Owner and Data Controller
Raison Services OÜ, Raison Securities Limited, Raison Asset Management Corp. and Raison Digital Ltd. act as joint controllers in respect of your personal information. Raison Services OÜ is the joint controller with primary responsibility for your personal information, including with respect to providing you with information and responding to any requests you may make under the GDPR.
Raison Services OÜ, Roosikrantsi 11, Tallinn city, Harju county, Estonia, 10119
Owner contact email: support@raison.app
Types of Data collected
Among the types of Personal Data that Raison collects, by itself or through third parties, there are:
Usage Data; Cookies; first name; last name; phone number; email address; various types of Data; Camera permission; Precise location permission (non-continuous); Approximate location permission (non-continuous); Sensors permission; Storage permission; Biometric Data access permission; Photo Library permission; geographic position; payment data; address; company name; gender; date of birth; username; password; VAT Number; Tax ID; profession; country; state; county; ZIP/Postal code; Social Security number (SSN); city; picture; profile picture; workplace; website; budget; User ID; academic background; number of employees; billing address; field of activity; house number; language; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service; number of Users; session statistics; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; browsing history; diagnostics; advertising data; product interaction; search history; purchase history; Universally unique identifier (UUID).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Raison.
Unless specified otherwise, all Data requested by Raison is mandatory and failure to provide this Data may make it impossible for Raison to provide its services. In cases where Raison specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by Raison or by the owners of third-party services used by Raison serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Raison.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Raison (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Contacting the User, Advertising, Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Location-based interactions, Remarketing and behavioral targeting, Handling payments, Interaction with data collection platforms and other third parties, Registration and authentication provided directly by Raison, User database management, Managing contacts and sending messages, Tag Management, Heat mapping and session recording, Data transfer outside of the UK, Interaction with external social networks and platforms, Traffic optimization and distribution, Spam and bots protection and Platform services and hosting.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Device permissions for Personal Data access
Depending on the User's specific device, Raison may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of Raison.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Raison.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. Raison may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Raison to derive the approximate position of the User on a continuous basis.
Biometric Data access permission
Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Photo Library permission
Allows access to the User's Photo Library.
Precise location permission (non-continuous)
Used for accessing the User's precise device location. Raison may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Raison to derive the exact position of the User on a continuous basis.
Sensors permission
Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.
Storage permission
Used for accessing shared external storage, including the reading and adding of any items.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Raison, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioral retargeting i.e. displaying ads tailored to the User’s interests and behavior, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on Raison. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
TikTok conversion tracking (TikTok Inc.)
TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on Raison. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of Raison.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Analytics (Universal Analytics) (Google Inc.)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Raison, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Yandex Metrica (YANDEX, LLC)
Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC.
Yandex Metrica can be used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are.
Personal Data processed: Cookies; Usage Data.
Place of processing: Russian Federation – Privacy Policy.
Google Analytics (Universal Analytics) with anonymized IP (Google Inc.)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Raison, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics 4
Google Analytics 4 is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Raison, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Raison.
Personal Data processed: browsing history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt out.
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Contacting the User
Contact form (Raison)
By filling in the contact form with their Data, the User authorizes Raison to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: email address; first name; last name; phone number.
Mailing list or newsletter (Raison)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Raison. Your email address might also be added to this list as a result of signing up to Raison or after making a purchase.
Personal Data processed: email address; first name; last name; phone number.
Phone contact (Raison)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Raison, as well as for fulfilling support requests.
Personal Data processed: phone number.
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Device permissions for Personal Data access
Raison requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Raison)
Raison requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (non-continuous); Biometric Data access permission; Camera permission; Photo Library permission; Precise location permission (non-continuous); Sensors permission; Storage permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of Raison and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows Raison to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube video widget without cookies (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows Raison to incorporate content of this kind on its pages.
This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on Raison unless they play the video.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Instagram widget
Instagram is an image visualization service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that allows Raison to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Handling payments
Payment processing services enable Raison to process payments by credit card, bank transfer or other means. To ensure greater security, Raison shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Payment by bank transfer (Raison)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by Raison, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: address; company name; first name; last name; payment data.
Stripe ( Stripe Technology Europe Ltd)
Stripe is a payment service provided by Stripe Technology Europe Ltd.
