Privacy Policy

This Privacy Policy (the “Policy”) governs the manner in which Raistone Capital LLC, Raistone Purchasing LLC and our affiliates (“Raistone”, “we”, “our” or “us”) collect, use, maintain, retain, share and disclose personal data about you, as an individual.

This Policy applies to the Site and all products and services offered by Raistone (“Services”) except as follow:

1. California Residents.  If you are a resident of California, see here for additional privacy policy terms applicable to you.
2. EU Citizens.  If you are a citizen of the European Union, see here for additional privacy policy terms applicable to you.

Helpful Definitions:

• “personal data” is data identifying you or your household or which relates to identifying you or your household.  “personal data” is not aggregated anonymized data.
• “Company” and the phrase “your Company” is the business or company which employs you or for which you are a representative.  Examples of “representative” are you as an employee, officer, director, manager, shareholder, member or other principal of the business or company.

1. What Information We Collect

In general, we collect personal data:

• from you when you visit www.Raistone.com (the “Site”); or
• when you or your Company interact or communicate with Raistone; or,
• where your Company does business with or through Raistone and personal data is collected about you in connection with such business; or
• where either your Company or Raistone communicate with the other for the purpose of reviewing information about the other, or of considering or conducting business with each other and personal data is collected about you in connection with such communication; or
• from other sources.
• When another party serves as a referral source to us, as a data broker to us or as a verification source for us and the other party provides personal data to us about you, we collect that personal data.  
• Information regarding your interactions with our Site or any Services.

The personal data that we may collect is:

• your name, email address, postal address, street address and phone number
• your title, department, industry and location
• your alias, unique personal or online identifier
• your signature,
• your demographic information (such as date of birth, age, ethnicity, race, gender, marital status)
• the name of your Company and the email address, postal address, street address, phone number, industry, location and other profile information of or about your Company.

You may refuse to supply personal data, however, that may prevent you from engaging in certain Site and/or Services related activities. Access and use of our Site and Services are subject to this Privacy Policy.

Your IP address, along with cookies, may be used to help identify you and gather basic information. We may create anonymous records from personal data by excluding information (such as your name and company) that makes the information personally identifiable. Among other uses, we may use this anonymous information for any lawful business purpose including, to direct future development, to analyze usage patterns so that we may enhance our services, and to provide reports based on anonymous non-personal identifiable information. We reserve the right to use and disclose anonymous information to third parties, at our discretion. 

2. How We Use Information We Collect

We may use your personal data for the following purposes:

• Evaluate your or your Company’s financial information
• providing the Site and Services to you or your Company
• enhancing, improving and developing existing or new features, products and services
• maintaining, repairing, fixing, debugging, diagnosing, administering and supporting the Site and Services
• audit, compliance, policy, procedures, regulation, financial reporting and accounting
• informing third parties who purchase your Company’s invoices with information about you and your relationship to your Company or the invoices
• your Company claims and fraud investigation and prevention
• customer relationship management
• general business administration
• marketing our products and services
• website optimization and maintenance
• systems and data security
• maintaining and servicing accounts

3. How We Share Information We Collect

Personal data we collect may be shared with Raistone’s third party service providers, who help with parts of our business operations (such as, but not limited to, funding, fraud prevention, payment processing, marketing, and technology services). 

Personal data we collect may also be shared in accordance with any definitive written agreement entered into between you or your Company and Raistone or its affiliates.  

Personal data we collect may shared with third parties who provide remarketing, or targeted advertising, services to us.

We may disclose your personal data: to law enforcement, government officials, or other third parties in order to comply with applicable law, subpoena, court order or similar legal process or procedure; where we believe, in good faith, that the disclosure of such information is necessary or prudent to prevent, or assist in preventing, physical harm or financial loss; to report suspected illegal activity; or to request or provide specific permission to share such information. 

Other websites may be accessible through our Site, including by our inclusion or offer of third-party products or services or by providing links to sites that are owned and operated by these third-party providers. These third-party providers may have their own privacy policies or other available data collection use and disclosure practices. Please consult each website’s privacy policy or such other available information, as the policies and practices of these third-party sites are not covered by our Policy. We do not control their collection of information, and therefore have no responsibility or liability for the content and activities of these linked sites.

We may disclose, share or assign your personal data with any businesses or persons in connection with any, or any potential, merger, sale, acquisition of or by Raistone or any transfer or assignment of any of the assets of Raistone.

