Legal Documentation

Privacy Policy

Last Updated: October 24, 2024

1. Who We Are and Data Controller

This digital platform is operated by 111111 ("we," "us," or "our"), accessible via coapola.site. As a publication and bespoke travel curation studio committed to ethical practices, we act as the primary data controller for personal data processed through this website.

For any data protection inquiries, you may reach our designated compliance officer exclusively via email at [email protected].

2. Scope of this Policy

This policy applies to all visitors, journal readers, subscribers, and clients interacting with our digital interfaces, forms, and email communications.

3. Categories of Personal Data Collected

We restrict data collection to what is necessary for providing editorial content and travel consulting:

4. Purposes of Processing and Legal Bases

Under applicable state privacy regulations in the United States and aligned international standards, we process your information strictly according to designated lawful grounds:

Processing PurposeData UtilizedLegal Basis
Inquiry Response & Journey ProposalsName, email, phone, messageContractual necessity & Consent
Site Performance & AnalyticsIP, browser, page viewsExplicit Consent (via Consent Mode)
Security & Fraud PreventionTechnical server logsLegitimate business interests
Legal & Regulatory ComplianceAudit logs, recordsStatutory obligations

5. Cookies & Google Consent Mode v2

Our website utilizes Google Consent Mode v2 in an advanced posture. By default, before user interaction with our cookie management banner, all advertising, remarketing, and analytics tags are locked in a denied state. Only strictly necessary operational cookies function. Your explicit choice is honored and can be revised at any time through the "Cookie Settings" link located in our footer.

6. Third-Party Sharing and Sale of Data

We do not sell, rent, or trade personal data to third parties under any circumstances. Data is shared only with verified technical providers (hosting infrastructure, transactional email gateways) bound by non-disclosure agreements, or when compelled by competent lawful authorities.

7. International Data Transfers

While 111111 operates within the United States, our global readership may access servers across international lines. When cross-border processing occurs, we implement standard contractual clauses and rigorous technical encryption safeguards.

8. Data Retention Schedule

We retain travel inquiries and correspondence for twenty-four (24) months following the resolution of the inquiry or completion of the itinerary, after which information is securely purged or anonymized.

9. User Rights and Regulatory Authorities

Depending on your jurisdiction (such as California under the CCPA/CPRA, or corresponding state and international frameworks), you possess the right to:

In the United States, privacy oversight is governed by respective State Attorneys General and the California Privacy Protection Agency (CPPA), as well as the Federal Trade Commission (FTC).

10. Children’s Privacy

Our publications and services are not directed toward children under 13 years of age (or under 16 where heightened regional thresholds apply). We do not knowingly solicit or store data from minors.

11. Contacting Our Data Desk

To exercise your legal rights or review this statement, contact: 111111 Data Protection Office via [email protected].

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