`PRIVACY POLICY  

Effective from June 10th, 2019  

RAVEN GROUP FILIP MACIEJEWICZ (“ RAVEN GROUP FILIP MACIEJEWICZ ”, “ Company ”, “ our ,” “ we ” or “ us ”) is committed to respecting your privacy. This Privacy Policy describes how RAVEN GROUP FILIP MACIEJEWICZ collects, uses, discloses, stores and otherwise processes information when you use our websites (“ Websites ”) and other services (such services together with the Websites, the “ Services ”). We urge you to read this Privacy Policy so that you understand our commitment to your privacy.  

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU ARE LOCATED OUTSIDE OF THE UNITED STATES, PLEASE BE AWARE THAT INFORMATION WE COLLECT WILL BE PROCESSED AND STORED IN THE UNITED STATES, A JURISDICTION IN WHICH THE DATA PROTECTION AND PRIVACY LAWS AND PRINCIPLES, INCLUDING YOUR DATA SUBJECT RIGHTS, MAY NOT OFFER THE SAME LEVEL OF PROTECTION AS THOSE IN THE COUNTRY/REGION WHERE YOU RESIDE OR ARE A CITIZEN. BY USING OUR SERVICES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF THE INFORMATION IN THE UNITED STATES AND, UNLESS OTHERWISE STATED IN THIS PRIVACY POLICY, VIRAL LAUNCH USES THIS CONSENT AS THE LEGAL GROUND FOR THAT DATA TRANSFER. WHEN COLLECTING YOUR PERSONAL DATA FOR THE USE OF OUR SERVICES, YOU MAY BE ASKED FOR YOUR EXPLICIT CONSENT TO THIS DATA TRANSFER AS PART OF ACCOUNT CREATION.  

Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read, understand and agree to all terms within this Privacy Policy. If you do not agree with any part of this Privacy Policy, please do not access or continue to use any of the Services or otherwise submit your Personal Data to RAVEN GROUP FILIP MACIEJEWICZ.  

Note to Residents of the European Union : In order to comply with the requirements of the European General Data Protection Regulation (“ GDPR ”) for our European consumers and users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.  

DEFINITIONS The following terms shall have the following definitions:  

“ Location Data ” shall mean data with respect to the country from which you are accessing or using the Services.  

“ Personal Data ” shall mean information that can be used to identify you, directly or indirectly, alone or together with other information. This includes information such as your full name, email address, phone number, device IDs, and certain cookie and network identifiers.  

HOW RAVEN GROUP FILIP MACIEJEWICZ COLLECTS AND USES PERSONAL DATA. RAVEN GROUP FILIP MACIEJEWICZ collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business, for advertising and marketing purposes and as further described in this Privacy Policy. RAVEN GROUP FILIP MACIEJEWICZ collects your Personal Data in a number of ways and for various purposes, including:  

(a) When you register for an account or interact with the Services . RAVEN GROUP FILIP MACIEJEWICZ collects Personal Data when you use or interact with our Services, including when you register for a Company account, browse our Services online, and, possibly, to make payments (including the possibility of processing of such payments). Personal Data may include name, address, phone number, username and password, email address, date of birth, and payment information. RAVEN GROUP FILIP MACIEJEWICZ uses Personal Data to create your Company account, enable your activity within our Services, and to provide the Services generally, including to develop, enhance, and improve our Services and your experience in using such Services. RAVEN GROUP FILIP MACIEJEWICZ also uses this data for internal purposes related to certain, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.  

(b) When RAVEN GROUP FILIP MACIEJEWICZ Collects Location Data, RAVEN GROUP FILIP MACIEJEWICZ may collect Location Data as part of the functionality of our Services. We may collect Location Data in several ways, such as through your wireless carrier, based on WiFi access point location, via Bluetooth beacons, through a connected device, or directly from the device on which you use the Services.  

