Sotto Kin (Powered by RarePhorm) LLC
Last Updated: December 3, 2025

1. Introduction

Sotto Kin (Powered by RarePhorm) LLC ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.sottokin.com (the "Site").

IMPORTANT NOTICE: We collect extensive user behavioral data and sell this data to third parties. By using our Site, you explicitly consent to this collection and sale of your data as described below.

2. Information We Collect

2.1 Information You Provide

We may collect information that you voluntarily provide to us, including:

• Name and contact information (email address, phone number)

• Company name and business information

• Communications you send to us

• Any other information you choose to provide

2.2 Automatically Collected Information

We automatically collect extensive behavioral and technical information when you visit our Site, including:

• Click data (every click you make on our Site)

• Scroll behavior (how you scroll through pages)

• Mouse movements and cursor positions

• Touch and swipe patterns on mobile devices

• Time spent on each page and section

• Hover behavior and interactions

• IP address and geolocation data

• Browser type, version, and settings

• Device information (type, operating system, screen resolution)

• Referring and exit pages

• Date and time stamps of visits

• Cookies and similar tracking technologies

3. How We Use Your Information

We use the information we collect for the following purposes:

• To sell to third parties for their commercial use, analytics, and product development

• To build and improve our own AI products and services

• To provide, maintain, and improve our services

• To respond to your inquiries and communicate with you

• To analyze user behavior and Site performance

• To send marketing communications (with your consent where required)

• To comply with legal obligations and protect our rights

4. How We Share Your Information

4.1 Sale of Data to Third Parties

WE SELL YOUR BEHAVIORAL DATA TO THIRD PARTIES. This includes all automatically collected information described in Section 2.2, such as click data, scroll behavior, mouse movements, swipe patterns, and other interaction data. These third parties may use this data for their own commercial purposes, including analytics, advertising, product development, and resale to other parties.

4.2 Other Sharing

We may also share your information with:

• Service providers who assist in operating our Site

• Business partners for joint offerings or collaborations

• Law enforcement or government agencies when required by law

• Other parties in connection with a merger, acquisition, or sale of assets

5. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to collect and track information about your use of our Site. Cookies are small data files stored on your device. You can control cookies through your browser settings, but disabling cookies may limit your ability to use certain features of our Site.

6. Your Rights and Choices

6.1 GDPR Rights (European Union Users)

If you are located in the European Union, you have the following rights under the General Data Protection Regulation (GDPR):

Right to Access: You have the right to request access to the personal data we hold about you.

Right to Rectification: You have the right to request correction of inaccurate personal data.

Right to Erasure: You have the right to request deletion of your personal data in certain circumstances.

Right to Restrict Processing: You have the right to request restriction of processing your personal data.

Right to Data Portability: You have the right to receive your personal data in a structured, commonly used format.

Right to Object: You have the right to object to processing of your personal data for direct marketing or based on legitimate interests.

Right to Withdraw Consent: Where we rely on consent, you have the right to withdraw it at any time. This includes withdrawing consent to the sale of your data.

6.2 CCPA/CPRA Rights (California Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: You have the right to know what personal information we collect, use, disclose, and sell.

Right to Delete: You have the right to request deletion of your personal information.

Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. See Section 6.3 below.

Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights.

6.3 Do Not Sell My Personal Information

California residents and other users can opt-out of the sale of their personal information. To exercise this right, please:

• Visit our "Do Not Sell My Personal Information" page on our website

• Email us with your request (contact information in Section 13)

Note: Opting out will not affect data already sold prior to your opt-out request.

6.4 How to Exercise Your Rights

To exercise any of the rights described above, please contact us using the information provided in Section 13. We will respond to your request within the timeframes required by applicable law (typically 30 days for GDPR requests and 45 days for CCPA requests).

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Behavioral data may be retained indefinitely for analytics and product development purposes, even after sale to third parties.

8. Data Security

We implement reasonable administrative, technical, and physical security measures to protect your information. However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. By using our Site, you consent to the transfer of your information to the United States and other countries where we or our service providers operate.

10. Children's Privacy

Our Site is not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date at the top of this policy and, where required by law, by providing additional notice (such as email notification). Your continued use of the Site after changes are posted constitutes acceptance of the updated Privacy Policy.

12. Legal Basis for Processing (GDPR)

Under GDPR, we process your personal information based on the following legal grounds: (1) Consent - you have given explicit consent for data collection and sale; (2) Contractual necessity - processing is necessary to provide our services; (3) Legal obligation - processing is required to comply with legal requirements; (4) Legitimate interests - processing is necessary for our legitimate business interests, subject to your rights and interests.

13. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Sotto Kin (Powered by RarePhorm) LLC
State of Georgia, United States
Website: www.sottokin.com
Email:

14. Supervisory Authority

If you are located in the European Union and believe we have not addressed your concerns, you have the right to lodge a complaint with your local data protection supervisory authority.