4. How We Retain and Protect Information We Collect

Personal data collected about you will be retained for as long as you remain an active user of the Site, as needed to provide you or your Company the Services, and for some time after in case you or your Company decide to re-activate the Services.  We also reserve the right to retain your personal data for longer periods for any lawful purpose.  We will also retain and use your personal data as required in order to comply with our legal obligations, resolve disputes, and to enforce our agreements.  

While Raistone takes the security and privacy of your personal information seriously and while Raistone maintains physical, electronic, administrative and procedural safeguards and personnel policies intended to be consistent with applicable laws, no method of data transmission over the Internet, or method of electronic or digital storage, can be guaranteed to be absolutely secure. 

5. Google Analytics and Remarketing

We use Google Analytics on our Site.  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic with other Google services.  Google may use the collected data to contextualize and personalize ads of its own advertising network.  For more information on Google Analytics click here “How Google uses data when you use our partners’ sites or app” www.google.com/policies/privacy/partners/

We use remarketing through Google.  As such advertisements for Raistone or our Site will appear on other websites that you visit.  Also, Google and other third-party vendors will show our advertisements on websites you visit after visiting our Site; and, such advertisements will be shown because you visited our Site (whether recently or in the past).  You can opt-out of the remarketing campaign through the Google Ads Settings page.

You can further opt-out of having made your activity on the Site or with the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on.  The add-on is generally understood to prevent the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about your activity on the Site or with the Services. 

For more information on the privacy practices of Google, please visit the Google Privacy web page https://policies.google.com/privacy.

6. Cookies

We use, and allow certain third parties to use, cookies, web beacons, and other similar capture or tracking technologies to enhance the Services and to help collect data. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive or like storage until you delete them, or until they are set to expire. You can control the use of cookies at the individual browser level. If you reject cookies, your ability to use some features or areas of our Site may be limited.

7. Children’s Privacy

Our Site and Services are not intended for children.  We do not direct our Site or Services to children under the age of 13 or knowingly attempt to solicit or receive information from children.

8 . Changes to this Privacy Policy

Raistone may revise this Policy at any time by updating this page on the Site and in such event your continued use of the Site or Services shall constitute your acceptance of such updated Policy. Accordingly, you should visit this page from time to time to review the then-current Policy because it is binding on you. Certain provisions of this Policy may be superseded by expressly designated legal notices or terms located on particular pages at the Site. All agreements, notices, disclosures and other communications that we provide to you electronically or posted on the Site shall satisfy any legal requirement that such communications be in writing if such requirements are applicable. 

9. Contact Us

For more information regarding this Policy, or if you have any questions or concerns, you may contact us in the following ways:

You may contact Raistone at c/o Raistone Capital LLC at the following address:360 Madison Avenue, 22nd Floor, New York, NY 10017, Attn: General Counsel, by calling our toll-free phone number:  888-626-6593, or by emailing us: privacy@raistone.com

10. California Privacy Policy: California Residents

The California Consumer Privacy Act (CCPA) requires us to provide some additional info to California residents, which we explain below. This page supplements our Privacy Policy.

CPRA: Pursuant to the California Consumer Privacy Act, California residents have the following specified rights:

• If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations. Please understand, however, that these rights are not absolute and are subject to exceptions, and we may be required or permitted by law to decline your request. In addition, we will not be able to process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold or shared;
• The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
• The business or commercial purpose for collecting or selling or sharing the personal information; and
• The specific pieces of personal information we have collected about you.

In addition, you have the right to correct or delete the personal information we have collected from you. These rights apply to sensitive personal information.

• Right To Limit Use and Disclosure of Sensitive Personal Information. You have the right, at any time, to direct us to limit our use of your sensitive personal information (but only if collected or processed with the purpose of inferring characteristics about you) to that use which is necessary for us to perform certain services or provide certain goods. However, as we may use, or disclose to a Service Provider or Contractor, your sensitive personal information (which was collected or processed with the purpose of inferring characteristics about you) beyond that use described above, you have the right to limit the use or disclosure of your sensitive personal information.

•  Right To Opt-Out Of Sale Or Sharing. Under the CPRA, you have a right, at any time, to direct us not to “sell” or “share” your personal information with “third parties” (as such terms are defined under the CPRA).  To be clear, “third parties” are not our Contractors or Service Providers.     

