Systems Over Tools · gonzascapuzzi.com

Privacy Policy

Last updated: March 15, 2026

This Privacy Notice for Gonzalo Scapuzzi (doing business as Systems Over Tools) ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at gonza@gonzascapuzzi.com.

Summary of Key Points

This summary provides key points from our Privacy Notice.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us — primarily your email address when you subscribe to our newsletter.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to deliver the newsletter and associated resources, communicate with you, and comply with law.

In what situations do we share personal information? We may share information with Beehiiv, our newsletter platform, which processes data on our behalf.

How do we keep your information safe? We have appropriate technical processes in place. However, no electronic transmission over the internet can be guaranteed 100% secure.

What are your rights? Depending on your location, you may have certain rights regarding your personal information. See Section 10 for details.

How do you exercise your rights? Contact us at gonza@gonzascapuzzi.com.

Table of Contents

  1. What information do we collect?
  2. How do we process your information?
  3. What legal bases do we rely on?
  4. When and with whom do we share your information?
  5. Do we use cookies and tracking technologies?
  6. Is your information transferred internationally?
  7. How long do we keep your information?
  8. How do we keep your information safe?
  9. Do we collect information from minors?
  10. What are your privacy rights?
  11. Controls for Do-Not-Track features
  12. Do United States residents have specific privacy rights?
  13. Do we make updates to this notice?
  14. How can you contact us about this notice?
  15. How can you review, update, or delete your data?

1. What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us.

We collect personal information when you express interest in obtaining information about our Services or subscribe to our newsletter. The personal information we collect includes:

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate.

Information automatically collected

Some information — such as your IP address and browser characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit or use our Services. This may include your IP address, browser type, device characteristics, operating system, language preferences, and other technical information. This information is primarily needed to maintain the security and operation of our Services.

We also collect information through cookies and similar technologies. The information we collect includes:

2. How Do We Process Your Information?

We process your information to provide, improve, and administer our Services and communicate with you.

We process your personal information for the following purposes:

3. What Legal Bases Do We Rely On?

We only process your personal information when we have a valid legal reason to do so.

If you are located in the EU or UK: We rely on the following legal bases under GDPR:

If you are located in Canada: We process your information based on express or implied consent, which you may withdraw at any time.

4. When and With Whom Do We Share Your Information?

We may share information in specific situations with the following third parties.

We share your data with third-party service providers who perform services on our behalf:

We have contracts in place with our third parties designed to safeguard your personal information.

We may also share your information in the following situations:

5. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) when you interact with our Services. Beehiiv uses tracking pixels to measure email opens and click redirects to track link clicks in newsletters.

You can usually set your browser to remove or reject cookies, though this may affect certain features of our Services.

6. Is Your Information Transferred Internationally?

We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are a resident in the EEA, UK, or Switzerland, please be aware that your information may be transferred to and processed in the United States.

We have implemented the European Commission's Standard Contractual Clauses for such transfers. Our Data Processing Agreement with Beehiiv is available at: https://www.beehiiv.com/dpa.

7. How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice.

We will retain your personal information for as long as you maintain an active subscription, plus 30 days after unsubscribing. When we have no ongoing legitimate business need to process your information, we will delete or anonymize it.

8. How Do We Keep Your Information Safe?

We aim to protect your personal information through organizational and technical security measures.

We have implemented appropriate technical and organizational security measures. However, no electronic transmission over the internet can be guaranteed 100% secure. Transmission of personal information to and from our Services is at your own risk.

9. Do We Collect Information From Minors?

We do not knowingly collect data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18 years old. If we learn that personal information from users under 18 has been collected, we will delete it promptly. Contact us at gonza@gonzascapuzzi.com if you believe we have collected data from a minor.

10. What Are Your Privacy Rights?

Depending on your location, you may have rights that allow you greater control over your personal information.

In regions like the EEA, UK, Switzerland, and Canada, you may have the right to: (i) request access and obtain a copy of your personal information; (ii) request rectification or erasure; (iii) restrict processing; (iv) data portability; and (v) object to processing.

To exercise these rights, contact us at gonza@gonzascapuzzi.com.

Withdrawing consent: You can withdraw your consent at any time by contacting us or clicking the unsubscribe link in any email.

Opting out of marketing: Click the unsubscribe link in any newsletter email, or contact us directly.

If you are in the EEA or UK and believe we are unlawfully processing your information, you have the right to complain to your Member State data protection authority or UK data protection authority.

11. Controls for Do-Not-Track Features

Most web browsers include a Do-Not-Track ("DNT") feature. As no uniform technology standard for recognizing DNT signals has been finalized, we do not currently respond to DNT browser signals.

12. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, or other US states with privacy laws, you may have specific rights.

Categories of Personal Information We Collect

Category Examples Collected
A. Identifiers Email address, IP address YES
B. California Customer Records Name, financial information NO
C. Protected classification characteristics Gender, age, race NO
D. Commercial information Purchase history, financial details NO
E. Biometric information Fingerprints, voiceprints NO
F. Internet or network activity Browsing history, online behavior NO
G. Geolocation data Device location NO
H. Audio, electronic, sensory data Images, audio, video recordings NO
I. Professional information Job title, work history NO
J. Education information Student records NO
K. Inferences Profiles based on collected data NO
L. Sensitive personal information NO

We will retain Category A information for as long as the user maintains an active subscription, plus 30 days after unsubscribing.

We have not sold or shared any personal information to third parties in the preceding twelve (12) months.

Your Rights

You may have the right to: know whether we process your data, access your data, correct inaccuracies, request deletion, obtain a copy, non-discrimination for exercising rights, and opt out of targeted advertising or profiling.

How to Exercise Your Rights

Contact us at gonza@gonzascapuzzi.com.

Appeals

If we decline to take action on your request, you may appeal by emailing gonza@gonzascapuzzi.com. If your appeal is denied, you may submit a complaint to your state attorney general.

13. Do We Make Updates to This Notice?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The updated version will be indicated by an updated date at the top of this Privacy Notice. We encourage you to review this Privacy Notice frequently.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may email us at gonza@gonzascapuzzi.com or contact us by post at:

Gonzalo Scapuzzi
Barcelona, BARCELONA 08025
Spain

15. How Can You Review, Update, or Delete the Data We Collect From You?

Based on the applicable laws of your country or state of residence, you may have the right to request access to, correct, or delete your personal information. To make a request, contact us at: gonza@gonzascapuzzi.com.