Privacy Policy

Personal information we collect

‍Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
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• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, and age.
• Profile data, such as your username and password.
• Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise. We may collect and maintain a record of your communications, and our responses, and maintain a recording of calls and/or transcriptions of such calls. Such recordings may capture your voice, image, communications and group chats during the calls, as well as other personal information.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Screening data, such as ownership rights and interests in companies.
• Government-issued identification data, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), and an image of the relevant identification card.
• Other data, not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
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‍Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
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• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as our business customers, data providers, social media platforms and data licensors.
• Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
• Marketing partners, such as joint marketing partners and event co-sponsors.
• Third-party services, such as social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

‍Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
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• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through the use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
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‍Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

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How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

‍Service delivery and operations. We may use your personal information to:

• provide and operate the Service and our business;
• personalise the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate;
• understand your needs and interests, and personalise your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

‍Research and development. We may use your personal information for research and development purposes, including to analyse and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymised data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymised data and share it with third parties for our lawful business purposes, including to analyse and improve the Service and promote our business.

‍Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for the following marketing purposes:
• Direct marketing. We may send you direct marketing communications, including our newsletter where you have provided your consent. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
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‍Events. We may use your personal information to administer events that we organize or sponsor.

‍Service improvement and analytics. We may use your personal information to analyse your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

‍Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities, and to comply with our anti-money laundering, Know-Your-Customer, and/or similar obligations;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

‍With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

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Retention

We generally retain personal information to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymise it, or isolate it from further processing.

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How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

‍Affiliates. Our corporate parent, subsidiaries, and affiliates.

‍Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

‍Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.

‍Business partners. For example, third parties with whom we co-sponsor events and those with whom we jointly offer services.

‍Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

‍Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

‍Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Raft, financing of Raft, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Raft as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

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Call recordings

We are committed to delivering the best service experience to our customers and we are proud to research and implement new solutions that will help us to maintain and improve our customer service.

We have partnered with selected service providers to enable within our communication systems AI call recording, transcription and analytical tools which interact with our voice and video communication tools to improve our Services and train our personnel (“Recording Tools”).

‍How do these Recording Tools work?
‍Our Recording Tools use AI-backed algorithms to record calls, create transcripts, extract relevant information for call summaries and analytics and make intelligent recommendations to allow us to:
• ensure we have up-to-date information on our contacts and interactions so we can provide you and your colleagues with a more joined up service;
• have a faster and better understanding of our interactions with you so we can provide you and your colleagues with an enhanced customer experience; and
• review and improve the quality and effectiveness of our sales and customer service efforts, customer onboarding, product implementation, and technical integration.

After each call, we will share a link with you so that you can also access the recording.

‍What personal information will we collect?
‍We will only collect your contact data and communications data as set out in the “personal information we collect” section above in respect of the Recording Tools.

Please note that we do not collect or process any sensitive personal information of any kind while using Recording Tools.

If you ever contact us and request access or deletion of your recordings, we will need a way to identify the right recordings. We will use the details that we collect about you, such as your name, email address, time of the call, Internet Protocol (IP) address and your browser type for this purpose.

Finally, we require that each Recording Tool will process your personal information only for the limited purposes set out above, exclusively in accordance with our written instructions, and pursuant to its contractual obligations to us.

‍How long will we keep your personal information? We will retain the call recordings for 12 months, or longer if it is required by applicable law. After this period, the recordings will be securely deleted. The call transcripts, summaries and other information derived from the recordings will be retained by us for a period of three years, after which we may either delete them or anonymise them.

‍Your consent
‍We rely on your consent to record the calls you participate in using a Recording Tool. We will never and cannot use a Recording Tool to record your calls if we have not received your consent. As such, before joining a call you will be asked to read the “Recording Consent Disclaimer” for the relevant Recording Tool, found here https://www.raft.ai/privacy, and actively “opt-in” to use a Recording Tool to record your call. You will be asked to give your consent every time you join a call with us, otherwise we will not record it.

‍“Opting out”
‍You can always withdraw your consent to the call recording at any time, even during an active call or afterwards.

• If you change your mind during a call, please let the Raft representative you are speaking with on the call know and they will be able to deactivate the Recording Tool mid-call. The partial recording will be immediately deleted.
• If you change your mind after you have had your call with us, please contact us at compliance@raft.ai. We will immediately proceed to delete the recording (unless we are required to keep it to comply with our legal obligations).

