Privacy Policy
Juan Cruz Giusto
Last updated: October 25, 2026
This policy explains what personal data I collect on jcgiusto.com, what I use it for, who I share it with, how long I keep it and how you can exercise your rights. This is my personal website: I run it as an individual, not as a company.
1. Who is responsible
- Name: Juan Cruz Giusto
- Address: Calle Los Pajaritos 7, 28007 Madrid, Spain
- Email: hey@jcgiusto.com
2. What data I collect
Data you give me
When you fill in a form on this site, I only collect what that form asks for:
- Newsletter: your email address and, if you give it, your name.
- Free downloads: it depends on the download.
- The Subscription eCommerce Metric Tree and the two Powered ICE prioritization spreadsheets: your email address only.
- The Art and Science of Subscription Experimentation presentation, the Summary of the 69 Best Growth Books and the Ultimate Subscription eCommerce Checklist: your name, your email address and whether you are an ecommerce brand, a SaaS or an agency/freelancer.
I also store the wording you agreed to and the time: the newsletter sign-up text, or the note next to a download button that says the download adds you to my newsletter.
If you signed up on the previous version of this site, I moved your email address, your name, the downloads you took and your subscription status into the tools described below.
If you email me, I get whatever you put in your email.
Technical data created when you submit a form
- The page you submitted it from.
- Your browser type.
- Your IP address, turned into an irreversible code. I never store the original IP. I use it only to limit abusive submissions.
No analytics, no tracking
I don’t use Google Analytics, the Meta Pixel or any other analytics or advertising tool on this site.
3. Why I use your data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Sending you the download you asked for | Your request |
| Sending you my newsletter | Your consent: confirmed by email if you use the newsletter form, or given with the download (see section 4) |
| Answering your emails | Your request |
| Protecting the forms against spam and abuse | Legitimate interest in keeping the site secure |
| Meeting legal obligations | Legal obligation |
You can withdraw your consent at any time. See section 4 for how to leave the newsletter.
4. Downloads add you to my newsletter
Taking any free download adds you to my newsletter. The form says so next to the button. There is no extra box to tick and no confirmation email: the email with your download is the only one you get at that moment.
- This only applies if you are new. If you are already on my list, your status does not change. If you unsubscribed before, you stay unsubscribed.
- If you sign up with the newsletter form instead, I first send you an email with a confirmation link. You are only subscribed once you click it.
How to leave the newsletter:
- Click the unsubscribe link at the bottom of any newsletter email. One click and you are out.
- Or reply “unsubscribe” to any of my emails.
- Or write to hey@jcgiusto.com.
5. Who I share your data with
I do not sell or rent your data. I only share it with the providers I need to run the site. Each one handles the data on my instructions:
| Provider | What for | Where |
|---|---|---|
| Railway | Hosting the site and the database where form entries are stored | Servers in the United States (Virginia) |
| Resend | Sending emails and managing the newsletter list | United States |
| Cloudflare | Spam check on the forms (Turnstile) | Global network, US company |
| My email inbox (Google Workspace), where your emails and replies to me arrive | United States |
The site’s fonts are stored on this site itself, so loading a page does not contact Google or any other font service.
Some links on this site take you to outside services with their own privacy policies. Those services handle your data as independent controllers:
- Notion Calendar, only if you click the link to book a call with me.
- Notion, Google Sheets and Google Drive, where some downloads live. You open them from the link in your download email.
- LinkedIn, X (Twitter) and YouTube, if you follow the links to my profiles.
A few blog posts show images stored on other websites (Substack and Go-To-Millions). When you open those posts, your browser loads the images from those sites, which receive your IP address.
I may also share data when the law requires it or to defend my legal rights.
6. Transfers outside the EU
Several of these providers are US companies. When your data leaves the European Union, the transfer relies on the EU-US Data Privacy Framework or on the standard contractual clauses approved by the European Commission.
7. How long I keep your data
- Newsletter: for as long as you stay subscribed. If you unsubscribe, my email tool (Resend) keeps your contact (email, first name, language and the downloads you took) marked as “unsubscribed”, so I never write to you again. It stays there until you ask me to delete it. Your form entries follow the 2-year rule below.
- Unconfirmed sign-ups: if you use the newsletter form and never click the confirmation link, I delete that sign-up one week after the link expires.
- Newsletter confirmation links: expire after 48 hours.
- Form entries: the full entry is kept for up to 2 years from our last contact (your most recent form entry). After that I delete it. I keep only what proves you agreed to the newsletter: your email, language, which form or download, the wording you agreed to and when. A newsletter sign-up also keeps your first name.
- If we work together: that is covered by our separate agreement, not by this website.
8. Security
- The whole site runs over an encrypted connection (HTTPS).
- Forms are protected by a spam check and submission limits.
- Access to the database is restricted and password-protected.
- IP addresses are stored only as an irreversible code.
9. Your rights
You can ask me at any time for:
- Access: to know what data I hold about you and receive a copy.
- Correction: to fix anything that is wrong.
- Deletion: to erase your data.
- Objection and restriction: to stop using it, or use it only for some purposes.
- Portability: to receive it in a format you can take to another service.
- Withdrawal of consent: without affecting anything done before.
Email hey@jcgiusto.com and tell me which right you want to exercise. I will answer within one month. I may ask for some information to confirm your identity.
If you think I have mishandled your data, you can complain to the data protection authority in your country. For example:
- the Spanish Data Protection Agency (www.aepd.es) in Spain;
- the AAIP in Argentina;
- the ANPD in Brazil;
- the Superintendence of Industry and Commerce in Colombia.
10. Children
This site is aimed at professionals. I do not knowingly collect data from anyone under 16. If I find I have, I will delete it.
11. Changes to this policy
If I change this policy, I will publish the new version here with its date. If the change is significant, I will also email my subscribers.