RAPT Ventures, Inc. Privacy Policy

INTRODUCTION

RAPT Ventures, Inc. (“we”, “us”, “our” and “RVI”) is committed to respecting and protecting your privacy. We act in accordance with the requirements of the applicable privacy and data protection laws in the markets where we operate. This privacy policy (“Privacy Policy” or “Policy”) describes how we collect, process, and share Personal Information (defined below) pertaining to our visitors and users of our Services (collectively, “you” and “your”) when you visit or make a purchase from www.raptventures.com or www.raptbaby.com (a “Site” or the “Sites”) or when you interact with our advertising and applications on third-party websites if those applications or advertising include links to this Privacy Policy.

This Policy does not apply to information processed by other third parties, for example, when you visit a third-party website or interact with third-party services, unless and until we receive your information from those parties. Any such processing not done at the direction of RVI is outside the scope of this Policy.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, your choice is not to use our Sites.

WHO WE ARE

RVI is an innovative neuro-technology company specialized in leveraging the power of brain plasticity to develop, support, and maintain healthy brain circuity from the outside in. Our products are available for purchase through our websites, as well as partner retailers. They deliver structured auditory experiences that evoke specific neuronal responses to support the development and maintenance of optimal brain structure, brain function and cognitive processes across all stages of life.

AGREEMENT

This Policy is incorporated into the Terms of Service. Your use of our Services indicates your acknowledgement of the practices described in this Policy.

CATEGORIES AND SOURCES OF PERSONAL INFORMATION

“Personal Information” means any information that identifies or can be used to identify you or your household, directly or indirectly (“Personal Information”). The Personal Information that we collect, and how we collect it, depends on how you interact with us. Examples include, but are not limited to, first and last name, date of birth, gender, occupation, email address, device and IP information, or other demographic information.

SOURCE

We collect Personal Information from various sources, which may vary depending on the context in which we process that Personal Information:

Automatically:	When you visit our Site	We collect Device Information, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We collect this information using the following tracking technologies, among others: “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site. “Flash Cookies” are local stored objects used to collect and store information about your preferences and navigation to, from and on our Sites.
Directly from you when you provide it to us:	When you Contact Us	We may collect Identity Information, Contact Information, and User Information, such as information that you provide by filling in forms on our Sites, records and copies of your correspondence, your responses to surveys that we might ask you to complete for research purposes, or your search queries on the Sites.
Directly from you when you provide it to us:	When you use our services or make a purchase	We collect Identity Information, Contact Information, and Order Information when you make a purchase or attempt to make a purchase through our Site.
From third parties:	Service Providers	From time to time we may obtain information about you from third-party sources, such as our social media platforms or our joint marketing partners. We take steps to ensure that these parties are legally or contractually permitted to share this information with us. We do not control these third parties’ tracking technologies or how they may be used.

HOW WE PROCESS YOUR PERSONAL INFORMATION

GENERAL

We generally process your Personal Information: (i) to fulfill our obligations under a contract with you, or to take steps prior to entering into a contract with you, (ii) to comply with a legal obligation, (iii) when it is in our legitimate business interest to use your Personal Information, or (iv) based on your consent. Our legitimate interests include operating, evaluating and improving our Services and business; preventing and protecting us and others against fraud, unauthorized transactions, claims and other liabilities; and ensuring compliance with company policies and industry standards. Our use of your Personal Information depends on who you are and how you interact with us. When you use our Services, we process your Personal Information in specific contexts and for certain specified purposes, as described below.

WHEN YOU VISIT OUR SITES

When you visit our Sites, we automatically collect and process Identity Information, Device/Network Information, Inference Information, and User Information. We use this data as necessary to provide the Service you request, initiate or fulfill your requests for certain features or functions through our Services. In addition to Device/Network Information, we may also collect and process Contact Information, and Inference Information that we collect, create, and/or receive (including through the use of cookies and similar technologies). We typically use this data as necessary in connection with certain legitimate business interests, such as ensuring the security of our Services and other technology systems, to prevent fraud, and otherwise analyze the use of our Services, to help us develop new features, products, or service, or make improvements, for example, by generating analytics about how our customers browse and interact with the Sites, and to assess the success of our marketing and advertising campaigns.

WHEN YOU CONTACT US

When you contact us we may collect and process Identity Information, Device/Network Information, Contact Information, and any User Information you provide as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes. Additionally where you consent, if relevant to your request, or if otherwise permitted by law, we may send you marketing communications as described further below.

WHEN YOU USE OUR SERVICES OR MAKE A PURCHASE

When you use our services or make a purchase, we may collect Identity Information, Contact Information, Device/Network Information, and Order Information to fulfill any orders placed through the Sites (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).

When in line with the preferences and with your consent, we may use your Inference Information to provide you with information or advertising relating to our products or services, as described below.

INTERNAL PROCESSING AND SERVICE IMPROVEMENT

We may use Personal Information for improving our Services, understanding how our Services are used, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging, and similar purposes.

SECURITY AND INCIDENT DETECTION

We may process Personal Information to improve the security of our Services, to identify and prevent crime, and prevent fraud. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security and anti-fraud activities.

COMPLIANCE, SAFETY, AND PUBLIC INTEREST

We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, to ensure content or advertising is directed to users eligible to participate in advertised services or view such content/advertisements, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law.

AGGREGATED/ANONYMIZED DATA

We process Personal Information about our customers and users in order to identify trends, such as to create aggregated or anonymized data about buying and spending habits, use of our Services, and other similar information (“Aggregated Data”). For example, we may process Aggregated Data to determine aggregate trends, response to various activities, and other aspects of our Services. We may also retain and use this information in connection with the development of products or services. We may pass Aggregated Data to certain third parties to give them a better understanding of our business and to improve our Services. Aggregated Data will not contain information from which you may be personally identified.

