Privacy Policy

1. Introduction

Americo Trading Inc. d/b/a Carney (“Carney,” “we,” “our,” or “us”) provides digital marketing services, publishes The Daily Carnage newsletter, and offers sponsorship and advertising opportunities through our website located at carney.co and any subdomains or related online properties (collectively, the “Site”).

This Privacy Policy describes how we collect, use, disclose, and protect personal information, and outlines the rights and choices available to individuals under applicable privacy laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR, the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), and other applicable privacy regulations.

By accessing or using the Site, submitting information to us, or purchasing our services, you acknowledge and agree to the terms of this Privacy Policy.

2. Data Controller and Contact Information

For purposes of GDPR, Carney is the “Data Controller” of personal data collected through the Site.

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may contact us with any questions or requests at the email above.

3. Categories of Personal Information We Collect

We collect personal information directly from individuals, automatically through the Site, and from third-party sources, as described below.

3.1 Information Provided Directly by You

We may collect the following categories of information when you voluntarily submit them:

• Contact Information: name, email address, company name, job title, and similar identifiers.
• Newsletter Subscription Information: email address and confirmation details associated with double opt-in enrollment for The Daily Carnage.
• Sponsorship and Advertising Information: contact information, creative content submissions, URLs, and related materials.
• Billing-Related Information: billing name and address as transmitted to us by Stripe or PayPal.
• Communications: content of emails or inquiries sent to us.

We do not intentionally collect sensitive personal information (GDPR Article 9 or CPRA-defined “sensitive personal information”).

3.2 Information Collected Automatically

When you access or use the Site, we and our service providers may collect information automatically through cookies, pixels, tags, scripts, and similar technologies, including:

• IP address
• Browser type and device characteristics
• Operating system
• Referring URLs and UTM parameters
• Pages viewed and time spent
• Interaction data (scrolling, clicks, form interactions)
• Advertising identifiers
• Approximate geolocation inferred from IP address

This information may be considered personal information or personal data under applicable law.

3.3 Information Obtained from Third Parties

We may receive personal information from:

• Email marketing platforms (e.g., Mailchimp): subscription status, engagement metrics.
• Analytics providers (e.g., Google Analytics): aggregated Site usage and behavior patterns.
• Advertising platforms (e.g., Google Ads, Meta, TikTok, LinkedIn): audience insights, conversion data, and metadata related to marketing campaigns.
• Payment processors (Stripe, PayPal): transaction confirmations, billing details, and payer information.

We do not receive or store full payment card numbers or financial account information.

4. Purposes and Legal Bases for Processing

Where required (e.g., under GDPR and UK GDPR), we rely on specific lawful bases to process personal data.

4.1 Purposes of Processing

We process personal information for the following purposes:

• Provision of Services: to operate the Site, deliver newsletters, process sponsorship and advertising submissions, and provide customer support.
• Communications: to send transactional notices, administrative updates, and marketing communications where lawful.
• Payment Processing: to facilitate purchases through third-party payment processors.
• Advertising and Marketing: to create custom or lookalike audiences, measure advertising performance, retarget users, and optimize campaigns.
• Analytics and Improvement: to analyze usage patterns, monitor performance, and improve functionality.
• Security and Fraud Prevention: to detect, investigate, and prevent fraud or unauthorized activity.
• Legal Compliance: to comply with obligations under applicable laws, regulations, and recordkeeping requirements.

4.2 Legal Bases (GDPR / UK GDPR)

Depending on the activity, our legal basis for processing may be:

• Consent: for newsletter subscriptions, non-essential cookies, and certain marketing activities.
• Contract: to process sponsorship purchases or deliver services you request.
• Legitimate Interests: including improving the Site, ensuring security, conducting marketing to existing customers, audience measurement, and responding to inquiries.
• Legal Obligation: for tax, accounting, and compliance requirements.

You may withdraw consent at any time by following unsubscribe instructions or contacting us.

5. Cookies, Pixels, and Tracking Technologies

We use cookies and similar technologies for functionality, analytics, advertising, and personalization. This includes:

• Google Analytics
• Google Ads conversion tracking and remarketing
• Meta Pixel
• TikTok Pixel
• LinkedIn Insight Tag
• Mailchimp marketing cookies (where applicable)

Where required by law, we will obtain your consent before placing non-essential cookies or processing personal data for advertising purposes.

Users may control cookies through browser settings or applicable consent tools.

6. Disclosure of Personal Information

We may disclose personal information for the purposes described in this Policy to:

• Service Providers: including hosting providers, analytics services, email platforms, advertising networks, and payment processors.
• Advertising Partners: to enable behavioral advertising, retargeting, conversion measurement, and custom audience generation.
• Professional Advisors: attorneys, accountants, auditors.
• Legal Authorities: when required by law, regulation, or court order.
• Business Transfers: in connection with mergers, acquisitions, reorganizations, or sale of assets.

We do not “sell” personal information in the traditional sense. However, our use of tracking technologies and audience matching constitutes “sharing” under the CPRA.

7. Your Rights

7.1 Rights Under GDPR / UK GDPR

Individuals in the EEA or UK have the right to:

• Access their personal data
• Request correction of inaccurate data
• Request deletion of personal data
• Restrict or object to certain processing
• Request data portability
• Withdraw consent
• Lodge a complaint with a supervisory authority

Requests may be submitted to info@carney.co.

7.2 Rights Under CCPA/CPRA (California Residents)

California residents have the right to:

• Request to know the categories and specific pieces of personal information collected
• Request deletion of personal information
• Request correction of inaccurate information
• Opt out of “sharing” personal information for cross-context behavioral advertising
• Limit use of any sensitive personal information (not collected by us)
• Be free from discrimination for exercising privacy rights

We provide a “Do Not Sell or Share My Personal Information” mechanism as required by CPRA.

Requests may be submitted to info@carney.co.

8. Data Transfers Outside the EEA/UK

Personal data may be transferred to and processed in the United States. Where required, transfers are made pursuant to:

• Standard Contractual Clauses approved by the European Commission; or
• Other lawful transfer mechanisms permitted by GDPR/UK GDPR.

9. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer period is required by law. Retention periods vary depending on the category of data and legal obligations.

10. Data Security

We implement reasonable technical and organizational measures to safeguard personal information. However, no security system is impenetrable, and we cannot guarantee absolute security.

11. Children’s Privacy

The Site is not intended for children under 16. We do not knowingly collect personal information from children under 16. If you believe such information has been collected, contact us so we may delete it.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date will reflect the revision. Continued use of the Site indicates acceptance of changes.

13. Contact Information

For questions or requests regarding this Policy, contact: