Privacy Policy

Last updated: October 2, 2026

1. Who we are

The Commerce Circuit is an independent publication operated by Emanuele Fornaro.

For the purposes of applicable data protection laws, including the EU General Data Protection Regulation (GDPR), Emanuele Fornaro is the data controller.

For privacy-related questions or requests, contact emanuele@thecommercecircuit.com.

2. Personal data we collect

When you subscribe to The Commerce Circuit, we collect your email address.

Our email service provider, Kit, may also process technical and usage information necessary to provide the service, such as IP address, device and browser information, subscription status, and information about interactions with emails and the newsletter service.

We do not intentionally collect special categories of personal data through The Commerce Circuit.

3. Why we process your data

We process your personal data to:

• manage your subscription to The Commerce Circuit;
• send you the newsletter and related editorial communications;
• manage subscription confirmations and unsubscribe requests;
• operate, secure and understand the performance of the newsletter service.

We do not sell your personal data.

4. Legal basis

Where required by applicable law, we rely on your consent to send you The Commerce Circuit by email.

Subscriptions use a double opt-in process: after submitting your email address, you are asked to confirm your subscription by email.

You may withdraw your consent at any time by using the unsubscribe link included in our emails. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5. Service providers

We use Kit as our newsletter and email service provider. Kit processes subscriber personal data on our behalf in order to provide subscription management, email delivery and related newsletter services.

Kit may use subprocessors to provide its services. Information about Kit's processing practices and subprocessors is available in Kit's privacy and data processing documentation.

6. International data transfers

Kit and some of its service providers are based in, or may process personal data in, the United States and other countries outside the European Economic Area.

Where required, Kit provides mechanisms for international data transfers including the EU-U.S. Data Privacy Framework and Standard Contractual Clauses approved by the European Commission.

7. How long we keep your data

We retain personal data for as long as necessary to manage your subscription and provide The Commerce Circuit, and as otherwise required to meet applicable legal or compliance obligations.

If you unsubscribe, we will no longer use your email address to send you the newsletter. You may also contact us to request deletion of your personal data, subject to any information we may need to retain for legal or compliance purposes.

8. Your rights

Depending on where you live, you may have rights regarding your personal data, including the right to:

• access your personal data;
• correct inaccurate data;
• request deletion of your data;
• restrict or object to certain processing;
• receive your data in a portable format where applicable;
• withdraw your consent at any time.

If you are in the European Economic Area, you also have the right to lodge a complaint with the competent data protection supervisory authority.

To exercise your rights, contact emanuele@thecommercecircuit.com.

9. Unsubscribing

Every newsletter email includes an unsubscribe link. You can use it at any time to stop receiving The Commerce Circuit.

10. Changes to this Privacy Policy

We may update this Privacy Policy when our services or data processing practices change.

If we make material changes affecting how we process your personal data, we will provide appropriate notice where required.