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

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.

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, timestamp and language

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
• Terms acceptance records (see "Terms acceptance records" below)
• a marker recording that a trial was taken

The licence 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 unauthorised alteration or deletion, on our licence 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 anonymise 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.

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 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

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 synchronise 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 synchronised 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 synchronises 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 recognise 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 organiser, 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 and sign-in providers

We use the following providers for specific operational purposes:

• Resend for email delivery
• Google Ireland Limited for sign-in with a Google account
• Apple Distribution International Limited for sign-in with an Apple Account
• 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

If you choose to sign in with Google or with Apple, you authenticate with that provider directly, on the provider's own sign-in page. The provider learns that you are signing in to RawCloser, and returns to us a verified email address and an identifier for your account with that provider. We use both only to identify your account and to sign you in. If you sign in with Apple and choose to hide your address, we receive Apple's private relay address instead of your own. No call recordings, transcripts, notes or other call content is sent to either provider.

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
• 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.

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

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

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 licence server. 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 anonymised 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. Contact