1. Introduction
Digital Seller School LLC ("DSS", "we", "us", "our") operates an automated lead engagement system ("LEA", the "Service") that processes prospective customer ("leads", "you") interactions across digital channels. This Privacy Policy describes how we collect, use, share, and protect your personal data when you interact with our landing pages, video sales letters (VSL), opt-in forms, and messaging channels.
We are committed to transparency and compliance with the General Data Protection Regulation (GDPR) (EU Regulation 2016/679) and the California Consumer Privacy Act (CCPA).
2. Data Controller
Digital Seller School LLC
704 Wallace St, Suite 502
Clovis, NM 88101 — United States
EIN: 36-5151783
Email: info@digitalsellerschool.it
For EU-specific inquiries, we act as the Data Controller under GDPR Art. 4(7).
3. Data We Collect
3.1 Personal Identifiable Information (PII)
- Email address
- Phone number (if provided)
- First name (and last name if provided)
- Instagram handle (if you engage via Instagram)
- Third-party CRM identifiers (Go High Level contact ID)
3.2 Behavioral Data
- Video Sales Letter (VSL) watch percentage and duration
- Call-to-action (CTA) click events
- Page visit history and duration
- Scroll depth and engagement metrics
- Return visit patterns
3.3 AI-Generated Derived Data
- Lead readiness score (0-100 scale)
- Personality profile classification (e.g., analytical, impulsive)
- Predicted objections
- Recommended communication channel
3.4 Message History
- Outbound messages sent by LEA (SMS, Email, Instagram DM)
- Inbound replies from you
- Setter handoff events (when a human agent takes over)
3.5 Metadata
- Source of lead acquisition (form type, campaign, channel)
- Timestamps of creation and processing
- Session identifiers (non-persistent)
4. Legal Basis for Processing (GDPR Art. 6)
We process your data under the following legal bases:
- Consent (Art. 6(1)(a)): When you submit an opt-in form, you consent to receive marketing communications.
- Legitimate Interest (Art. 6(1)(f)): To improve our sales funnel, analyze conversion patterns, and engage with prospects who have shown explicit interest.
- Contract (Art. 6(1)(b)): If you become a customer, to fulfill our contractual obligations.
5. How We Use Your Data
We use your personal data to:
- Send you personalized educational content and marketing communications about our Amazon FBA training program
- Qualify leads and determine readiness for human sales team engagement
- Automate initial outreach via SMS, email, and Instagram Direct Messages
- Hand off qualified leads to our human sales representatives ("setters")
- Improve the effectiveness of our automated messaging system
- Comply with legal obligations and respond to lawful requests
6. Third-Party Data Processors
We share your data with the following third-party processors under Data Processing Agreements (DPAs) compliant with GDPR Art. 28:
| Processor | Purpose | Location |
|---|---|---|
| Anthropic PBC | AI message generation (Claude API) | United States |
| Go High Level (HighLevel LLC) | CRM and communication platform | United States |
| PostHog Inc. | Product analytics — VSL behavior, page engagement | US / EU |
| Manychat Inc. | Instagram Direct Message automation | United States |
| Twilio Inc. | SMS gateway provider | United States |
| Meta Platforms Inc. | Instagram messaging via Instagram Graph API | US / Ireland |
For EU-US data transfers, we rely on Standard Contractual Clauses (SCCs) adopted by the European Commission pursuant to GDPR Art. 46.
We do NOT sell your personal data to third parties.
7. Data Retention
We retain your personal data for 3 years from the date of last contact. After this period, we permanently delete your data, unless:
- Legal obligations require longer retention (e.g., tax records)
- You explicitly request earlier deletion (see Section 9)
- You re-engage, which resets the retention timer
8. Data Security
We implement appropriate technical and organizational measures to protect your data, including:
- Encryption in transit (TLS 1.2+) and at rest
- Access controls and authentication on internal systems
- Regular security audits
- Incident response procedures per GDPR Art. 33
In the event of a data breach affecting your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and, where required, notify you directly.
9. Your Rights (GDPR Art. 15–22, CCPA §1798.100–150)
You have the right to:
- Access: Obtain a copy of the personal data we hold about you.
- Rectification: Correct inaccurate or incomplete data.
- Erasure (right to be forgotten): Request deletion.
- Restriction: Limit our processing in specific circumstances.
- Portability: Receive your data in structured, machine-readable format.
- Objection: Opt out of processing based on legitimate interest or direct marketing.
- Withdraw Consent at any time, without affecting prior lawful processing.
- Non-discrimination: Exercise your rights without adverse consequences.
To exercise any of these rights, contact us at info@digitalsellerschool.it. We will respond within 30 days (extendable by 60 days for complex requests).
10. Cookies and Tracking Technologies
Our landing pages use cookies and similar technologies for analytics and user experience optimization. You may control cookies via your browser settings.
11. Children's Privacy
Our Service is not directed at minors under 18. We do not knowingly collect data from individuals under 18. If you believe a minor has provided us with personal data, contact us immediately at info@digitalsellerschool.it.
12. International Users
If you access the Service from outside the United States, please be aware that your data will be transferred to, stored, and processed in the United States. By using the Service, you consent to such transfer.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice on our website. The "Last Updated" date at the top reflects the most recent revision.
14. Supervisory Authority
If you are an EU/EEA resident and believe we have violated GDPR, you have the right to lodge a complaint with your local data protection supervisory authority. A list of authorities is available at edpb.europa.eu.
15. Meta Platform Compliance
LEA integrates with Meta Platforms (Facebook + Instagram) Business APIs to manage Direct Message conversations and ad performance data. Our integration is subject to and complies with the Meta Platform Terms and Meta Developer Policies.
Data deletion request via Meta: If you wish to delete data we collected through Meta-related interactions (Instagram DMs, Facebook lead ads), submit a request to info@digitalsellerschool.it with subject "Meta Data Deletion Request". We process within 30 days as per GDPR/CCPA.
Data retention via Meta APIs: message history retained 3 years from last interaction (see Section 7). Meta-derived data is stored on our infrastructure under standard encryption and never shared back to third parties.
This product is not endorsed, certified, or affiliated with Meta Platforms, Inc.
16. Contact
Digital Seller School LLC
Privacy Inquiries: info@digitalsellerschool.it
Response Time: Within 30 days