Privacy Policy

1. Who we are

RawCloser is operated by Fabio Antonelli.

2. Scope

This Privacy Policy applies when you use the RawCloser website, the RawCloser application, our licence server, and our website sign-up forms.

3. Website sign-up forms

When you join the waitlist or apply for tester access on our website, we collect:

• email address, for waitlist sign-up
• email address and a required free-text job description, for tester applications
• a salted hash of the submitter's IP address, for rate limiting and abuse prevention

We do not store the raw IP address in our own application.

Retention:

• until public launch plus 12 months, or
• until unsubscribe or deletion request,

whichever comes first.

Lawful basis:

• consent, for communications
• pre-contractual steps, for tester access requests
• legitimate interests, for rate limiting and abuse prevention

4. What we collect

We collect only the data needed to provide and secure the service.

A. Account and entitlement data

• email address
• plan
• renewal date
• one-time trial marker
• payment processor customer identifier, where billing is active
• licence token / entitlement record
• terms acceptance version and timestamp

B. Local device data

RawCloser stores certain metadata on the user's device only, including browser identifier string and a derived device-type label. This data does not reach our servers.

C. Call and workspace data

• call audio processed on the user's Mac
• transcripts stored on the user's Mac
• notes stored on the user's Mac
• local AI analysis performed on the user's Mac

D. Website and server logs

Our hosting provider's web server logs may record:

• client IP address
• timestamp
• request line
• response status
• bytes transferred
• referrer
• browser identifier string

5. What we do not collect

We do not collect call audio, transcripts, notes, or call content on our servers.

We do not sell personal data.

We do not collect advertising identifiers.

We do not use analytics.

We do not use third-party ad trackers.

6. Licence server

We operate a licence server at api.rawcloser.com.

When you log in, launch the application, or refresh your session, RawCloser sends your email address to our licence server and receives back a signed entitlement token. The licence server is the authoritative source of what plan you have access to; the application does not determine entitlement locally.

The licence server may store:

• email address
• plan
• renewal date
• payment-processor customer identifier, where billing is active
• a marker recording that a trial was taken

The licence server does not receive call content.

7. Local-first processing

RawCloser is designed to be local-first for call data.

By default:

• call audio is processed on the user's Mac
• transcripts are stored on the user's Mac
• notes are stored on the user's Mac
• local AI analysis is performed on the user's Mac

However, certain account and entitlement checks require your email address to be sent to our licence server, and website sign-up flows may involve third-party processors described in this Policy.

8. Lawful bases

We rely on the following lawful bases under GDPR:

• Contract: to provide the RawCloser service, account access, entitlement checks, and customer support
• Legal obligation: to comply with tax, accounting, consumer law and record-keeping obligations
• Legitimate interests: to secure our systems, prevent abuse, and enforce one-trial and entitlement rules
• Consent: for website communications and any other feature that we clearly present as consent-based
• Pre-contractual steps: for tester access requests and related onboarding communications

9. Free trial

New users may be offered a 10-day free trial. No payment method is required at trial start, and no charge is made automatically at the end of the trial.

The trial is available once per user and is linked to the email address used to start it. If the same email address has already used a trial, a new trial will not be available under that email address.

10. Tester access

Approved testers may receive free access during the testing phase for a period of up to approximately one month, as determined by us.

In addition, approved testers may receive a one-time, personal, non-transferable code granting 50% off a paid subscription for 12 months after the tester period ends.

We may issue conditions for use of the code, including any redemption deadline, when the code is issued. The code applies only to the recipient and only as communicated at the time of issue.

11. Early-access discount

Before public launch, users who sign up early may be eligible for a personal, non-transferable code for 20% off the first 12 months of the selected plan.

Eligibility is determined by sign-up before public launch. If eligible, the discount will be issued as an individually provided code sent to the email address used to sign up.

The code must be redeemed by the deadline stated when it is issued. The discount applies to the first paid subscription purchase made using the code, and the 12 discounted months run from that first paid purchase date.

The discount may be withdrawn or changed for future sign-ups, but any code already issued will be honoured according to the terms stated at the time of issue.

12. Email delivery and sign-in providers

We use the following providers for specific operational purposes:

• Resend for email delivery
• Hugging Face for one-time first-launch model download
• Stripe for billing where billing is enabled
• Namecheap for hosting of the website and licence server

These providers may receive personal data needed to perform their service.

13. International transfers

Some of the providers we use may process personal data outside your country of residence, including in the United States.

These providers include:

• Stripe Payments Europe Limited in Ireland, and related Stripe group entities, as applicable
• Resend
• Hugging Face
• Namecheap

Where required, transfers are covered by Standard Contractual Clauses, Data Privacy Framework certification, and provider terms incorporated into our service agreements.

14. Hosting logs

Our website and licence server are hosted on shared infrastructure and the hosting provider's web server logs may record the items listed above, including raw IP addresses.

These logs are on the hosting provider's systems, not ours. Our own application writes no access log and stores no IP address on the server.

Log retention is 180 days.

15. Security

We use technical and organisational measures intended to protect personal data, including access controls, rate limiting, and server-side validation.

No method of transmission or storage is perfectly secure.

16. Your rights

Depending on your location, you may have the right to:

• access your data
• correct your data
• delete your data
• restrict processing
• object to processing
• withdraw consent
• receive a portable copy of certain data

To exercise those rights, contact privacy@rawcloser.com.

17. Retention

We keep personal data only as long as needed for the purposes described in this Policy.

Examples:

• account data: while the account remains active and for a reasonable period afterward for legal, tax and security purposes
• one-time trial marker: retained according to our retention policy for 24 months for entitlement and abuse-prevention purposes
• web server logs: 180 days
• billing and accounting records: as required by law

18. Deletion

If you delete your account, RawCloser deletes the associated local data from the device and rewrites the local database file so that deleted content is no longer retained in unreferenced form.

When you delete your account, we also delete the associated account record on our licence server, subject to any data we must keep for legal, tax, accounting, or security reasons.

This deletion does not automatically remove historical account, billing, or legal-retention records that we are required or permitted to keep.

19. Changes to this Policy

We may update this Policy from time to time. If a change is material, we will notify you and, where required, ask you to accept the updated version again.

20. Contact