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 license server, and our website sign-up forms.

3. Website sign-up forms

This section is being updated to reflect the website’s current sign-up forms. In the meantime, see the short notice at the sign-up form privacy notice for what the site’s forms collect today.

Advertising attribution totals. When a person submits a form after arriving through one of RawCloser's Instagram advertisements, the form request may include an advertising label supplied in the page URL. RawCloser uses the label only to maintain an aggregate daily count of form submissions attributed to that label. RawCloser does not store the label with the person's email address, name, lead record, Meta click identifier, consent token, IP address, or other personal identifier.

RawCloser stores the advertising label, the calendar date, and the aggregate number of attributed submissions. The label is validated against RawCloser's permitted advertising labels; unexpected URL values are ignored or discarded. RawCloser does not use this information to identify, profile, or contact the person.

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
• license token / entitlement record
• terms acceptance version, timestamp and language
• registered-installation and authorization-key release records for the AI model (see section 6)
• a short-lived request counter that limits abusive requests to the license server (see sections 6 and 14)

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

E. Onboarding and coaching information

RawCloser stores locally the answers you provide during onboarding, including your selling style, industry, revenue targets, most common objection, and a free-text description of what you sell. The free-text field may include the name of your business, clients, or other people if you choose to enter them.

We use this information locally to configure and personalize RawCloser's coaching and AI features. We do not send it to RawCloser or third parties. The legal basis is performance of the contract under Article 6(1)(b) GDPR to the extent the information is necessary to provide the requested features; otherwise, the applicable basis is your consent under Article 6(1)(a).

5. What we do not collect, and advertising identifiers

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

We do not sell personal data.

RawCloser does not use third-party advertising cookies or similar browser identifiers for this aggregate measurement. RawCloser may receive a validated advertising or campaign label in a page URL and use it only to maintain a daily aggregate count of form submissions attributed to that label. The label is not linked to a lead, email address, Meta click identifier, consent token, IP address, or other personal identifier. If you give consent to Meta advertising measurement, RawCloser may read and use the Meta click identifier associated with your visit and may send limited server-side event data to Meta through the Conversions API.

RawCloser does not use Meta Pixel, Meta scripts, Meta SDKs, Meta advertising cookies, or similar browser-based advertising trackers. The optional Meta measurement feature uses limited first-party browser storage and server-side event transmission as described in this Privacy Policy.

RawCloser does not use the feature as general website analytics. It uses the limited events only to measure and optimize RawCloser advertising on Meta.

6. License server

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

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

The application repeats this request periodically while it is open, and about every five minutes (at most eight times an hour) while your plan appears to have ended, so that a renewal is recognized.

The license server may store:

• email address
• plan
• renewal date
• payment-processor customer identifier, where billing is active
• Terms acceptance records (see "Terms acceptance records" below)
• a marker recording that a trial was taken
• registered-installation and authorization-key release records (see "AI model key and registered installations" below)
• a short-lived request counter (see section 14)

The license server does not receive call content.

Terms acceptance records

When you accept or re-accept our Terms, we store an append-only record, protected against unauthorized alteration or deletion, on our license server. The record contains the email address associated with your account, used as the account identifier, the version of the Terms accepted, the date and time of acceptance, the language in which the Terms were presented and, where applicable, the account termination date, used only to calculate the retention period. We do not store your IP address as part of this acceptance record.

We retain these records while your account remains active and afterward for the period reasonably necessary to document the contractual relationship, demonstrate which Terms applied, and establish, exercise, or defend legal claims. We generally retain the minimum acceptance record for up to 10 years after account termination, unless a shorter period is justified or a longer period is required by law. We then delete or anonymize it, subject to any applicable legal hold or other legal requirement.

The legal basis for this retention is our legitimate interest in administering and documenting the contractual relationship and protecting our legal rights.

AI model key and registered installations

RawCloser's AI features use a language model that the app downloads to the Mac in encrypted form. The encrypted model file cannot be used by the app without an authorization key. When the app needs to obtain or renew that authorization, it sends RawCloser's license server the account email address, a public key generated on the Mac, and the version number of the model key it needs.

