Privacy Policy
Last updated: October 7, 2026
This is the short version, in plain language. It covers this website, the KRAMO pre-order and the emails we send about it. If anything is unclear, write to support@promo.kramo.org.
- We never see your card. Payment happens on Stripe's pages.
- Your answers stay with us. What you tell us about your wellbeing is stored only in our own database.
- We do not share health information with advertisers. Meta receives only the signal that a page of this site was viewed.
- One email is enough to see, export or delete your data.
Who we are
KRAMO is a daily practice app for anxious attachment, with five-minute exercises and an SOS tool for hard moments. The data controller for the information described here is Translate.com LLC (KRAMO), 571 Washington Street, Afton, WY 83110, USA, phone +1 (620) 520-6995, email support@promo.kramo.org. Full details are in the legal notice.
Why we treat your data as sensitive
KRAMO is about wellbeing. The simple fact that you pre-ordered it, your answers in our quiz, and anything you choose to tell us in the optional questions after payment, may say something about your mental health. We treat all of it as health data.
- UK and EEA: we process it only with your explicit consent (Art. 9(2)(a) GDPR and UK GDPR), which you give by ticking the consent box before checkout. You can withdraw it at any time by emailing us. We then delete your answers and stop using your data for anything except what the law still requires, such as payment records and a refund you are owed. Withdrawal does not affect what we did before.
- United States: we use it only to provide your pre-order, handle refunds and decide what to build. We do not sell it, and we do not share it with advertisers.
What we collect, why, and on what basis
The legal bases in brackets apply under the GDPR and UK GDPR.
| What | Why | Basis |
|---|---|---|
| Your order: the email you enter in checkout, amount, currency, country, payment reference and payment status | To confirm your pre-order, email you its terms, give you access at launch and make refunds | Contract (Art. 6(1)(b)); explicit consent (Art. 9(2)(a)); tax records: legal obligation (Art. 6(1)(c)) |
| Your consent: that you ticked the box and when | To be able to show that we asked | Legal obligation (Art. 6(1)(c), Art. 7(1)) |
| Quiz answers and the first name you give in the quiz. Where the law allows it without a separate consent step (United States), each answer is saved as you give it, linked only to the random identifier in your browser; elsewhere your answers are saved only when you enter your email and tick the consent box | To show your pattern and plan, to email you about KRAMO if you leave your email, and to understand what to build first. Stored only in our own database; never sent to Google or Meta | Explicit consent (Art. 9(2)(a)) in the UK and EEA; in the United States, to provide what you asked for |
| Optional answers after payment (for example, what you have already tried) | To understand what to build first. Stored only in our own database, with your order | Explicit consent (Art. 6(1)(a), Art. 9(2)(a)); you can skip them |
| Refund requests: your email and, if you give it, a reason | To find your order and refund it | Contract and legal obligation (Art. 6(1)(b), (c)) |
| Emails you send us | To answer you | Contract or legitimate interest (Art. 6(1)(b), (f)) |
| Usage events: a random identifier stored in your browser, pages and sections viewed, scroll depth, buttons pressed, checkout started or completed, the campaign parameters of the link you arrived on, the referring page, browser type and approximate country | To count visits and pre-orders and see which parts of the page work. Stored in our own database. They contain no email address and nothing you answered (quiz answers are covered above) | Legitimate interest in running and improving the offer (Art. 6(1)(f)) |
| Google Analytics and the Meta Pixel | See "Analytics and advertising" below | Consent (Art. 6(1)(a)) |
You do not have to give us anything beyond what checkout needs. Without an email address and a payment we cannot take a pre-order. There is no automated decision-making with legal or similar effects on you.
Payment
Payments are processed by Stripe. Your card and bank details are entered on Stripe's pages and never reach us. Stripe tells us your email, the amount, your country and a payment reference.
- Orders in US dollars are sold by us; Stripe processes the payment on our behalf. Your statement shows KRAMO.
- Orders in pounds or euros may be sold through Link, a Stripe service. In that case the seller (merchant of record) is Sold through Link, LLC, a Stripe affiliate, which handles checkout and VAT as an independent controller under its own privacy policy (link.com/privacy). Your statement may then show LINK.COM*. Checkout shows who the seller is before you pay.
Analytics and advertising
We use Google Tag Manager to load two tools. In the UK and EEA they load only after you click "Accept" in the cookie banner. If you click "Reject", or do nothing, they are not loaded at all. To change your choice later, delete this site's cookies and site data in your browser; the banner then appears again. Elsewhere, including the United States, they load when you open the page.
