1. INTRODUCTION
This Privacy Policy describes how Raise-22 ("we," "us," or "our") collects, uses, and shares information about you when you use our mobile application and related services (collectively, the "Services").
By creating an account and using our App, you agree to the collection and use of information in accordance with this policy. If you do not agree to these terms, please do not create an account or use our Services.
2. INFORMATION WE COLLECT
2.1 Information You Provide During Registration
To use our App, you must create an account. During registration and use of our Services, we collect:
- Email Address (required for account creation and authentication)
- Nickname/Username (chosen by you for display within the App)
- Payment Activity (subscription status, purchase history, payment dates)
- Account preferences and settings
2.2 Information We Collect Automatically
When you use our App, we automatically collect certain information about your device and usage:
Device Information:
- Device ID (unique identifier for your device)
- Device Type (Android or iPhone/iOS)
- Operating system version
- App version
Usage and Progress Data:
- Learning progress through lessons and modules
- Quiz attempts, scores, and completion rates
- Time spent on different sections and features
- Training exercises completed
- Performance metrics and statistics
- Feature usage patterns
- Session duration and frequency
- In-app navigation paths
2.3 Information We Do NOT Collect
We want to be clear that we do NOT collect:
- Real names or personal identification beyond nickname
- Credit card numbers or sensitive payment details (processed by third-party payment providers)
- Location data
- Phone numbers
- Social media profiles
- Photos or media from your device
- Contacts or address book information
Note: While we track payment activity (subscription status, purchase history), we do not store or have access to your actual payment card information, which is handled securely by our payment processors.
3. HOW WE USE YOUR INFORMATION
We use the collected information for specific purposes, each with a legal basis for processing:
3.1 Contract Performance
Legal Basis: Necessary for the performance of our contract with you
- Provide Core Services: Enable account creation, authentication, and access to app features
- Track Learning Progress: Monitor your advancement through training modules and save your progress
- Process Payments: Manage subscriptions, verify payment status, and maintain purchase history
- Personalize Experience: Adapt difficulty levels and content based on your performance
- Technical Support: Respond to support requests and troubleshoot issues
3.2 Legitimate Interests
Legal Basis: Necessary for our legitimate interests (or those of a third party)
We have a legitimate interest in improving our services and protecting our business:
- Improve Our Services: Analyze usage patterns to enhance app features and content
- Analytics: Understand how users interact with our app to improve functionality
- Security: Detect and prevent fraudulent or unauthorized access, protect against abuse
- Bug Detection: Monitor app performance and fix technical issues
3.3 Consent
Legal Basis: Based on your consent
- Marketing Communications: Send promotional emails about new features or content (only if you opt-in)
- Optional Features: Process data for any optional features you choose to enable
You may withdraw consent at any time through account settings or by contacting us.
3.4 Legal Obligations
Legal Basis: Necessary to comply with legal obligations
- Financial Records: Maintain transaction records as required by tax and accounting laws
- Legal Compliance: Retain data as required by applicable laws or legal proceedings
- Fraud Prevention: Process data to prevent illegal activities
3.5 Vital Communications
Legal Basis: Contract performance and legitimate interests
- Essential Notifications: Send critical account-related communications such as:
- Security alerts and breach notifications
- Payment confirmations and billing issues
- Terms of Service or Privacy Policy updates
- Account verification and authentication
Note: You cannot opt out of essential communications as they are necessary for service operation and security.
4. DATA STORAGE AND SECURITY
4.1 Where We Store Your Data
Your information is stored on secure servers provided by our hosting services. Data may be processed and stored in various locations globally, but always with appropriate security measures.
4.2 Security Measures
We implement industry-standard security measures including:
- Encryption of data in transit and at rest
- Secure authentication protocols
- Regular security audits and updates
- Limited access controls for our team
- Protected API endpoints
While we strive to protect your information, no method of electronic storage is 100% secure. We cannot guarantee absolute security but commit to maintaining reasonable safeguards.