(c) When you communicate with RAVEN GROUP FILIP MACIEJEWICZ or elect to receive promotional materials . We collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email or other forms of communication (including email address, mobile number, etc.). If you consent to such messages, we may (i) use your Personal Data and other information to communicate with you about the Services; (ii) provide you with promotional messages and personalized advertising; (iii) notify you of other products; (iv) notify you of contests, challenges, sweepstakes, and other promotions (“ Promotions ”); (v) notify you of Services we think may be of interest to you; and (vi) for other marketing purposes. Please note that regardless of your email settings, we may send you notifications pertaining to the performance of our Services, such as revision of this Privacy Policy or other formal communications relating to products or Services you have purchased or use. We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests. We may also use your Personal Data to address your requests, inquiries, and complaints.  

(d) When you participate in special activities, offers or programs . RAVEN GROUP FILIP MACIEJEWICZ may request or otherwise collect Personal Data when you participate in Promotions, when you participate in surveys, or when you participate in research activities or initiatives (“ Research ”). This includes Personal Data, such as name, address, email address, telephone number and other information that may be appropriate in order to participate. We may also launch surveys that ask you to answer questions about a range of topics from Personal Data to brand and product preferences. Promotions or surveys may be run by a Viral Launch service provider. In such instances, Personal Data may be collected directly by and/or shared with RAVEN GROUP FILIP MACIEJEWICZ, the service provider, and/or business partner, including for marketing purposes.  

(e) When you engage with our online communities or advertising . RAVEN GROUP FILIP MACIEJEWICZ may collect your Personal Data when you engage with any online communities, to the extent that RAVEN GROUP FILIP MACIEJEWICZ has created the same. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with RAVEN GROUP FILIP MACIEJEWICZ.  

(f) When you access third party products and services . We may allow you to (i) register and pay for third-party products and services, (ii) pay for the Services, or (iii) otherwise interact with another website, mobile application, or Internet location (collectively “ Third Party Sites ”) through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services.  

(g) When you connect with RAVEN GROUP FILIP MACIEJEWICZ through social media . You may choose to enable, log into, or sign on to the Services through various social media or social networking services, such as Facebook or Twitter (“ Social Networking Service ” or “ SNS ”). When you connect using your SNS accounts, RAVEN GROUP FILIP MACIEJEWICZ may collect Personal Data that you have provided to that SNS. For example, when you log in to the Services with your Facebook credentials, with your consent, RAVEN GROUP FILIP MACIEJEWICZ may collect Personal Data from your Facebook profile that is permitted under Facebook’s Terms of Use, such as your email address, profile picture, and friend list. RAVEN GROUP FILIP MACIEJEWICZ may use this data to provide, enhance, and personalize the Services. If you do not want to provide us with this data, you need to adjust the privacy settings on your SNS account.  

(h) When RAVEN GROUP FILIP MACIEJEWICZ collects data from third parties or publicly-available sources . RAVEN GROUP FILIP MACIEJEWICZ may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services, such as providing you with a single point of sign on for our Services and/or building an account dashboard letting you understand how to access and control all the Services you use from a single location.  

(i) When we collect cookies, device ID’s, location, and other tracking technologies . We may collect certain Personal Data using cookies and other technologies such as web beacons, device ID’s, advertising ID’s, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.  

(j) When we aggregate or centralize data . RAVEN GROUP FILIP MACIEJEWICZ may aggregate and centralize Personal Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.  

(k) When we comply with legal requirements or obligations. RAVEN GROUP FILIP MACIEJEWICZ may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Services Agreement or other terms and conditions and agreements, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.


HOW RAVEN GROUP FILIP MACIEJEWICZ DISCLOSES PERSONAL DATA. RAVEN GROUP FILIP MACIEJEWICZ may disclose your Personal Data for the purposes as described in Section 2 and in the following ways:  

  (a) Affiliates . With companies, ventures or projects that are owned or controlled by RAVEN GROUP FILIP MACIEJEWICZ, and internally within RAVEN GROUP FILIP MACIEJEWICZ, in order to provide and improve Services, for marketing purposes, and for advertising.  