If the applicable trial, paid plan, or payment grace period is active, the license server returns an authorization key encrypted to that public key and signed by RawCloser. The app stores the authorization key only in encrypted form. The key is valid for up to 14 days from the date it is released, and never beyond the end of the applicable access period; the app renews it automatically when it can reach the license server. When the license has ended, the key expires, or the user signs out or deletes the account, the app deletes the stored authorization key and the AI features become unavailable until access is restored.

The corresponding private key stays on the Mac and is never sent to RawCloser. It is stored encrypted, with a key protected by the macOS Keychain.

For each registered installation, RawCloser stores:

• the internal license identifier;
• an installation identifier derived from the public key using SHA-256;
• the public key;
• the date of registration;
• the date the installation was last seen by the license server (that is, the date of its last successful key request);
• the date of the first key release;
• the number of key releases; and
• the release or revocation status and, where applicable, the date and reason for release.

RawCloser also stores a limited key-release record containing the license identifier, installation identifier, key version, and date and time of release. RawCloser creates no more than one such record per installation in a 24-hour period.

These installation and key-release records do not contain the raw IP address, an IP hash, a device name, a hardware identifier, or the account email address. They are linked to the account through the internal license identifier.

RawCloser uses these records to release authorization keys only for entitled accounts, enforce the limit of three active installations per license, prevent abuse, and administer support requests concerning registered installations.

Each license may have up to three active registered installations. If a fourth installation is presented, RawCloser may refuse registration. An installation that has not been seen by the license server for more than 30 days may be released when its place is needed to register another installation; until it is released, it continues to count toward the limit. Otherwise, a user may contact RawCloser at hello@rawcloser.com to request that an installation be released. Release is subject to account-security checks, and a request does not guarantee that an installation will be released.

RawCloser retains installation records for up to 12 months after the installation was last seen by the license server. RawCloser retains key-release records for up to 90 days after the release. The date of the first key release and the number of key releases are part of the installation record and are kept for as long as that record is kept. These records are deleted earlier when the account is deleted or a valid erasure request requires their deletion, subject to the limited exceptions described in section 18.

The model files are downloaded from Hugging Face, a third-party hosting and delivery provider (see section 12). Hugging Face can receive the IP address associated with the download request and information identifying the requested file. RawCloser does not send call audio, transcripts, notes, coaching data, or AI output to Hugging Face or to the RawCloser license server.

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 license server, the AI model files are downloaded from Hugging Face as described in sections 6 and 12, and website sign-up flows may involve third-party processors described in this Policy.

Call audio, transcription, language detection, and local analysis

RawCloser records and transcribes calls locally on your Mac. No call audio, transcript, language code, coaching score, local AI output, or temporary audio measurement described in this section is sent to RawCloser, Fabio Antonelli, or any third party.

RawCloser may detect whether a call is in English or Italian. It stores the resulting language code with the local call record and uses it to transcribe the call and generate in-call outputs, including call notes, extracted objections, and suggested replies, in the call's language. Other AI outputs, including the sales assistant chat, weekly improvement advice, and pre-call warm-up advice, follow your AI response language setting. RawCloser can translate notes and extracted objections into your app language when you request this or enable automatic translation.

When a call runs through a calling app on your Mac, RawCloser separates the two sides of the call by which audio input was active—the microphone or your Mac's audio output. It does not analyze voice characteristics and does not identify any person.

When enabled by the user, RawCloser may analyze limited acoustic properties of a microphone-only call locally on the Mac to estimate whether segments entered the microphone directly or were reproduced through a loudspeaker. The feature uses fixed signal characteristics and thresholds. It does not create or use a voice profile, voiceprint, embedding, calibration recording, or other speaker-specific representation, and it is not designed to identify a person.

The resulting role labels may be “You,” “Prospect,” or “Unclear.” RawCloser may use those labels locally in SmartNotes and objection extraction. The labelled transcript is provided to those features only when at least 60% of the words are labelled and both roles appear; otherwise, the features receive the plain transcript without speaker labels.