‍The Recording Tools safe?
‍We appreciate that AI is generally considered a high-risk technology. However, your security and privacy are our top priority. As such, we have taken steps to assess the risks associated with the use of each of our selected Recording Tools, and we have implemented appropriate technical and organisational measures to sufficiently mitigate them.

If you would like further information on how a particular Recording Tool works, and the measures we have implemented to protect your privacy and security, please do not hesitate to contact us.

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Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights in the Notice to European Users section.

‍Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

‍Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice (https://www.raft.ai/raft-documentation-portal).

‍Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

‍Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

‍Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

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Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

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Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect.

Our third-party service providers will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees and other third-parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where Raft is legally required to do so.

However, you should be aware that the transmission of information and data is never completely secure and there is a measure of risk associated with the use of any online service. As such we cannot guarantee the security of your personal information.

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International data transfers

We may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

‍Users in Europe should review the Notice to European Users section for information on international data transfers from Europe.

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Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us using the details in the ‘How to contact us’ section. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

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Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

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How to contact us

• Email: compliance@raft.ai

‍• Mail: Raft, 55 Southwark Street, London, England, SE1 1RU

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Notice to European Users

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General

Where this Notice to European Users applies. The information provided in this “Notice to European Users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

‍Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). In the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified.

Sensitive personal information. References to “sensitive personal information” in this Privacy Policy should be understood to include a reference to “special category data” as defined in the GDPR.

‍Controller. Raft is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

‍Our EU GDPR Representative: Our EU representative appointed under the EU GDPR is DataRep. You can contact them by using the following details:

• By email to: datarequest@datarep.com
• Online: www.datarep.com/data-request
• By post to: mail your inquiry to DataRep at the most convenient of the addresses listed here (DataRep EU EAA Contact Locations 2024 found at https://www.raft.ai/raft-documentation-portal) [Please ensure to post your request addressed to “DataRep”.]

‍Our UK Data Protection Officer. We have appointed a “Data Protection Officer”, this is a person who is responsible for independently overseeing and advising us in relation to our compliance with the UK GDPR (including compliance with the practices described in this Privacy Policy). If you want to contact our Data Protection Officer directly, you can email: privacy@dataguard.co.uk.

We are registered with the UK Information Commissioner’s Office (ICO) under number ZB235836.

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Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

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Service delivery and operations

Categories of personal information involved

• Contact data
• Demographic data
• Profile Data
• Communications data
• Data from Third Party Services
• Device data

Legal Basis

• Contractual Necessity
• Legitimate Interests - We have a legitimate interest in supplying our services to our customers.

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Research and development

Categories of personal information involved

• Contact data
• Demographic data
• Communications data
• Device data
• Online activity data
• Communication interaction  data

Legal basis

• Legitimate Interests - We have a legitimate interest in improving our business by understanding more about how endusers make use of our Services and platform.

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Direct marketing

Categories of personal information involved

• Contact data
• Demographic data
• Communications data
• Marketing data

Legal basis

• Legitimate Interests - We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose.
• Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications

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Events

Categories of personal information involved

• Contact data
• Demographic data
• Communications data
• Marketing data

Legal Basis

• Contractual Necessity to administer the event(including communicating with you as andwhere necessary)
• Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications

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Service improvement and analytics

Categories of personal information involved

• Contact data
• Demographic data
• Communications data
• Device data
• Online activity data
• Communication interaction data

Legal Basis

• Legitimate Interests - We have a legitimate interest in providing you with a good service, which is personalised to you and that remembers your selections and preferences.
  
  We rely on legitimate interests for the transcription and analysis of any call recordings.
• Consent, in respect of any optional cookies used for this purpose and/or recording of calls.

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Compliance and protection

Categories of personal information involved

• Any and all data types relevant in the circumstances

Legal Basis

• Compliance with Law
• Legitimate Interests - Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.

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Further uses

Categories of personal information involved

• Any and all data types relevant in the circumstances

Legal Basis

• The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected.
• Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected

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Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

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Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Information. Be informed about how your data is used.
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to contact@raft.ai or our postal address provided in the ‘How to contact us’ section. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfil any request you make will depend on a number of factors (e.g., why and how we are processing your personal information and the relevant legal basis), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

• For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
• For users in the United Kingdom – the contact information for the UK’s data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

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Data processing outside Europe

Many of our service providers, advisers, partners or other recipients of data are based in the U.S. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
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It is important to note that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
• Transfers to territories without an adequacy decision. ‍
• ‍We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above).
• However, in these cases
• we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
• in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.