This Privacy Policy explains how Titan Development Studio, LLC, a Delaware limited liability company, doing business as "Cupp'd" ("Cupp'd," "we," "us," or "our"), collects, uses, discloses, and protects information when you visit or interact with our website at cuppdapp.com (the "Site"). This Site is directed at coffee shop and café owners and operators interested in the Cupp'd platform. This Policy applies only to the Site. It does not apply to the Cupp'd mobile application for consumers, or to the Cupp'd Business Portal (business.cuppdapp.com), each of which is governed by its own separate privacy policy. By using the Site, you acknowledge the practices described in this Policy. ## 1. Information We Collect ### 1.1 Information You Provide to Us When you fill out our contact/inquiry form or otherwise reach out to us, we collect: - First and last name - Email address - Business name - Number of business locations - Any additional information you choose to include in your message to us - Whether you've opted in to receive promotional emails and updates, via a separate checkbox on the form (unchecked by default — submitting an inquiry alone does not opt you in) If you click through to purchase a subscription, you will be directed to Stripe, our payment processor, to complete that transaction. We do not collect or store your payment card details ourselves — see Section 4 below. If you click "Login," you will be directed to the Cupp'd Business Portal (business.cuppdapp.com), which is a separate product governed by its own privacy policy. ### 1.2 Information Collected Automatically When you visit the Site, we and our service providers may automatically collect: - Device and browser information (device type, browser type and version, operating system) - IP address and general location derived from it (city/region level — not precise GPS location) - Pages viewed, links clicked, time spent on pages, and referring/exit URLs - Information collected through cookies and similar tracking technologies (see Section 2) ### 1.3 Information We Do Not Collect on This Site This Site does not collect precise geolocation data, biometric data, or health information. We do not knowingly collect information from children (see Section 9). ## 2. Cookies and Similar Tracking Technologies We use cookies and similar technologies for the following purposes: - **Strictly necessary** — required for the Site to function (e.g., security, load balancing) and to remember your cookie preferences. These cannot be switched off. - **Analytics** — to understand how visitors use the Site, so we can improve it. When enabled, we use Google Analytics for this purpose. - **Marketing** — reserved for advertising and remarketing tools we may enable in the future (such as the Meta Pixel or Google Ads remarketing). These tools are **not currently active** on the Site. If we enable them, they will only load after you opt in through our cookie preference center. We ask for your affirmative consent before loading Google Analytics or any other non-essential cookies, through the cookie preference center on the Site ("Your Privacy Choices"). You may withdraw or change consent at any time using the **Your Privacy Choices** link in the Site footer, or through your browser settings. **If you are located in the United States:** depending on your state of residence, you may have the right to opt out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising. Because advertising / remarketing pixels are not currently active, the Site does not presently share Site activity with Meta or Google Ads for that purpose. If we enable those tools later, opting out via **Your Privacy Choices** (or sending a Global Privacy Control / GPC signal, which we honor where technically feasible) will keep marketing storage denied. We also link to this Policy at [/privacy](/privacy). You can also control cookies generally through your browser settings, though blocking all cookies may affect Site functionality. ## 3. How We Use Your Information We use the information you submit through the inquiry form to: - Respond to your inquiry and provide the information you requested - Follow up with you regarding that specific inquiry - Send you promotional emails and updates about Cupp'd, **only if you checked the opt-in box on the form** — you can unsubscribe at any time using the link in any such email, and we honor unsubscribe requests promptly - Operate, maintain, and improve the Site - Analyze Site usage via Google Analytics **only if you have consented** to analytics cookies - Detect, prevent, and address fraud, security, or technical issues - Comply with our legal obligations Submitting an inquiry alone does not opt you in to promotional emails — only checking the separate opt-in box does. Promotional emails we send comply with the CAN-SPAM Act, including an unsubscribe mechanism in every message. ## 4. How We Share Your Information We do not sell your personal information for money. We share information only in the following circumstances: - **Service providers.** With vendors who perform services on our behalf, including hosting (Amazon Web Services), payment processing (Stripe), analytics (Google Analytics, when you consent), and email/CRM tools we use to manage inquiries (Mailchimp). These providers are contractually restricted from using your information for their own purposes. - **Advertising partners.** Not currently applicable. If we later enable advertising or remarketing pixels (such as Meta or Google Ads), we may share Site activity with those platforms for advertising purposes only after you opt in to marketing cookies. That sharing can qualify as "sharing" under certain US state privacy laws even when no money changes hands — see Section 2 for your opt-out and consent rights. - **Email service provider.