The first name entered for the user and the name of the person or business entered for the call may be provided as context to the local AI model to help assign roles. The names, labels, transcripts, notes, and AI output remain on the Mac and are not sent to RawCloser or third parties.

RawCloser may provide local coaching based on the user's microphone audio and the separated call. This may include speaking pace, vocal energy compared with the user's level earlier in the same call, talk-time balance, and pitch variation. Pitch is processed temporarily and discarded. RawCloser stores only a local 0–10 coaching score and does not store pitch values or pitch patterns.

RawCloser may label transcript segments as “You,” “Prospect,” or “Unclear” and use the separated transcript to suggest replies, extract objections and the user's responses, and prepare call notes, including a short quote attributed to the other party. During a call, RawCloser may compare transcribed words with objection phrases to generate a suggested reply. This involves processing call content and transcript text, not analysis of the other party's voice characteristics. These are role labels, not identities, and “Prospect” means the other party on the call, whatever their relationship to the user.

RawCloser may generate weekly local statistics about the user's calls. These may include scores for pace, energy, talk-time balance, pitch variation, apparent trust signals shown by the prospect, and objection handling. The objection-handling score may be generated by the local AI from the week's objections and the user's responses.

Temporary audio measurements, including levels, frequency measurements, and pitch measurements, are discarded immediately. They are not written to logs, diagnostics, or crash reports. All data described in this section follows the local call-data retention period described in this Policy.

Call-data retention and deletion

RawCloser deletes the full-call audio file immediately after transcription. Short audio clips created for in-call processing are deleted immediately after the relevant processing is complete. RawCloser does not retain call audio after those steps.

Transcripts, transcript segments, call notes, extracted objections and responses, and other call-content data are stored in the local database on your Mac while the related lead remains in the app. When you delete a lead, RawCloser immediately erases the lead's personal data, including the lead's name, phone number, company or profession, and custom-field values. It also erases the call content associated with that lead, including full-call and live transcripts, transcript segments, call notes, and extracted objections and responses.

When you delete a lead, RawCloser deletes future calendar events linked to that lead. Past linked calendar events retain only their date and time; their title is replaced with “Deleted lead” and the link to the lead is removed. Copies previously written to an external calendar are handled as described in Section 11 of this Policy.

To preserve the user's sales statistics and revenue history, RawCloser may retain a lead-independent record containing the call date, duration, and outcome, the deal status and amount, and the user's coaching scores. Deal notes and prospect-related scores, including the prospect's apparent trust scores, are erased. The retained record does not contain the prospect's name, contact details, or other direct contact information. A blank placeholder may remain so that historical statistics and records continue to function. These retained records may still be personal data because they remain part of the user's local account data; they are not represented as anonymous data and are not used to identify the deleted lead.

There is no undo for lead deletion. The app displays a confirmation that the deletion cannot be undone.

Weekly improvement advice is generated locally from call notes. When a lead is deleted, RawCloser deletes the stored weekly improvement advice for every week in which that lead had a call. Advice for the most recently completed week may be regenerated using the remaining call data; advice for earlier weeks is not regenerated. If a single call's content is deleted, RawCloser also deletes the stored weekly advice for the week containing that call. Weekly statistics totals are not deleted solely because related advice is deleted and may continue to include the retained statistical data described above.

You can delete stored weekly improvement advice for any week in the app. Manually deleted advice is permanently erased and is not regenerated automatically. You can request new advice for the most recently completed week by selecting “Generate new advice”; it is generated from the same call data.

You can also delete the content of an individual call without deleting the related lead. This deletes the call's transcript, transcript segments, call notes, extracted objections and responses, and prospect trust scores for that call. The call's date, duration, and outcome, and any related deal, may remain as described above. RawCloser also deletes the stored weekly improvement advice for the week containing that call. Deleting the call's content does not delete the weekly statistics totals described above.

RawCloser deletes erased data from the local database. The database is configured to overwrite deleted content with zeros, and the app flushes the database's write-ahead log after each deletion. These measures are subject to the technical limits of the operating system and storage device. RawCloser cannot erase copies held in backups that you make of your Mac, including Time Machine backups.