• Right Of No Retaliation Following Opt-Out or Exercise Of Other Rights. Under the CPRA, you have a right for us to not discriminate against you because you exercised any of your rights under the CPRA.  Your right is qualified by certain other provisions in the CPRA.  

To exercise the above rights, you may submit your request in an email to Privacy@raistone.com and include in the subject line the phrase “Your California Privacy Rights,” and include your name, email address or mailing address.  

The chart below summarizes the personal information we collect and use by reference to the categories of personal information specified in the CPRA. It describes our current practices as well as our practices during the 12 months preceding the effective date of our Privacy Notice. Information you voluntarily provide to us, such as in free-form webforms or posts on some of our websites, may contain additional categories of personal information not described below Information you voluntarily provide to us, such as in free-form webforms or posts on some of our websites, may contain additional categories of personal information not described below.

Categories of Personal Information Collected	Business and Commercial Purposes for Collecting, Using, and Disclosing	Parties That May Receive Personal Information, “Sold” Or “Shared”
Identifiers, including name, email address, mailing address, phone number; Personal information categories listed in the California Customer Records statute, including name, mailing address, phone number; Internet or other electronic network activity information, including information regarding the device and browser you use, network connection, IP address, and how you browse through our apps and sites; Geolocation data, including your mailing and billing address; Inferences, or information derived from other personal information about you, which could include your preferences, interests, and other information used to personalize your experience; Other information you provide; and Sensitive personal information, which may include: Government-issued identifiers, including social security, driver’s license, state identification card, or passport number; Your account access credentials (such as account log-in, financial account,  password, or credentials allowing access to an account); Your device’s precise location; Information you voluntarily disclose that may reveal certain characteristics about you such as your racial or ethnic origin or sexual orientation; Education, professional or employment related information	Provide the Raistone servicesCommunicate with you to provide updates or respond to your comments and questions Audit the Raistone servicesDetect security incidents and prevent fraud, debug and repair errorsMaintain your account Provide customer serviceConduct research and development and other activities to improve the Raistone servicesUnderstand how users interact with the Raistone services	Companies who help us provide you with our services, including cloud storage providers, payment processors, security vendors, email providers, marketplaces and data analytics vendors;Advertisers and marketing vendors;Partners who provide a range of services to merchants, such as by developing apps or themes for use by merchants, serving as an affiliate that refers potential merchants to us, or helping merchants build or manage stores;Law enforcement or other third parties in connection with legal requests, to comply with applicable law or to prevent harm.

Why we collect and share your Personal Information

We use and share your personal information for the purposes set out in the Policy. For categories of sensitive personal information that we collect, we only use or disclose such information either with your specific consent when required, or as otherwise permitted by law.

Sources of Personal Information

To make your experience better, we collect and use personal information provided by:

You: We collect the information you provide when you use our platform, including when you visit and/or sign up on Raistone’s Site, fill in order information, or contact Raistone support. We collect account and payment information you provide to us (including information about your business if you are a merchant).  

Your device(s): We collect information from and about the devices you use, including computers, phones, and other web-connected devices you use to access our apps or services, and we combine this information across different devices you use.

Third parties: We receive information from partners who help us provide you with our services including the following:

Service Providers. We receive information from our service providers, who help us provide services to our clients.

Subprocessors. We work with third party subprocessors for cloud hosting, content delivery, data analysis, internal logging, fulfillment services and email transmission, among others, to provide you with our services.  

Analytics and cookie providers. We receive information through our use of cookies, social plugins (such as the Facebook “like” button), pixels and tags for business purposes, such as providing information to help measure how users interact with our website content. For more information about how we use these technologies, see our Cookie Policy.

CALIFORNIA “SHINE THE LIGHT” (CA Civil Code 1798.83)  California law permits residents of California to request certain details about how their personal information is shared with third parties for direct marketing purposes.  California residents may make such request by emailing at Privacy@raistone.com and specifying that you are making a “California Shine the Light Request,” but may not make such requests more than once during the course of any calendar year.

CALIFORNIA “DO NOT TRACK” DISCLOSURE. You may have set your privacy preferences on your internet browser to not track your usage and browsing history.  In other words, you may have turned on “DO NOT TRACK” in your internet browser.  However, our Site does NOT respond to or honor such preference or setting.  In other words, even if you have turned on “DO NOT TRACK” in your internet browser, Raistone nevertheless DOES TRACK your activity on our Site and use that information as provided in this Policy.