Privacy policy
Last updated:
Who processes your data
Varela Digital Group LLC, a company formed in the State of Wyoming, United States (filing ID
2026-002046831), with its business address at 1057 NW 136th Ave, Miami, FL 33182. Managing member: Jonathan
Varela. Contact for any privacy matter: jonathan@
This policy covers this site and the stores of all the company’s brands: Herbaciane Cudeńka, Miminhos de Chá, Tassenschätzchen, Theeschatjes, 티방울 (Tibangul), Teakincsek, Çay Minnoşları, Tea Cuties and La Cuadrilla.
What data we process
- When you buy: your email address (and, in some stores or depending on the payment method, your name; with MB WAY, also your phone number; with UPI, also your billing address), the country you buy from, the product, the amount, the currency, the payment method and the date. For cards, Stripe only gives us partial details, such as the card brand, the last 4 digits and the country; we never see the full number.
- When you order a custom service: the information you send us so we can do it, such as your city, your photos, your prices and the occasions you cater to. For “50 klientów na start” we also gather, from public sources, the name and public contact details of businesses in your area: if your business appears on one of those lists and you don’t want it to, write to us and we will remove it (legitimate interest in providing the service, GDPR Art. 6(1)(f)).
- When you browse the stores: technical data such as your IP address, browser, device, the pages you visit and the time, and what cookies and the pixel record (see below).
- When you write to us: the content of your message and the email address or phone number you send it from.
To buy, we need your email address: without it we cannot send you the product. We do not ask for health data or data about minors.
Purposes and legal basis
The legal bases apply to anyone who buys from the European Union (General Data Protection Regulation, GDPR).
| Purpose | Legal basis |
|---|---|
| To deliver what you bought, support you and, if you ask, refund your money. | The contract (GDPR Art. 6(1)(b)). |
| To write to you if the bank declines your payment, with a link to complete the purchase. | The contract you started (GDPR Art. 6(1)(b)). |
| To remind you of a purchase you left unfinished, up to 3 times depending on the store; from any of those emails you can ask us to stop writing to you. | Our legitimate interest in helping you complete the purchase you started (GDPR Art. 6(1)(f)); you can object at any time. |
| To meet our accounting and tax obligations. | A legal obligation (GDPR Art. 6(1)(c)). |
| To prevent fraud, keep things secure and defend ourselves in claims or payment disputes. | Our legitimate interest in making sure charges are legitimate and in being able to prove delivery (GDPR Art. 6(1)(f)). |
| To measure which ads work and show you advertising, with the Meta pixel and the Conversions API. | You can limit or turn off cookies in your browser and object at any time by writing to us. |
We do not sell your data or share it with third parties so that they can sell you their products.
Who we share it with
With these providers, each for its own task:
- Stripe: processes payments (see below).
- Impultienda (ZOUT TECH LLC, Miami, USA): platform for the stores and the checkout.
- Brevo (Sendinblue SAS, Paris): sends the stores’ emails.
- Cloudflare: hosts this site and the product access pages.
- Google: our email and the fonts (Google Fonts) loaded by this site and the stores.
- Meta Platforms Ireland Ltd.: the Meta pixel and the Conversions API in the stores. For collecting and sending that data we are joint controllers with Meta (GDPR Art. 26); Meta alone is responsible for what Meta does afterward (facebook.com/privacy/policy).
- Microsoft Ireland Operations Ltd.: Microsoft Clarity, at every store’s checkout and on La Cuadrilla’s sales page, to see how the page is used.
- Anthropic: the artificial intelligence assistant (Claude) we use to read and answer support messages and to prepare the custom services.
- FormSubmit: the order form on the custom web page from Herbaciane Cudeńka, which forwards to you by email the orders placed through that page.
Stripe
We use Stripe for payments, analytics, and other business services. Stripe may collect personal data including via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud and loss prevention and detection, authentication, analytics related to the performance of its services, and to enhance and customize the user experience. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.
Where it is processed
The company is based in the United States and processes your data there; if you buy from the European Union, you give it to us directly when you buy. Some providers also process it in the United States. Stripe, for example, complies with the EU-US Data Privacy Framework.
Cookies and measurement
This site (vareladigitalgroup.com) does not use advertising pixels or analytics tools. It loads its fonts from Google Fonts, which receives your IP address.
The brands’ stores use cookies and similar technologies: the Meta pixel and the Conversions API, to measure which ads work and to show you advertising that may interest you, and, at every store’s checkout and on La Cuadrilla’s sales page, Microsoft Clarity, to see how the page is used. Through them, cookie identifiers, your IP address, browser data and events such as “page view” or “purchase” are sent to those providers. You can delete or block cookies in your browser, and you can object to this measurement by writing to us.
How long we keep it
- Purchase data: for as long as the relationship lasts and then for the period required by tax law.
- Browsing data: up to 24 months.
- Support emails: up to 24 months from the last message.
Your rights
You can ask us to give you access to your data, correct it, delete it, restrict its processing, transfer it to
another service or object to our use of it, and you can withdraw any consent you have given at any time. Write to
jonathan@
If you bought from the European Union, you can also lodge a complaint with your country’s data protection authority (GDPR Art. 77): in Poland, the UODO; in Portugal, the CNPD; in Germany, the authority of your federal state; in the Netherlands, the Autoriteit Persoonsgegevens; in Hungary, the NAIH; in Spain, the AEPD. The list of all the authorities is on the website of the European Data Protection Board.
Data deletion
If you want us to delete everything we hold about you, write to jonathan@
Security
The site and the checkouts are encrypted with HTTPS, and card details are received by Stripe, not by us. Access to the data is limited to the people who need it for their work. If a breach affecting you were to occur, we would notify you.
Changes to this policy
If we update it, we change the date at the top. If the change is significant, we also notify you by email.