When you delete a canceled deal, calendar event, CRM list or custom field, script branch, unlinked sign-in method, or superseded AI-generated pre-call advice, RawCloser hides the item immediately and permanently erases it automatically after 30 days. The erasure process runs when the app starts and once each day while the app is open. Superseded automatically extracted objections are erased immediately.

Deleted call types and call phases remain hidden until account deletion because they are configuration records used to preserve historical call statistics and do not contain information about prospects. Deleted color presets, Terms-acceptance records, recording-consent records, and the internal database-migration log are also retained until account deletion for the purposes described in this Policy.

When you delete your RawCloser account, RawCloser permanently erases the local database and the data it contains, including the records described above and database free space used by previously deleted items, subject to the technical limits of the operating system and storage device.

8. Lawful bases

We use personal data for the following purposes, each with its corresponding lawful basis under GDPR:

• Account and entitlement access: contract
• Billing, payments, and tax records: legal obligation and contract
• Security and abuse prevention: legitimate interest
• Enforcement of the one-time free-trial rule: legitimate interest, applied proportionately
• Promotional communications: consent where required, or legitimate interest only where legally permitted
• Customer support: contract or legitimate interest, depending on context
• Terms acceptance records: legitimate interest in administering and documenting the contractual relationship and protecting our legal rights
• Key release, license validation, and enforcement of the three-installation limit: performance of the contract under Article 6(1)(b) GDPR, because these operations are necessary to provide the licensed AI features and administer the license
• Abuse prevention, request throttling, duplicate-release prevention, security monitoring, and support administration: RawCloser's legitimate interests under Article 6(1)(f) GDPR in protecting the service, preventing unauthorized use, maintaining system security, and responding to support requests
• Aggregate advertising measurement: RawCloser's legitimate interests under Article 6(1)(f) GDPR in measuring the effectiveness of its advertising and improving campaign allocation. RawCloser applies data minimization by storing only a validated advertising label, date, and aggregate count, without linking the count to a lead or individual.

RawCloser applies these measures in a limited way: the license-server records do not contain call content, audio, transcripts, notes, device names, hardware identifiers, or raw IP addresses, and the records are retained only for the periods stated in this Policy.

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 and early-access discount — data use

Where we offer a personal, non-transferable promotional code — a one-time tester discount code or an early-access discount code, as described in our Terms of Service — we use the email address you applied or signed up with to issue and validate the code, and, once redeemed, your plan and renewal date to apply it.

Lawful basis: performance of the contract offering the code, and legitimate interest in preventing misuse of single-use codes.

11. Calendar integrations

Calendars on your Mac

On macOS, RawCloser may optionally allow you to connect calendars already set up in the Calendar app on your Mac. Calendar integration is disabled unless you choose to connect a calendar.

macOS asks for your permission before RawCloser can access the calendars. You can withdraw that permission at any time in System Settings → Privacy & Security → Calendars, although the exact name or location of this setting may vary by macOS version.

RawCloser reads, only from the calendars you select, events falling within a period from 90 days in the past to 365 days in the future. For those events, RawCloser reads the title, start and end times and their time zones, location, notes, and recurrence information.

RawCloser keeps this data in local storage managed by the application on your Mac and does not send it to RawCloser's servers. If you enable write-back, RawCloser writes the data described under "Write-back" into the calendar you choose, through the Calendar app.

If the selected calendar is connected to an external calendar provider, that provider may synchronize the events with its service under its own terms and privacy policy. The provider may be Apple, Google, Microsoft, or another calendar provider.

Apple, Google, Microsoft, and other calendar providers are independent providers of their own calendar services. Their processing of synchronized calendar data is governed by their own terms and privacy policies, not by this Privacy Policy.

When you use this option, RawCloser does not receive or store any password, access token, or renewal token for your calendar accounts.

Write-back

If you enable the write-back feature, RawCloser may create, update, and delete copies of its own future events in the calendar you select.

Automatically created appointment titles may include the lead's name. As a result, that name may be transferred to and stored by the calendar provider that synchronizes the selected calendar, such as Apple, Google, or Microsoft.