Personal Data processed: billing address; email address; first name; last name; payment info; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Heat mapping and session recording
Heat mapping services are used to display the areas of Raison that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of Raison for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Typeform widget (TYPEFORM S.L)
The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.
Personal Data processed: email address; first name; last name; phone number.
Place of processing: Spain – Privacy Policy.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Raison.
The interaction and information obtained through Raison are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Raison isn’t being connected back to the User’s profile.
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by X Corp.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Like button and social widgets (Meta Platforms, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Non-continuous geolocation (Raison)
Raison may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Raison.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed: geographic position.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
OneSignal (Lilomi, Inc.)
OneSignal is a message sending service provided by Lilomi, Inc.
OneSignal allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Depending on the permissions granted to Raison, the Data collected may also include precise location (i.e. GPS-level data) or WiFi information, apps installed and enabled on the User's device. Raison uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the OneSignal service.
The Data collected may be used by the service provider for interest-based advertising, analytics and market research. In order to understand OneSignal's use of Data, consult OneSignal's privacy policy.
Push notifications opt-out
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Interest-based advertising opt-out
Users may opt-out of OneSignal advertising features through applicable device settings, such as the device advertising settings for mobile phones.
Different device configurations, or updates to devices, may affect or change how these indicated settings work.
Personal Data processed: email address; geographic position; language; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt out.
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: company name; country; Data communicated while using the service; date of birth; email address; first name; last name; phone number; physical address; Trackers; Usage Data; username; various types of Data.
Place of processing: United States – Privacy Policy.
Trustpilot Automatic Feedback Service (Trustpilot A/S)
The Trustpilot Automatic Feedback Service is a message-sending service provided by Trustpilot A/S that automates the sending of email requests for product or service reviews based on specific Users’ actions performed on Raison.
Personal Data processed: email address; first name; last name; User ID.
Place of processing: Denmark – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of Raison, therefore allowing the provision of Raison from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Play Store (Google Ireland Limited)
Raison is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
App Store Connect (Apple Inc.)
Raison is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage Raison on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of Raison.
App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.
Personal Data processed: advertising data; diagnostics; product interaction; purchase history; search history; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy.
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Registration and authentication provided directly by Raison
By registering or authenticating, Users allow Raison to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Raison)
The User registers by filling out the registration form and providing the Personal Data directly to Raison.
Personal Data processed: academic background; billing address; budget; city; company name; country; county; date of birth; email address; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; physical address; picture; profession; profile picture; Social Security number (SSN); state; Tax ID; Trackers; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.
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Remarketing and behavioral targeting
This type of service allows Raison and its partners to inform, optimize and serve advertising based on past use of Raison by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Raison with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Raison with the LinkedIn advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
TikTok Remarketing ( TikTok Information Technologies UK Limited )
TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of Raison with the TikTok advertising network.
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United Kingdom – Privacy Policy.
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Spam and bots protection
This type of service analyzes the traffic of Raison, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Raison in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Traffic optimization and distribution
This type of service allows Raison to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Raison and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare, Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Raison, i.e., communication between Raison and the User's browser, while also allowing analytical data from Raison to be collected.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Raison, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Raison.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Raison.
Pipedrive (Pipedrive OÜ)
Pipedrive is a User database management service provided by Pipedrive OÜ.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Estonia – Privacy Policy.
Intercom
Intercom is a User database management service provided by Intercom Inc., Intercom R&D Unlimited Company or by Intercom Software UK Limited, depending on how the Owner manages the Data processing.
Intercom can also be used as a medium for communications, either through email, or through messages within Raison. Intercom Messenger may use Trackers to recognize and track Users behavior.
Personal Data processed: Data communicated while using the service; email address; Trackers; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
Raison may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
Raison adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Raison, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
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Personal Data collected through sources other than the User
The Owner of Raison may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Raison to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Cookie Policy
Raison uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Raison.
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Transfer of Personal Data outside of the United Kingdom
Data transfer abroad based on consent (UK)
If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via Raison.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Raison or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Raison may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Raison and any third-party services may collect files that record interaction with Raison (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Raison and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Raison (or third-party services employed in Raison), which can include: the IP addresses or domain names of the computers utilized by the Users who use Raison, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Raison who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Raison. The Data Controller, unless otherwise specified, is the Owner of Raison.
Raison (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Raison as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to Raison, if not stated otherwise within this document.