5. SHARING OF INFORMATION
We do not sell, rent, or trade your personal information. We may share your information only in these limited circumstances:
- Service Providers: With trusted third parties who assist in operating our app (e.g., cloud hosting, analytics)
- Legal Requirements: When required by law, court order, or government request
- Business Transfers: In the event of merger, acquisition, or sale of assets
- Protection of Rights: To protect our rights, property, or safety, or that of our users
- With Your Consent: When you explicitly agree to sharing
6. DATA RETENTION
We retain your account information for as long as your account remains active. Progress and activity data is retained to maintain your learning history and provide continuous service.
6.1 Account Deletion
You can delete your account directly through the app:
- Navigate to: Menu (☰) → Settings → Account → Delete Account
- Follow the confirmation prompts to complete deletion
- Your account and associated data will be permanently removed
6.2 What Gets Deleted
Upon account deletion, we permanently remove:
- Account information (email address, display name)
- Training progress and quiz history
- User preferences and app settings
- Achievement data (badges, streaks, completion records)
- User profile data and skill level selections
6.3 Limited Data Retention for Legal Compliance
Following deletion, we may retain certain anonymized data as required by law:
- Financial Records: Anonymized transaction records retained up to 7 years for tax/accounting purposes
- Analytics Data: Aggregated, anonymized usage statistics that cannot identify you
- Legal Compliance: Data required for fraud prevention or legal proceedings
7. YOUR RIGHTS AND CHOICES
7.1 Account Management
Through the app's settings menu, you can:
- Access and update your account information
- Change your nickname and preferences
- View your complete progress and activity history
- Export your data (via email request to info@raise22.com)
- Reset your training progress while keeping your account
- Delete your account and all associated data
To delete your account:
- Open the Raise-22 app
- Tap the menu (☰) in the top-left corner
- Select "Settings" → "Account"
- Tap "Delete Account" and follow confirmation prompts
To request data export: Email info@raise22.com with subject "Data Export Request" - we'll provide your data within 30 days.
7.2 Data Rights
Depending on your location and the legal basis for processing, you may have the following rights:
For All Users:
- Right to Access: Request a copy of your personal data
- Right to Rectification: Correct inaccurate or incomplete information
- Right to Erasure ("Right to be Forgotten"): Delete your personal information (via in-app deletion)
- Right to Data Portability: Receive your data in a structured, machine-readable format
Additional Rights Based on Legal Basis:
Where processing is based on Consent:
- Right to withdraw consent at any time
- Withdrawal doesn't affect lawfulness of prior processing
Where processing is based on Legitimate Interests:
- Right to object to processing
- We will stop processing unless we have compelling legitimate grounds
Where processing is for Direct Marketing:
- Absolute right to object at any time
- We will immediately stop processing for marketing purposes
Right to Restriction:
- Request we limit processing while disputes are resolved
- Applies when accuracy is contested or processing is unlawful
Automated Decision-Making:
- Right not to be subject to solely automated decisions
- Currently, we do not use automated decision-making that produces legal effects
To exercise these rights, contact us at privacy@raise22.com. We will respond within 30 days. We may request identity verification to protect your data.
7.3 Communication Preferences
You can opt out of non-essential emails through your account settings or by using the unsubscribe link in our emails. Note that you cannot opt out of critical account-related communications.
8. CHILDREN'S PRIVACY
Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected information from a child under 18, we will delete that information promptly.
9. INTERNATIONAL DATA TRANSFERS
Your information may be transferred to and processed in countries other than your own. These countries may have different data protection laws. We ensure appropriate safeguards are in place for such transfers in compliance with applicable laws.
For European Union users, we comply with GDPR requirements for international data transfers.
10. THIRD-PARTY SERVICES
Our app may use third-party analytics services (such as Google Analytics) to help us understand app usage. These services may collect information about your device and usage patterns. They have their own privacy policies governing their data practices.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy periodically. We will notify you of material changes by:
- Posting the updated policy in the app
- Sending an email notification to registered users
- Requiring acknowledgment upon next app login for significant changes
The "Last Updated" date at the top indicates the most recent revision. Continued use after changes constitutes acceptance of the updated policy.
12. CONTACT US
If you have any questions about this Privacy Policy or our data practices, please contact us:
For data export requests, email info@raise22.com with subject "Data Export Request"
For data protection concerns, you also have the right to lodge a complaint with your local data protection authority.