These events contain only:

• the event title;
• the event start and end times, including their time zones;
• recurrence information, where applicable; and
• technical identifiers that allow RawCloser to recognize and update its own copies. These identifiers do not contain personal data.

Calendar providers may also add standard metadata to events created through their calendar services. This may include creation and modification timestamps and, depending on the provider, an account email address or other account information as the event's creator or organizer, as well as a link to the event. RawCloser does not set or control these provider-generated fields.

RawCloser does not write unrelated RawCloser notes, call audio, transcripts, descriptions, locations, attendees, conferencing links, or analysis into your calendar.

Disconnection, deletion, and copies

When you disconnect a calendar or delete your RawCloser account, RawCloser removes the calendar data stored by the application on your Mac. Events previously written into your calendar are not automatically deleted when you disconnect the calendar or delete your RawCloser account. You may use the "Delete copies" function, where available, to remove those RawCloser-created events. You remain responsible for copies that you manually create, modify, export, or retain outside RawCloser.

macOS keeps RawCloser's calendar permission until you withdraw it in System Settings → Privacy & Security → Calendars.

Legal basis

Where calendar integration is used to provide a feature you request, the legal basis is performance of the contract under Article 6(1)(b) GDPR. Where applicable, processing necessary to secure the integration, prevent misuse, and maintain reliable operation is based on our legitimate interests under Article 6(1)(f) GDPR.

Calendar event content may contain information about other people. You are responsible for ensuring that you have the right to connect and use the selected calendars and that your use of the integration complies with applicable law and any duties owed to other people whose information appears in those calendars.

12. Email delivery, sign-in, and service providers

We use the following providers for specific operational purposes:

• Resend for email delivery;
• Google and Apple for their respective sign-in and authentication services;
• Hugging Face for hosting and delivery of the AI model files (see below);
• Stripe for billing where billing is enabled; and
• Namecheap for hosting the website and license server.

• Meta Conversions API — Meta advertising measurement and optimization; independent controller; server-side event recipient. Data may include the Meta click identifier, hashed email for selected events, event data, and limited live browser user-agent data. International-transfer mechanism: as identified in the applicable Meta account terms and Privacy Policy.

Hugging Face — hosting and delivery of the AI model files: the encrypted language model, which is stored in a private repository, and the speech-recognition model, a publicly available model published by a third party and hosted by the same provider. The app contacts Hugging Face to download these files, including before sign-in at first launch, and again when a model is updated or has to be downloaded again. Hugging Face may receive the IP address associated with each request and information identifying the requested files. Hugging Face may process this information under its own terms and privacy information. RawCloser does not control Hugging Face's independent server logs or retention practices. RawCloser does not include your email address or any other account identifier in these requests. Hugging Face does not receive call audio, transcripts, notes, coaching data, or AI output from RawCloser.

If you choose to sign in with Google or Apple, you authenticate directly with that provider through its sign-in page in your system browser. The relevant provider processes your sign-in and authentication information under its own terms and privacy policy and acts independently from RawCloser in relation to that processing.

After authentication, the provider returns an authorization result that allows our license server to verify the provider's identity token and receive your verified email address and the identifier for your account with that provider. Our license server then issues RawCloser's own sign-in credential.

RawCloser uses the verified email address and provider account identifier to identify your RawCloser account and sign you in. We store the sign-in information needed for this purpose on your Mac, and our license server stores your email address for licensing. If you sign in with Apple and choose to hide your email address, Apple provides a private relay address instead of your personal email address.

No call recordings, transcripts, notes, or other call content are sent to Google or Apple through this sign-in process. Google and Apple may process information under their own terms and privacy policies. Namecheap hosts infrastructure used by RawCloser and may process data on RawCloser's instructions as a service provider or processor.

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
• Google Ireland Limited in Ireland, and Google LLC in the United States
• Apple Distribution International Limited in Ireland
• Hugging Face
• Namecheap

Google states that it complies with the EU-U.S. Data Privacy Framework, the UK Extension to that framework, and the Swiss-U.S. Data Privacy Framework, and that it relies on Standard Contractual Clauses for transfers that an adequacy decision does not cover.

