Privacy Policy

Last updated: April 9, 2026

1. Introduction

Ciro Campagnoli ("we," "us," or "our") operates the website campagnoli.ai (the "Site"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our Site and interact with our AI Family Office platform and agents.

We are committed to complying with the General Data Protection Regulation (GDPR) for users in the European Union, the California Consumer Privacy Act (CCPA) for users in California, and all other applicable data protection laws.

2. Information We Collect

Information you provide:

  • Name, email address, and other contact details submitted through forms or direct communication.
  • Messages and content shared during interactions with our AI agents (Ettore, Valentina, Sam, Luna, Luca, Sofia, Maya, PR Maven, and others).
  • Business information provided in the context of the AI Family Office services.

Information collected automatically:

  • Device and browser information (type, language, operating system).
  • IP address and approximate geographic location.
  • Pages visited, time spent, referring URLs, and navigation patterns.
  • Cookies and similar tracking technologies (see Section 6).

3. How We Use Your Information

  • To operate, maintain, and improve the Site and our AI Family Office services.
  • To provide personalized AI agent interactions with persistent memory and context.
  • To respond to inquiries and communicate with you.
  • To analyze usage patterns and optimize the user experience.
  • To comply with legal obligations and enforce our Terms of Service.

4. AI Agent Interactions

Our AI Family Office includes specialized AI agents that maintain persistent memory to provide continuity across conversations. Data shared with these agents—including business information, portfolio details, and personal preferences—is stored securely and used exclusively to deliver the service. This data is not sold to third parties and is not used to train external AI models.

5. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your personal data based on:

  • Consent: When you voluntarily provide information or interact with our agents.
  • Legitimate interest: To operate and improve our services, analyze usage, and ensure security.
  • Contractual necessity: To fulfill services you have requested.
  • Legal obligation: To comply with applicable laws and regulations.

6. Cookies and Tracking

We use cookies and similar technologies to:

  • Remember your language preferences.
  • Analyze traffic and usage patterns via Google Analytics.
  • Improve site performance and user experience.

Google Analytics collects anonymized data about how visitors use the Site. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. You can also manage cookie preferences through your browser settings.

7. Data Sharing and Disclosure

We do not sell your personal information. We may share data with:

  • Service providers: Hosting (Vercel), AI infrastructure (Anthropic), analytics (Google), and communication tools (Telegram) that help us operate the Site and services.
  • Legal requirements: When required by law, court order, or governmental authority.
  • Business transfers: In connection with a merger, acquisition, or sale of assets.

8. Data Retention

We retain personal data for as long as necessary to provide our services and fulfill the purposes described in this policy. AI agent conversation data is retained to maintain persistent memory and service continuity. You may request deletion of your data at any time (see Section 9).

9. Your Rights

Under GDPR (EEA residents):

  • Right to access, rectify, or erase your personal data.
  • Right to restrict or object to processing.
  • Right to data portability.
  • Right to withdraw consent at any time.
  • Right to lodge a complaint with a supervisory authority.

Under CCPA (California residents):

  • Right to know what personal information is collected and how it is used.
  • Right to request deletion of personal information.
  • Right to opt out of the sale of personal information (we do not sell your data).
  • Right to non-discrimination for exercising your privacy rights.

To exercise any of these rights, contact us at the email address below.

10. International Data Transfers

Your data may be transferred to and processed in the United States and Italy. We ensure appropriate safeguards are in place for international transfers, including standard contractual clauses where required by GDPR.

11. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet is 100% secure.

12. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Continued use of the Site after changes constitutes acceptance of the revised policy.

14. Contact

For questions about this Privacy Policy or to exercise your data rights, contact:

Ciro Campagnoli
Miami, FL · Bologna, Italy
Email: privacy@campagnoli.ai