  (b) Service Providers and Vendors . With business partners, marketing partners, vendors and contractors to provide, improve, and personalize the Services.  

  (c) SNS Providers . With SNS providers when we use social network widgets, buttons, or plug-ins in our Services.  

  (d) Advertising and Marketing Purposes . With advertising and marketing partners for advertising and marketing purposes on RAVEN GROUP FILIP MACIEJEWICZ's behalf and on behalf of third parties. With companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of RAVEN GROUP FILIP MACIEJEWICZ and third-party advertisements that are personalized and displayed on our sites and apps and through other channels.  

  (e) Analytics . With certain companies for purposes of analytics and improvement of the Services.  

  (f) Legal Compliance . With law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Services Agreement and other terms and conditions or agreements, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.  

  (g) Sale . With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.  


LEGAL BASIS FOR PROCESSING This section addresses the legal basis for processing Personal Data if you reside outside of the United States. For the purposes of applicable data protection laws, Viral Launch is the controller of the Personal Data you provide to us (the “ Data Controller ”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy, please see below for appropriate contact information. The following shall apply to users residing in the European Economic Area: (a) No Requirement to Participate . You may choose not to provide RAVEN GROUP FILIP MACIEJEWICZ with your Personal Data; however, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services. (b) Rights with Respect to Personal Data . You have the following rights: (i) Right of access to your Personal Data (Art. 15 GDPR). You have the right to ask Viral Launch for confirmation on whether RAVEN GROUP FILIP MACIEJEWICZ is processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved). (ii) Right to rectification (Art. 16 GDPR). You have the right to have your Personal Data corrected, as permitted by law. (iii) Right to erasure (Art. 17 GDPR). You have the right to ask RAVEN GROUP FILIP MACIEJEWICZ to delete your Personal Data, as permitted by law. This right may be exercised among other things: (A) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed, (B) when you withdraw consent on which processing is based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR and where there is no other legal ground for processing, (C) when you object to processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21(2) GDPR, or (D) when your Personal Data has been unlawfully processed. (iv) Right to restriction of processing (Art. 18 GDPR). You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested, when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead, or when you have objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of RAVEN GROUP FILIP MACIEJEWICZ override your grounds. (v) Right to data portability (Art. 20 GDPR). You have the right to receive the Personal Data that you have provided to RAVEN GROUP FILIP MACIEJEWICZ, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.

(vi) Right to object (Art. 21 GDPR). You have the right to object to RAVEN GROUP FILIP MACIEJEWICZ's processing of your Personal Data, as permitted by law. This right is limited to processing based on Art. 6 (1)(e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims. (c) Disclosure . RAVEN GROUP FILIP MACIEJEWICZ may disclose your Personal Data in the following ways:  

(i) GDPR . The GDPR permits the sharing of Personal Data relating to users who are residents of the European Economic Area with third parties only under certain circumstances. If you reside in the European Economic Area, RAVEN GROUP FILIP MACIEJEWICZ will only share your Personal Data as described in our Privacy Policy if we are permitted to do so under applicable European and national data protection laws and regulations.  

(ii) Marketing . Where RAVEN GROUP FILIP MACIEJEWICZ is legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do by contacting Viral Launch.  

(iii) Additional use of Personal Data . Additional use of your Personal Data that is not described in this Privacy Policy will only take place as required by statute or when RAVEN GROUP FILIP MACIEJEWICZ has obtained your consent. (d) Legal Basis for Processing under the GDPR . In this section, RAVEN GROUP FILIP MACIEJEWICZ hereby provides information on the legal basis for processing of your Personal Data as required by Art. 13 and 14 of the GDPR:  

(i) When you register for a Company account or interact with our Services, such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.  

(ii) When we collect Location Data following your prior consent, we process such data on the basis of your prior consent. Art. 6(1)(a) GDPR. In other cases, where we process your Location Data without consent, for example in order to provide our Services, such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.

(iii) When you communicate with us or sign up for promotional materials, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with our promotional messages. Where we are required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent. Art. 6(1)(a) GDPR.  