Apple states that its international transfers of personal data collected in the European Economic Area, the United Kingdom and Switzerland are governed by Standard Contractual Clauses.

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

Hugging Face may process download-request information outside the European Economic Area. RawCloser is reviewing the applicable Hugging Face contracting entity, processing locations, transfer mechanism, and supplementary measures. RawCloser will document that assessment before relying on the Hugging Face service for production downloads involving users in the EEA.

14. Hosting logs

Our website and license 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 raw IP address on the server.

Log retention is 180 days.

To limit abusive requests to the license server, RawCloser maintains a short-lived request counter keyed by a keyed hash of the account email address. The counter is used only for the applicable one-hour rate-limit window and is deleted by a periodic cleanup shortly after that window ends. RawCloser does not store the raw email address in this counter and does not use the counter for advertising or profiling.

The RawCloser license-server records described in section 6 do not contain an IP address or IP hash. This statement does not describe logs maintained by third-party providers that serve the model files, such as Hugging Face, or the hosting provider's logs described above.

Our application's own server log records errors and refused requests. A line may contain a keyed hash of an email address or a salted hash of an IP address, never the address itself, and is kept for 90 days. For example, a refused request for an authorization key is logged with a keyed hash of the email address.

15. Security

We use technical and organizational 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

Data subjects may exercise the following rights, in the cases provided by law, to:

• access your data
• correct your data
• delete your data
• restrict processing
• object to processing based on our legitimate interest
• object at any time to the processing of your personal data for direct marketing purposes
• withdraw consent
• receive a portable copy of certain data

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

You also have the right to lodge a complaint with a data protection supervisory authority. In Italy, this is the Garante per la protezione dei dati personali: https://www.garanteprivacy.it/

17. Retention

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

Examples:

• account data: retained for the duration of the account and afterward for the period necessary to address tax, accounting, dispute, and security obligations, unless a different legal obligation or need applies
• 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
• terms acceptance records: for the life of the account and generally up to 10 years after account termination, as described in §6
• registered-installation records: up to 12 months after the installation was last seen by the license server, including the date of the first key release and the number of key releases
• authorization-key release records: up to 90 days after the release
• license-server request counter: the one-hour rate-limit window, plus the short time until the next periodic cleanup
• license-server application error log: 90 days

Daily advertising-attribution totals are retained for 24 months and then deleted or anonymized further.

The retention periods are based on the time reasonably needed to administer licenses, investigate unauthorized use, respond to support requests, reconcile account activity, and protect the service. RawCloser periodically reviews these periods and deletes the records earlier when they are no longer needed.

Delivery ledger. To manage delivery, retries, and duplicate prevention, RawCloser keeps a limited delivery ledger for up to 14 days. The ledger contains only the event ID, delivery status, completion status, and relevant date and time, together with a restricted internal reference where needed to process withdrawal or deletion requests. It does not contain an email address, hashed email address, event payload, fbc, user agent, IP address, payment details, or call or app content. The ledger is deleted after the retention period.

18. Deletion

If you delete your account, RawCloser deletes the local data associated with the account from the device and rewrites the local database file so that deleted content is no longer retained in unreferenced form. Deletion covers the local data managed by the application; any copies you have exported or kept outside the application are not automatically deleted.

When you delete your account or make a valid erasure request, we delete the account data described in this Policy from our license server, including the registered-installation and authorization-key release records described in section 6. We retain only: the minimum Terms acceptance records necessary to document the contractual relationship, demonstrate which Terms applied, and establish, exercise, or defend legal claims; a coded marker that a free trial was used, for up to 24 months, to prevent abuse of free trials; and, if you asked not to receive our marketing emails, a record of that request so we can continue to honour it. We also record the account termination date solely to calculate the retention period for the Terms acceptance records. Unless a shorter period is justified or a longer period is required by law, the Terms acceptance records are generally deleted or anonymized no later than 10 years after the account termination date. The coded trial-use marker is deleted after the stated 24-month period, and the marketing-suppression record is retained only for as long as necessary to ensure that we do not send you marketing communications.