** If you opt in to promotional emails, we share your email address with Mailchimp, the platform we use to send those communications and manage inquiries. - **Business transfers.** If Titan Development Studio, LLC is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy or a successor policy. - **Legal requirements.** Where required to comply with applicable law, legal process, or governmental request, or to protect the rights, property, or safety of Cupp'd, our users, or others. ## 5. Legal Bases for Processing (EEA/UK Visitors) If you are located in the EEA or UK, we rely on the following legal bases under GDPR / UK GDPR: - **Consent** — for non-essential cookies (including Google Analytics), future marketing cookies if enabled, and promotional email communications. - **Legitimate interests** — for Site security, fraud prevention, and improving essential Site functionality that does not require non-essential cookies, balanced against your rights. - **Contractual necessity** — where we need information to respond to your inquiry or take steps toward a contract at your request. - **Legal obligation** — where processing is necessary to comply with the law. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. ## 6. International Data Transfers Cupp'd is based in the United States, and the information we collect is processed and stored in the United States (including via AWS infrastructure). If you are located outside the United States, your information will be transferred to, and processed in, the United States, which may not have the same data protection laws as your home jurisdiction. Where required, we rely on appropriate safeguards for these transfers, such as Standard Contractual Clauses (for EEA transfers) or the UK International Data Transfer Addendum (for UK transfers), as implemented through our service providers' data processing agreements. ## 7. Your Privacy Rights ### 7.1 EEA and UK Residents Under GDPR / UK GDPR, you have the right to: - Access the personal information we hold about you - Correct inaccurate information - Request erasure of your information - Restrict or object to certain processing - Receive your information in a portable format - Withdraw consent at any time - Lodge a complaint with your local data protection authority (in the UK, the Information Commissioner's Office) ### 7.2 US State Residents Depending on your state of residence, you may have rights under laws such as the California Consumer Privacy Act (as amended by the CPRA) and similar laws in other states, including the right to: - Know what personal information we collect, use, and disclose - Access and delete your personal information - Correct inaccurate personal information - Opt out of the sale or sharing of your personal information - Limit the use of sensitive personal information - Not be discriminated against for exercising these rights - Appeal a decision regarding your request ### 7.3 How to Exercise Your Rights You may submit a request by emailing [privacy@titandevstudio.com](mailto:privacy@titandevstudio.com). We will verify your request and respond within the timeframe required by applicable law (generally 30 days for GDPR/UK GDPR, 45 days for US state laws, each with possible extensions). You may also designate an authorized agent to submit a request on your behalf where permitted by law. To manage cookie preferences on this Site, use **Your Privacy Choices** in the footer. ## 8. Data Retention We retain contact and inquiry information collected through this Site for up to **24 months** from your last interaction with us (for example, your last form submission or email exchange about that inquiry), after which it is deleted or anonymized, unless a longer period is required for legal, accounting, or dispute-resolution purposes. Analytics data retained by Google is subject to our Google Analytics data-retention settings and your cookie choices. You may request earlier deletion, subject to Section 7. ## 9. Children's Privacy This Site is intended for business owners and operators and is not directed at children. We do not knowingly collect personal information from anyone under the age of 16. If you believe a child has provided us with personal information, please contact us at [privacy@titandevstudio.com](mailto:privacy@titandevstudio.com) and we will delete it. ## 10. Data Security We use reasonable administrative, technical, and physical safeguards designed to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. ## 11. Third-Party Links The Site links to third-party services we do not control, including Stripe (for payment), the Apple App Store and Google Play Store (to download the Cupp'd app), and the Cupp'd Business Portal (business.cuppdapp.com). Your use of those services is governed by their own privacy policies, which we encourage you to review. ## 12. Changes to This Policy We may update this Policy from time to time. If we make material changes, we will update the "Last Updated" date above and, where required by law, provide additional notice. We encourage you to review this Policy periodically. ## 13. Contact Us If you have questions about this Policy or wish to exercise your privacy rights, contact us at: Titan Development Studio, LLC 651 N Broad St, Suite 201, Middletown, Delaware 19709, United States [privacy@titandevstudio.com](mailto:privacy@titandevstudio.com) General Site inquiries: [hello@cuppdapp.com](mailto:hello@cuppdapp.com) ## 14. Governing Law This Policy is governed by the laws of the State of Delaware, without regard to its conflict-of-laws principles, except where applicable data protection law (including GDPR/UK GDPR) requires otherwise for the rights described in Section 7.