Last Updated: August 12th 2024

Raisy, operating as a registered company and its affiliates (“Raisy”, “we”, “our”, and/or “us”) values the privacy of individuals who use our apps, websites, or services that link to this Privacy Policy (collectively, our “Services”). If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “personal data” means any information relating to an identified or identifiable individual. This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal data from users of our Services. By using our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service.

INFORMATION WE COLLECT

We may collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us

Registration and Profile. When you register for an account to use our Services, for instance to make an investment/contribution using Raisy, we ask you for your personal data, which may include your email address, user name, digital wallet number, public information from your digital wallet and additional information provided when making an investment/contribution (if relevant). We will also collect any information you provide in response to screening questions required by our customers before you can make an investment/contribution using Raisy.

Know your customer (KYC) identity verifications. Some companies/projects might require you to do a “Know your customer” identify verification, before making investments/contributions to their company/project. These requirements are set by the company/project and not by Raisy. If you are required to carry out a “Know your customer” identity verification, the information that you provide (e.g. copy of ID document, photo, name, birth date, nationality, verification photo/video) will be stored by Raisy on behalf of the company/project. The company/project requiring such verification will have access to that information.

Communications. If you contact us directly, we may receive additional personal data about you. For example, when you contact us via a contact form, email, or other means, we will receive your first name, last name, email address, as well as the content, date, and time of your message. If you contact us from third party sources, like Telegram and Intercom, we will receive your user name, as well as the content, date and time of your message.

B. Information We Collect When You Use Our Services

Location Information. When you use our Services, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, including but not limited to the pages or other content you view, the searches you conduct, and the dates and times of your visits.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, applications, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/ partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect personal data using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on our Services. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, hidden tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and allows us to improve the functionality of our Services. Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect personal data.

• Strictly Necessary Cookies. Some Cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of Cookies.
• Functional Cookies. Functional Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you and remember your preferences. For example, we use functional Cookies to remember your choice of language or region.
• Analytical or Performance Cookies. We also use Cookies for website analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics. Google uses the data collected to track and monitor the use of our Service. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https:// policies.google.com/privacy?hl=en . We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/ analytics/answer/6004245 . These providers may also collect information about your use of other websites, apps, and online resources.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect:

• To provide, maintain, debug, improve, and enhance our Services;
• To understand and analyze how you use our Services, and develop new products, services, features, and functionalities;
• To understand and analyze usage patterns;
• To process your job application;
• To communicate with you, provide you with updates and other information relating to our Services and its promotions, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To send you SMS, calls, or push notifications;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• To aggregate and otherwise de-identify for other business purposes;
• To facilitate transactions and payments;
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected. LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION If you are located in the European Economic Area or the United Kingdom, we only process your personal data when we have a valid “legal basis,” including as set forth below.
• Consent. We may process your personal data where you have consented to certain processing of your personal data.

• Contractual Necessity. We may process your personal data where required to provide you with our Services. For example, we may need to process your personal data to respond to your inquiries or requests.
• Compliance with a Legal Obligation. We may process your personal data where we have a legal obligation to do so. For example, we may process your personal data to comply with tax, labor and accounting obligations.
• Legitimate Interests. We may process your personal data where we or a third party have a legitimate interest in processing your personal data. Specifically, we have a legitimate interest in using your personal data for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your personal data when these interests are not overridden by your rights and interests.

HOW WE SHARE THE INFORMATION WE COLLECT

We do not share or otherwise disclose information we collect from you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/ partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout .

Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes unless we have your permission.

Required by Law and Similar Disclosures. We may access, preserve, and disclose your personal data if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose and transfer your personal data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent. We may also disclose personal data with your permission. For example, we may disclose “Know your customer” personal data to other companies/projects who require “Know your customer” identity verification, if and when you make investments/contributions to their company/project using Raisy, and you consent to said disclosure.

YOUR CHOICES

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. It may take up to ten business days for us to process your request. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the personal data we maintain about you, update and correct inaccuracies in your personal data, restrict or object to the processing of your personal data, have your personal data anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your personal data to another company. In addition, you have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
• You may withdraw any consent you previously provided to us regarding the processing of your personal data at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain personal data for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. By using our Services, you consent to our use of Cookies and our processing of personal data collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Services may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices of these Third-Party Services. Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services. We encourage you to read the privacy policies of these Third-Party Services.

RETENTION

We take measures to delete your personal data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When we process personal data for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re- enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations. For instance, Customer data is retained for as long as the account is in active status. Data enters an “expired” state when the account is voluntarily closed. Expired account data will be retained for 90 days.

SECURITY

We make reasonable efforts to protect your personal data by using physical and electronic safeguards designed to improve the security of the personal data we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your personal data.

INTERNATIONAL MATTERS

Our Services are hosted in the European Economic Area. Please note that we may transfer personal data from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal data from children under 18 years of age, and no parts of our Services are directed to children. If you learn that a child has provided us with personal data in violation of this Privacy Policy, please alert us at privacy@raisy.io.

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal data previously collected from you through our Services, we will attempt to notify you through our Services, by email, or by other means.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@raisy.io or write to us at:
34 St Augustine St
D08 Y190 Dublin
Irlande