Privacy Policy

1. Who we are

cbnsndwch LLC ("Ingenio," "we," "us") operates the website at Ingenio Ventures (the "Site"). We are a Delaware LLC. For privacy inquiries, contact us at privacy@ingenio.vc.

2. What we collect

We collect information only when you voluntarily provide it or when it is generated automatically by your use of the Site.

Information you provide

• Research access requests: name, email address, organization, and your stated interest in Cuba's economic transition.

Information collected automatically

• Analytics and session data: if you consent to analytics cookies, we use Microsoft Clarity to collect behavioral analytics including page visits, click maps, and session recordings. See our Cookie Policy for details.
• Log data: our hosting provider (Cloudflare) may collect standard server log data (IP address, browser type, referring URL, timestamps) as part of normal infrastructure operation. We do not use this data for profiling.

3. How we use your information

• To evaluate and respond to research access requests.
• To send you research access credentials if your request is approved.
• To correspond with you about your access or the research library.
• To understand how the Site is used and improve it (analytics, only with consent).

We do not sell, rent, or share your personal information with third parties for marketing purposes. We do not use your information for automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal basis (GDPR)

If you are located in the European Economic Area, our legal bases for processing your personal data are:

• Legitimate interests — processing research access requests and operating the Site.
• Consent — analytics cookies (you may withdraw consent at any time via the cookie banner or by contacting us).

5. Third-party processors

6. Data retention

Research access request data is retained for as long as necessary to manage your access and for legitimate business recordkeeping, typically no longer than 3 years after your last interaction with us. You may request deletion at any time (see Section 7).

7. Your rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion of your data.
• Object to or restrict processing of your data.
• Request portability of your data.
• Withdraw consent for analytics at any time (see Cookie Policy).

To exercise any of these rights, email privacy@ingenio.vc. We will respond within 30 days.

8. International transfers

Our infrastructure is operated by Cloudflare, which may process data in the United States and other countries. If you are located in the EEA, your data may be transferred to and processed in the US. Cloudflare relies on Standard Contractual Clauses for such transfers.

9. Children

This Site is not directed to individuals under 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, contact us at privacy@ingenio.vc.

10. Changes to this policy

We may update this Privacy Policy from time to time. Material changes will be indicated by updating the "Last updated" date above. We encourage you to review this page periodically.

11. Contact

For privacy questions or to exercise your rights, contact us at privacy@ingenio.vc.