MARKETING COMMUNICATIONS

We may send you marketing and promotional communications via email or SMS if you sign up for such communications or purchase products from us. We may also send you these communications if you register for our Services or for a promotion, or in connection with your communications with or submission of User Information to us. These communications may be personalized based on your Consumer Profile. We may also collect Device/Network Information and Contact Information so that we can determine whether you have opened an email or interacted with our communications, and we may generate Inference Information based on these interactions. We may also process this Personal Information for targeted advertising.

CONTEXTUAL ADVERTISING

We operate contextual advertisements on our Service. We generally use data collected in this context as appropriate for the purpose of marketing our Services, our sponsors, or advertisers. We may display advertising customized to users’ location and other contextual factors (such as time of day, events, etc.) and the requirements of local law or to comply with local legal restrictions.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your Personal Information with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific purposes, each described below.

On Our Blog	We may have public blogs on our Sites. Any information that you include in a comment on our blog may be read, collected and used by anyone. If your Personal Information appears on our blogs and you want it removed, please contact us at [email protected].
Shopify and Payments	Our shopping site is hosted by Shopify. Shopify provides us with the online e-commerce platform that allows us to sell our products to you. Your data is stored securely through Shopify’s data storage, databases and the general Shopify application. We use third parties for secure credit card processing and these third parties collect your information to process your orders and credit card payments. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
Other Affiliates	We will share Personal Information with our employees, contractors, third party service providers and affiliated organizations that need to know that information in order to process a purchase order, and who are bound by contractual obligations to keep such information confidential and use it only for the purposes for which we disclose it to them. For example, your postal address will be sent to a carrier that needs to ship you a product. We may share Personal Information with third parties to market their products or services to you if you have consented to these disclosures. We contractually require any such third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. We also use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Data Aggregators	Some content or applications, including advertisements, on the Sites may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. To learn more about this practice, and to learn about your choices in connection with it, please visit the digital advertising Alliance’s Self-Regulator Program for Online Behavioral Advertising at www.aboutads.info or the Network Advertising Initiative at www.networkadvertising.org.
Corporate Events	Your Personal Information may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Information may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
Legal Disclosures	In limited circumstances, we may, without notice or your consent, access and disclose your Personal Information, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Service or a customer agreement, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Information as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Information to such parties.

YOUR RIGHTS AND CHOICES

We take reasonable steps to ensure that the data we collect is accurate, complete and up to date. After you purchase a product or opt-in to receive updates from us, you may update your Personal Information, or withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected] or mailing us at RAPT Ventures, Inc., 1345 Avenue of the Americas, 33rd Floor, New York, NY, 10105.

You also have the right to complain to a data protection authority about the collection and use of Personal Information. If you no longer want to receive information from us, please utilize the unsubscribe functionality that we use or contact us at [email protected]. If you contact us directly, we may remove or update your information within a reasonable time and only with your consent or direct request. If you make a direct request to us, we may ask you to verify your identity to ensure that your Personal Information is protected.

Our Services do not respond to your browser’s do-not-track request. If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Privacy Policy, or Google Analytics Opt-out.

DATA SECURITY

The security of your Personal Information is important to us, but no method of transmission over the Internet, or method of electronic storage, is 100% secure. We will maintain appropriate administrative, physical, and technical safeguards for protection of the security, confidentiality and integrity of your Personal Information.

RETENTION OF PERSONAL INFORMATION

We retain Personal Information where we have an ongoing legitimate business or legal need to do so.

Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria to determine retention period:

Whether we have a legal or contractual need to retain the data,
Whether the data is necessary to conduct our business,
Whether you can access and delete the data, and
Whether you would reasonably expect that we would retain the data until you remove it.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in back-up archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible

MINORS

Our products are intended for parents and are not directed at children. We request that children under the age of 18 not provide any Personal Information on our Sites. Further, we do not knowingly collect Personal Information from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.

INTERNATIONAL TRANSFERS

We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Information may be transferred to the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Information in foreign countries. Contact us for more information regarding transfers of data to the U.S.

CHANGES TO OUR POLICY

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Any such changes will be posted on this page. We encourage you to frequently check this page for any changes to our Privacy Policy. Your continued use of the Sites after any change in this Privacy Policy will constitute your acceptance of the change.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:

RAPT Ventures, Inc.

1345 Avenue of the Americas, 33rd Fl.

New York, NY 10105

Identity Information:	Personal Information about you and your identity, such as your name, username, biographic/profile data, employer information, and other Personal Information you may provide on registration forms or as part of an account profile.
Contact Information:	Information such as your name, address, email address, telephone number, username, or account login details.
Device/Network Information:	Information regarding your interaction with our Services or advertisements (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, advertiser ID, or device characteristics.
Inference Information:	Personal Information used to create a profile about you reflecting your preferences (such as the services you seem to prefer based on use of our Services), as well as your characteristics, likes, interests, and other data or analytics provided about you by social media companies or data aggregators.
Order Information:	Personal Information we collect in connection with a transaction or purchase, such as your order, the price, and other similar information.
User Information:	Information such as unstructured/free-form data that may include any category of Personal Information, e.g. data that you give us in free text fields such as comment or feedback boxes and in-app support, live chat, Personal Information you provide when you complete forms, surveys, or when you provide to be published or displayed (“posted”) on public areas of the Sites, or transmitted to other users of the Sites or third parties. Your User Information is posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Sites with whom you may choose to share your User Information. Therefore, we cannot and do not guarantee that your User Information will not be viewed by unauthorized persons. If you delete your User Information from the Sites, copies of your User Information may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Information, is governed by our Terms of Service.