This deletion does not remove records that Stripe or other independent service providers may retain under their own legal obligations and privacy policies. RawCloser does not control those records. RawCloser may retain only the limited records expressly described in this Privacy Policy, including Terms acceptance records, a coded trial-use marker, and a marketing-suppression record where applicable.

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. Meta advertising measurement

Meta advertising measurement. If you give optional consent through our privacy controls and, where applicable, the lead form, RawCloser may use limited information to measure and improve RawCloser advertising on Meta. The legal basis is your consent under Article 6(1)(a) GDPR. You may withdraw consent at any time.

For ViewContent and Lead events, we may send Meta the Meta click identifier (fbc), the event type, event time, event ID, relevant page URL, and the live browser user agent. These events do not include an email address.

For StartTrial and Purchase events, we may additionally send a normalized email address transformed using SHA-256, but only after you confirm the email address through the single-use confirmation link we send to that address. If you do not complete confirmation, RawCloser does not send your email address, including in hashed form, in any Meta event.

Purchase events may include the amount and currency of the relevant first purchase, including a value of zero where the applicable invoice is zero. We do not send your raw email address, first name, phone number, IP address, postal address, payment details, call content, or app content to Meta.

Meta may receive and process this information as an independent controller under its applicable terms and privacy information. The applicable Meta entity and contractual terms depend on the Meta Business account and service configuration. We will identify the applicable entity and link to the relevant terms when they are confirmed.

We do not send events before valid consent. We do not send events after consent is withdrawn, and we suppress queued events that have not yet been sent. RawCloser retains stored attribution data for no longer than 60 days after the last relevant advertising, trial, purchase, or attribution event. Consent evidence is retained for 3 years after the last relevant consent or withdrawal event, or for a longer period where required to establish, exercise, or defend legal claims. Consent records are minimized and do not include the raw email address unless separately necessary.

Browser storage. After the applicable consent action, RawCloser may store the following limited first-party markers in browser storage on the resources pages: the Meta click identifier for up to 7 days; the consent token for up to 60 days; and a rejection marker for up to 90 days. The markers record or support the visitor's privacy choice and the operation of the optional Meta measurement feature. They are deleted or invalidated earlier when the visitor withdraws consent or when the relevant purpose ends. RawCloser does not use these markers for unrelated advertising or analytics.

Meta may process data outside the European Economic Area. Before activation, RawCloser will document the applicable transfer mechanism, such as the EU–US Data Privacy Framework where applicable or Standard Contractual Clauses, together with any required transfer assessment and supplementary measures.

Withdrawing consent stops future RawCloser transmissions. It does not automatically erase data already received by Meta. You may request that RawCloser delete its related data and, where appropriate, submit a deletion request to Meta. Meta may retain or process data under its own terms and legal obligations.

RawCloser deletes the related data from its own active systems and suppresses queued and future events.

An event that is already being transmitted when you withdraw consent may reach Meta before the withdrawal takes effect. RawCloser attempts to suppress queued events and prevents future events, but cannot recall a request that has already left its systems.

If a technical failure causes an event to be retried, RawCloser uses the event ID to support deduplication. Meta controls deduplication and may apply its own retention and processing rules.

If you do not complete email confirmation, RawCloser does not send your email address, including in hashed form, to Meta. RawCloser may send a confirmation email to the address entered in the form solely to verify control of that address.

Confirmation-email provider. RawCloser uses Resend as a processor to send the email-address confirmation message. RawCloser provides Resend with the email address entered in the form and the information necessary to send and deliver that message. Resend may process limited technical and security information under its applicable terms and documented instructions from RawCloser.

RawCloser is reviewing and will implement Resend's applicable data-processing terms before using Resend for this confirmation flow. Resend is not used to send the Meta event data described in this section.

For US residents, additional rights and opt-out choices may apply, including rights relating to targeted advertising or the sale or sharing of personal information where applicable law applies. RawCloser will honor applicable Global Privacy Control signals and will suppress optional Meta advertising-measurement events where required.

21. Contact