Google Analytics 4
Provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (for the UK and EEA) and Google LLC (elsewhere). It receives neutral events: page viewed, scroll depth, button pressed, checkout started, pre-order paid (amount and currency), refund requested, together with campaign parameters, page address and browser data. It sets cookies. Google Analytics 4 does not store full IP addresses.
Meta Pixel
Provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (for the UK and EEA) and Meta Platforms, Inc. (elsewhere). We use it only for PageView: it tells Meta that a page of this site was viewed, with the page address, browser data, IP address and Meta's cookie, so we can see whether our Facebook and Instagram ads bring visitors. It does not receive your purchase, the buttons you press, your answers, your email or your name. Meta's automatic event detection is switched off. In the UK and EEA we and Meta are joint controllers for this collection and transmission (Art. 26 GDPR, Meta's controller addendum); Meta alone is responsible for what it does afterwards under its own privacy policy.
We do not share health information with advertisers. Neither Google nor Meta receives your answers, your email address or your name from us.
Storage in your browser
We keep a few small entries in your browser's storage: a random identifier, the campaign parameters of the link you first arrived on, your cookie choice (UK and EEA), and, during checkout, the order you started. They let us count visits and pre-orders, connect a payment to the visit, and remember your choice so we do not ask again. Google Analytics and the Meta Pixel set their own cookies only when they load, as described above.
Emails
After payment Stripe sends you a payment receipt; the terms of your pre-order stay available on this site. We write to you only about your pre-order: launch news, your access, and refunds. We will not send you unrelated marketing unless you agree to it separately.
Who processes data for us
Only service providers that work for us under contract and on our instructions:
- Stripe — payments (for pound and euro orders sold through Link, Link is an independent controller, see above);
- Supabase — our database, where orders, answers and usage events are stored;
- Netlify — website hosting;
- an email delivery provider — the emails about your pre-order;
- Google (Tag Manager, Analytics) and Meta (Pixel) — measurement, as described above.
We do not sell personal data, and we do not give your email to anyone for their own marketing.
Transfers outside the UK and EEA
Some of these providers are in the United States, and Translate.com LLC (KRAMO) itself is a US company. Transfers from the EEA rely on the EU-US Data Privacy Framework where the recipient is certified (and its UK Extension for UK data), and otherwise on the European Commission's standard contractual clauses (Art. 46(2)(c) GDPR) with the UK addendum.
How long we keep it
- Payment records and refund requests: as long as tax and accounting law requires, usually up to ten years.
- Your optional answers: until you ask us to delete them, and at the latest 24 months after launch.
- Order data and email address: until you ask us to delete them, and at the latest 24 months after launch or after your refund, apart from the payment records above.
- Usage events: 24 months.
Your rights
You can ask for a copy of your data, have it corrected or deleted, restrict or object to how we use it (Art. 15–18, 21 GDPR), take it with you (Art. 20) and withdraw any consent at any time with effect for the future (Art. 7(3)). One email to support@promo.kramo.org is enough; you do not need a form. We reply within one month. You may also complain to a data protection authority: in the UK the Information Commissioner's Office (ico.org.uk), in the EEA the authority where you live or work.
US residents and consumer health data
This section is our consumer health data notice for Washington, Nevada, Connecticut and other US states with similar laws, and covers California rights too.
- What we collect: the fact of your pre-order, your email, payment details from Stripe (never your card number), your optional answers, refund requests and the usage events listed above.
- Sources: you, Stripe, and your browser.
- Why: to provide the pre-order you asked for, email you about it, make refunds, decide what to build, and meet legal duties.
- Who receives it: only the service providers listed above, under contract. We do not sell personal data or consumer health data, and we do not share health information with advertisers. The Meta Pixel receives only a page-view signal, with no answers, order or email.
- Your rights: to know and access what we hold, to have it deleted or corrected, and to withdraw consent. Email support@promo.kramo.org. If we turn down a request, reply with "Appeal" and we will review it within 45 days; if you disagree with the outcome you can contact your state attorney general. We will not treat you differently for using these rights.
- Breaches: if your information is ever accessed without authorisation, we will notify you and the authorities as the law requires, including under the FTC Health Breach Notification Rule.
Age
KRAMO is for adults. It is not intended for anyone under 18, and we do not knowingly collect their data.
Changes
If we change this policy we update the date above. If a change matters for your pre-order, we email you.