Privacy Policy

Effective {{EFFECTIVE_DATE}}

Who we are. Fully Dry is a website operated by Five Key LLC. Five Key LLC is the "controller" responsible for your personal information. Contact: fullydry.help@gmail.com, or by mail at Fully Dry (Five Key LLC), 1964 RAHNCLIFF CT # 22426, SAINT PAUL MN 55122-3448, USA. You can also reply to any email from us.

What we collect.

• Email signup: your email address, the page you signed up from, the date and time, and your confirmation of the double opt-in. If you open our emails or click links in them, our email provider records that (open and click data).
• Kit reservations: if you reserve the First 30 Days Owner Kit, we note your email address and that reservation, and use it only to tell you about the kit. You can ask us to remove it anytime.
• Emails you send us: your address and whatever you write.
• Website visits: like every website, our host (Cloudflare) automatically processes technical request data, such as your IP address, browser type, the page requested and the time, to deliver the site and keep it secure. We also use Cloudflare Web Analytics to count page views. It doesn't use cookies, doesn't store anything on your device, and doesn't track you across sites. Cloudflare processes your IP address to provide the service but doesn't use it to identify you.
• The payback calculator runs entirely in your browser. The numbers you enter and your result are never sent to us or stored.
• We don't collect sensitive information (such as health, financial account, precise location or government ID data), and we don't ask for it.

Why we use it, and our legal basis (relevant if you are in the EU, EEA, UK or Switzerland).

• To send the course and Fully Dry emails you asked for, and to use open and click data to see which lessons help and to note interest in things you click: your consent (GDPR / UK GDPR Art. 6(1)(a)). You can withdraw consent at any time by unsubscribing. This doesn't affect emails already sent.
• To run, secure and fix the website (server request data): our legitimate interests in a working, secure site (Art. 6(1)(f)).
• To answer your messages and requests: our legitimate interests and, for rights requests, our legal obligations (Art. 6(1)(c)).
• We don't use your information for advertising, we don't build ad profiles, and we don't make automated decisions with legal or similarly significant effects about you.

Who processes it for us. We use service providers that handle data only on our instructions and under data-processing terms:

• MailerLite (email list and sending; form submissions) – MailerLite, Inc., USA.
• Cloudflare (website hosting, security and request logs, cookieless analytics) – Cloudflare, Inc., USA.
• Google (Gmail, for our contact inbox) – Google LLC, USA.

We may also disclose information if the law requires it, or to protect our rights. If Fully Dry is ever sold or transferred, your information may go with it under this policy. We never sell or rent your personal information.

International transfers. We are based in the United States, and our providers store and process data in the US and in other countries where they operate. If you are in the EU, EEA, UK or Switzerland, your data is transferred to the US. MailerLite, Inc. and Cloudflare, Inc. are certified under the EU-U.S. Data Privacy Framework, its UK Extension and the Swiss-U.S. Data Privacy Framework. Where a transfer isn't covered by those, we rely on the European Commission's Standard Contractual Clauses (and the UK Addendum) in our providers' data processing terms.

How long we keep it.

• Subscriber data: while you're subscribed. After you unsubscribe, we keep only your email address and unsubscribe status, on a suppression list, so we don't email you again. Ask us to delete it fully and we will.
• Unconfirmed signups: deleted within 30 days.
• Emails you send us: up to 2 years, unless needed longer for a legal reason.
• Rights-request log (date, request, outcome): 2 years.
• Server request data: kept by Cloudflare for short periods under its own retention practices.

Your rights. Wherever you live, you can ask to see, correct or delete the personal information we hold about you. If you're in the EU, EEA, UK or Switzerland, you also have the right to:

• access your data and receive a copy
• rectification (correction)
• erasure
• restriction of processing
• data portability
• object to processing based on legitimate interests
• withdraw consent at any time
• lodge a complaint with your local data protection supervisory authority (in the UK, the ICO)

To make a request, email fullydry.help@gmail.com or reply to any of our emails. We may ask you to confirm the request from the address involved. We respond within one month (EU/UK) or 45 days (US states), and free of charge.

US state privacy rights. Residents of California and of other states with consumer privacy laws (such as Colorado, Connecticut, Virginia, Texas, Oregon and Minnesota) have rights under those laws. These include the right to know or access, correct, delete and get a copy of their personal information, and to opt out of its sale, of sharing for targeted (cross-context behavioral) advertising, and of profiling. Fully Dry is a small publication and likely falls below these laws' thresholds, but we honor these requests for everyone. We don't sell personal information, don't share it for targeted or cross-context behavioral advertising, and don't use or disclose sensitive personal information. There is nothing to opt out of, but you may still ask, and we'll confirm. We won't treat you differently for using your rights. You can use an authorized agent; we may verify the request. If we deny a request, you can appeal by replying to our answer.

Do Not Track and Global Privacy Control. Because we don't sell or share personal information or track you across sites, these browser signals don't change anything on our site. We treat a GPC signal as a valid opt-out request anyway.

Cookies. Our website itself sets no cookies and stores nothing in your browser. The signup form sends your email directly to MailerLite and doesn't load MailerLite's scripts. If you use a MailerLite-hosted signup page we link to, MailerLite may use small storage items on that page to run the form; see MailerLite's privacy and cookie policies. Our emails contain open and click tracking (a tiny image and tracked links), which you agree to when you sign up. You can limit open tracking by turning off images in your email app, and stop all of it by unsubscribing.

Children. Fully Dry is for adults. It isn't directed to children under 13, and anyone under 16 in the EU/UK should not sign up. We don't knowingly collect children's information. If you believe a child has signed up, contact us and we'll delete it.

Security. We use reputable providers, two-factor sign-in on our accounts, and limit access to the people who run the site. No method is 100% secure.

Changes. We'll post updates here and change the effective date. If a change materially affects how we use your email, we'll tell subscribers by email before it takes effect.

Contact. Five Key LLC (operator of Fully Dry), fullydry.help@gmail.com, 1964 RAHNCLIFF CT # 22426, SAINT PAUL MN 55122-3448, USA.