Privacy Policy

1. Who is responsible

The controller for personal data processed on this website is Epiphany77 Ventures Ltd, [Registered office address], London, United Kingdom, represented by Charlie Carrel. Email: [contact email]. Full details are in the imprint.

2. Hosting and server logs

This website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you open a page, your browser automatically sends technical data to Vercel’s servers: your IP address, the date and time of the request, the page requested, the referring page, your browser type and operating system. Vercel stores this in request logs for a short period to deliver the website, keep it secure and diagnose faults.

Legal basis: our legitimate interest in operating a secure and reliable website (Art. 6(1)(f) GDPR and UK GDPR). Vercel processes this data on our behalf under its Data Processing Addendum, which includes the EU Standard Contractual Clauses for transfers to the United States. We do not use the logs to identify visitors.

3. Anonymous visit statistics

Apart from Google AdSense (section 4), which only runs with your consent, this website sets no cookies, uses no local storage for tracking and loads no advertising or social-media scripts.

To see which pages are read and where visitors come from, we use Vercel Web Analytics, provided by our hosting provider and served from charlescarrel.com itself. For each page view it records the time, the page address including campaign parameters such as utm_source, the referring page, the country and region derived from your request, and your device type, operating system and browser. It uses no cookies, and the records are not linked to your IP address. Visits are told apart by a hash calculated from the request, which is discarded after 24 hours, so you cannot be recognised on a later visit or followed to other websites. We only see aggregated statistics.

Legal basis: our legitimate interest in understanding how the website is used (Art. 6(1)(f) GDPR and UK GDPR). Vercel processes this data on our behalf under the same Data Processing Addendum as the hosting.

4. Google AdSense (only with your consent)

We use Google AdSense to show advertisements, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, together with Google LLC in the USA. When AdSense is active, your browser loads a script from Google, which transmits your IP address and information about your browser and the page you are on. Google sets cookies to recognise your browser, measure ads and, where permitted, personalise them, and may combine this data with other data it holds about you.

None of this happens until you click “Accept” in the consent banner. If you decline, or do not choose, no request is made to Google at all. Your choice is stored in your browser’s local storage under the key “ads-consent” so we do not ask again; this entry contains nothing but the choice itself. You can withdraw or change your consent at any time here: Cookie settings. Withdrawal applies from the next page load.

Legal basis: your consent (Art. 6(1)(a) GDPR and UK GDPR, Art. 5(3) of the ePrivacy Directive as implemented nationally, and regulation 6 PECR in the UK). Google transfers data to the USA under the EU-US Data Privacy Framework and Standard Contractual Clauses. More in how Google uses data from partner sites and Google’s privacy policy. You can manage ad personalisation at adssettings.google.com.

5. Images, fonts and third-party content

Fonts are served from our own domain. Course images from Elite University and video thumbnails from YouTube are fetched by our server and delivered to you from charlescarrel.com; your browser does not contact those providers to display them. Course and video information is refreshed by our server, not by your browser.

The website contains no embedded videos, maps or social-media widgets. Apart from AdSense with your consent, content from other providers only loads once you follow a link to their site.

6. Links to other websites

When you click a link to another site, that site’s privacy policy applies. This website links to:

• Elite University (elite.charlescarrel.com), where courses are sold on the Kajabi platform. Purchases, accounts and payment data are handled there.
• CoinPoker, via an affiliate link. If you create an account through it, CoinPoker may tell us that a sign-up happened through our link so a commission can be paid. We do not receive your name, email or account details from CoinPoker.
• YouTube, Instagram and X, for Charlie’s channels.

7. Contact by email

If you email us, we process your email address and the content of your message to answer you. Legal basis: Art. 6(1)(b) GDPR where the request relates to a contract, otherwise our legitimate interest in answering enquiries (Art. 6(1)(f)). Emails are deleted once the matter is closed, unless we have to keep them for legal reasons.

8. Your rights

Under the GDPR and UK GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected and, in certain cases, deleted or restricted;
• receive the data you provided in a portable format;
• object to processing based on legitimate interests;
• withdraw consent you have given, for example for AdSense, with effect for the future;
• complain to a supervisory authority: in the UK the Information Commissioner’s Office (ico.org.uk), in the EU the authority of your country of residence.

To exercise any of these rights, email [contact email].

9. Age

This website is not directed at children. The CoinPoker platform it links to is only for adults (18+ or the legal age where you live).

10. Changes

We update this policy when the website changes. The date at the top shows the current version. Adding cookie-based analytics, embedded videos or a contact form would require a further update and, where consent is needed, an extension of the consent banner.