Privacy Policy

Phantom LUTs Pty Ltd
Last Updated: 1 July 2025

1. Introduction
Welcome to Phantom LUTs. This Privacy Policy explains how Phantom LUTs Pty Ltd ("we," "us," or "our") handles information in connection with your use of our website (www.joelfamularo.com) and your purchase of our digital products ("Products").

Your privacy is of utmost importance to us. Our guiding philosophy is that your personal information should only be used for essential purposes: to complete your purchase, provide support, and meet our operational and legal obligations.

This philosophy is put into practice through our core principle of data minimization. We do not store your personal or transactional information on our own servers. Instead, we partner with trusted, industry-leading third-party services to host our website, process sales, deliver products, handle invoicing, and manage communications securely.

This policy outlines what information is collected, our legal basis for processing it, and with whom it is shared. By using our website and services, you acknowledge that you have read and understood this policy.

2. Information We and Our Partners Collect
To provide our services, our third-party partners collect certain information. We do not have access to your full financial details, such as credit card numbers.

  • Personal Information: Your name, email address, and billing address/country of residence.

  • Transactional Information: Details about the Products you purchase, the price, and the date of the transaction.

  • Technical and Usage Data: Anonymous usage data collected by our website platform (Squarespace) and analytics service (Google Analytics) for security and analytical purposes.

  • Communications Information: Information you provide when you contact us directly via email or social media, such as your name, username, and the content of your messages.

3. Legal Basis for Processing
We process your personal data based on the following legal grounds, primarily by directing our trusted third-party partners to perform actions on our behalf:

  • Performance of a Contract: We process your personal and transactional information through our payment and delivery partners (e.g., Stripe, SendOwl) to fulfill our contract with you. This includes processing your payment, delivering the Product you purchased, and providing customer support related to that purchase.

  • Legitimate Interests: We process technical and communications data through our website host and analytics providers to maintain the security of our website, analyze traffic to improve our services, and respond to your inquiries. We ensure that our legitimate interests do not override your rights and freedoms.

  • Legal Obligation: We, and our invoicing partner (Quaderno), are required to process and retain certain transactional information to comply with our respective financial and tax laws.

4. How Your Information is Used
The information collected is used for the following purposes:

  • To Process Your Order & Deliver Products: To securely handle your payment and provide you with a download link.

  • To Provide Customer Support: To communicate with you to verify your purchase, resolve issues, or answer questions.

  • To Analyse Website Traffic: To understand how visitors engage with our site, allowing us to improve our user experience.

  • To Comply with Legal and Tax Obligations: To generate invoices and maintain records as required by law.

  • To Operate and Secure Our Website: To ensure our website and third-party integrations function correctly and securely.

  • To Protect Our Intellectual Property: To monitor for and act against unauthorised distribution of our Products, as detailed in our EULA found at https://www.joelfamularo.com/eula

5. Who We Share Your Information With (Our Third-Party Partners)
We do not sell your personal information. We rely on the following essential service providers who act as "data processors" on our behalf. They are contractually obligated to protect your data.

  • Website & Analytics

  • Sales, Delivery & Invoicing

    • SendOwl: Processes the sale and delivers your digital product. Privacy Policy

    • Stripe & PayPal: Securely process payments. We do not see or store your credit card details. Stripe Policy | PayPal Policy

    • Quaderno: Automatically generates tax-compliant invoices. Privacy Policy

  • Communications

Business Transfers: In the event of a merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be shared or transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

6. Intellectual Property Enforcement
As stated in our EULA, we actively monitor for unauthorised distribution and piracy of our Products to protect our intellectual property. This may involve engaging third-party services to scan publicly accessible information on digital marketplaces, file-sharing networks, and social media. This monitoring is limited to public data and is conducted for the sole purpose of identifying and acting against copyright infringement. We do not share our customers' private purchase information with these services for this purpose unless compelled by a court order.

7. Data Retention
We do not retain your personal data on our own systems, except for direct communications.

  • Transactional Data: Our partners retain your information in accordance with their policies and as necessary to comply with their legal and tax obligations.

  • Communications Data: Personal data from direct communications, such as support emails or social media messages, is retained as necessary to provide ongoing customer support and for our business records, unless a valid request for erasure is received.

  • Analytics Data: Anonymous analytics data may be retained indefinitely for statistical purposes.

8. Cookies and Tracking Technologies
Our website uses cookies and similar technologies for several purposes:

  • Essential Cookies: Required for the basic functionality of our website and e-commerce platform (e.g., keeping items in your cart).

  • Analytics Cookies: We use services like Google Analytics which use cookies to help us understand anonymous user behavior so we can improve our website. You can opt-out of Google Analytics tracking by installing their browser add-on.

  • Affiliate & Marketing Cookies: When you are referred to our site by one of our affiliates, a cookie may be placed in your browser. This cookie is used solely to identify the referring affiliate so they can be credited for the sale if you make a purchase.

Most web browsers allow you to control cookies through their settings. You can set your browser to block certain cookies, to notify you when a cookie is being set, or to delete cookies. Please be aware that if you block essential cookies, certain features of our website may not function correctly.

9. Your Data Rights
Under applicable data protection laws, including GDPR, you have certain rights over your personal data.

  • Right of Access: You can ask for a copy of the personal information we hold about you.

  • Right to Rectification: You can ask us to correct inaccurate information.

  • Right to Erasure (Right to be Forgotten): You can ask us to delete your personal information.

  • Right to Restrict Processing: You can ask us to temporarily halt the processing of your data under certain conditions.

  • Right to Data Portability: You can ask for a copy of your data in a machine-readable format.

  • Right to Object: You can object to us processing your data for our legitimate interests.

To exercise these rights, please contact us at hello@joelfamularo.com. As we do not store your core transactional data on our systems, we will act as a facilitator for your request. Upon receiving a request, we will first verify your identity to protect your privacy, and then instruct our relevant third-party partners to process your request. We will also delete any direct correspondence we hold with you, if requested.

Please note that your rights may be limited. For example, we may be required to retain certain transactional data (like invoices) to comply with our legal and tax obligations, even after a request for erasure. We will inform you of any such limitations.

10. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. As no uniform technology standard for recognizing and implementing DNT signals has been finalized, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

11. Data Security
We rely on the robust technical and organizational security measures implemented by our industry-leading partners to protect your information from unauthorized access, use, or disclosure.

12. International Data Transfers
Our business and our third-party partners operate globally. Your information is processed primarily in the United States and other countries where our partners maintain facilities. For users outside the U.S. (including Canada, the UK, and the EEA), please be aware that your data will be transferred to and stored in countries with different data protection laws. We rely on legally-approved transfer mechanisms, such as Standard Contractual Clauses, to ensure your information is protected to a high standard.

13. Children's Privacy
Our website and Products are not intended for or directed at children under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected data from a child, we will take steps to delete it immediately.

14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last Updated" date.

15. Contact Us
If you have any questions about this Privacy Policy, please contact us at: hello@joelfamularo.com