in applicable law.
7. How long we keep it
- Purchase and billing data: for the period required by applicable accounting and tax law, typically between 5 and 7 years.
- Product and membership access data: for as long as your access lasts, plus a reasonable period afterwards to handle any claims.
- Newsletter data: until you unsubscribe, plus a minimal record of the unsubscribe so we do not email you again.
- Content posted in the community: while the community is active or until you request its deletion.
- Analytics and advertising data: according to each platform's retention periods, typically between 14 and 26 months.
Once those periods end, data is deleted or irreversibly anonymised.
8. Your rights
Wherever you live, you can exercise the following rights:
- Access: find out what data of yours we process and obtain a copy.
- Rectification: correct inaccurate or incomplete data.
- Erasure: ask us to delete your data when it is no longer needed.
- Restriction: ask us to restrict processing in certain circumstances.
- Portability: receive your data in a structured, commonly used format.
- Objection: object to processing based on legitimate interest, including direct marketing.
- Withdraw consent: at any time, where consent is the basis for processing.
To exercise them, write to jose@racowski.com stating which right you wish to exercise. We will respond within 30 calendar days of your request. We may ask you to verify your identity first.
Exercising these rights is free, except for manifestly unfounded or excessive requests.
9. Rights by country in Latin America
Our audience is largely Latin American, so we honour the rights granted to you by your local law, including:
- Chile: Law 19.628 on the protection of private life and Law 21.719, which strengthens those rights and creates the Personal Data Protection Agency.
- Brazil: the General Data Protection Law (LGPD, Law 13.709), including the rights of confirmation, access, correction, anonymisation, portability and deletion, before the ANPD.
- Mexico: the Federal Law on Protection of Personal Data Held by Private Parties, with the ARCO rights of access, rectification, cancellation and objection.
- Colombia: Law 1581 of 2012 and its implementing rules, before the Superintendency of Industry and Commerce.
- Argentina: Law 25.326 on the protection of personal data, before the Agency for Access to Public Information.
- Peru, Ecuador, Uruguay and other countries: the rights granted by their applicable law.
The route to exercise them is the same: jose@racowski.com.
10. California residents
If you live in California, state law (CCPA and CPRA) gives you the right to know what categories of personal data we collect and why, to request its deletion or correction, and not to be discriminated against for exercising those rights.
We do not sell your personal data and we do not share it for monetary consideration. The use of advertising cookies may be treated as "sharing" for cross-context behavioural advertising under that law; you can prevent it by rejecting advertising cookies in your browser or adjusting your Meta preferences.
11. Security
We apply reasonable technical and organisational measures to protect your data: encryption in transit via HTTPS, access controls, credentials managed outside public code, and providers that meet recognised industry standards.
No transmission over the internet is completely secure, so we cannot guarantee absolute security. If a security breach affecting your data occurred and posed a risk to your rights, we would notify you and inform the competent authority where the law requires it.
12. Children
Our products are aimed at professionals and are not intended for anyone under 18. We do not knowingly collect children's data. If we find we have received data from a minor without the required authorisation, we will delete it. If you believe this has happened, please write to us.
13. Automated decisions
We use automated segmentation to decide which emails you receive, based on the products you have bought or the materials you have downloaded. We do not make automated decisions producing legal effects concerning you or similarly significantly affecting you. You can object to that segmentation by writing to us.
14. Changes to this policy
We may update this policy when our services, our providers or applicable law change. The version in force is always the one published on this page, with its update date. If a change is material, we will notify you by email or through a prominent notice on the site.
15. Contact and complaints
To exercise your rights or resolve any question about this policy:
Newport Group USA Inc
Email: jose@racowski.com
Website: racowski.com
If you believe we have not handled your request properly, you can lodge a complaint with the data protection authority of your country of residence. In the European Union, with the supervisory authority of your member state.
Last updated: 2 August 2026