(iv) When you participate in special activities, offers, or programs. For non-sensitive Personal Data, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with our promotional messages or to allow you to participate in our special activities, offers or programs.  

(v) When you engage with our advertising and we actively collect your Personal Data in this context, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to provide you with our promotional messages.  

(vi) When you access third party products and services and we obtain Personal Data about you from such third party sources. For Personal Data that we need in order to perform the Services (e.g. if you pay for third party products through our Services), such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.  

(vii) Regarding other Personal Data, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to enhance your experience and to improve our Services.  

(viii) When you connect with us through social media, where we obtain your consent in such case (e.g., for marketing purposes), we process such data on the basis of your prior consent. Art. 6 (1)(a) GDPR. Where we do not collect your consent in such case, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is providing you with better Services and to enable you to use the full range of our Services.  

(ix) When we collect data from third parties or publicly-available sources, for Personal Data which we need in order to perform the Services (e.g., for email verification purposes), such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR. Regarding other Personal Data, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is providing you with better Services and to enable you to use our Services more efficiently.  

(x) When we leverage and/or collect cookies, device IDs, Location Data, data from the environment, and other tracking technologies, we process such data on the basis of your consent (Art. 6(1)(a) GDPR), and based on our legitimate interest (Art. 6(1)(f) GDPR), where we do not obtain your consent and our legitimate interest is to provide you with better Services or marketing.  

(xi) When we aggregate or centralize data, such processing is either necessary for the performance of our Services (Art. 6(1)(b) GDPR) or we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with better or customized Services and marketing.

(xii) When you sign up for our services that consist of social sharing and communication with others, where we collect your consent in such case, we process such data on the basis of your prior consent (Art. 6(1)(a) GDPR) and where we do not collect your consent in such case, such processing is necessary for the performance of our Services (Art. 6(1)(b) GDPR).  

(xiii) When we disclose Personal Data to our affiliates and partners, and to our service providers and vendors, where we collect your consent in such case, we process such data on the basis of your prior consent. Art. 6(1)(a) GDPR. Where we do not collect your consent in such case, such processing is necessary for the performance of our Services (Art. 6(1)(b) GDPR), or we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to provide you with better Services and marketing.  

(xiv) When we process or share Personal Data in the event of an actual or contemplated sale, we process such data for our legitimate interest in offering, maintaining, providing, and improving our Services. Art. 6(1)(f) GDPR.  

(xv) When we conduct analytics, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to enhance your experience and to develop and improve our Services.  

(xvi) When we investigate suspected illegal or wrongful activity, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.  

(e) Right to lodge a complaint before the Data Protection Authority . RAVEN GROUP FILIP MACIEJEWICZ encourages you to contact us directly and allow us to work with you to address your concerns. Regardless, you have the right to communicate a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.  

(f) Changes to this Privacy Policy . In order to enhance our Services, it might be necessary to change this Privacy Policy from time to time. RAVEN GROUP FILIP MACIEJEWICZ reserves the right to modify this Privacy Policy in accordance with the applicable data protection laws. Please visit our Website from time to time for information on updates to this Privacy Policy.  

(g) How to contact us or our Privacy Office . In case of questions about the processing of your Personal Data please contact us at contact@alpharavenhouse.com. If we are required under applicable law to appoint a data protection officer (DPO), you can contact the DPO that is responsible for your country/region at contact@alpharavenhouse.com.

SECURITY RAVEN GROUP FILIP MACIEJEWICZ implements appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data. The Services may provide a link or otherwise provide access to Third Party Sites. RAVEN GROUP FILIP MACIEJEWICZ provides these links for convenience. RAVEN GROUP FILIP MACIEJEWICZ has no control over, does not review, and is not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Any data, including personal data, collected directly by any Third Party Site is not governed by this Privacy Policy, and any data you provide to Third Party Sites, you provide at your own risk. RAVEN GROUP FILIP MACIEJEWICZ strongly encourages you to review the privacy policies of any Third Party Sites with that you interact with. In the event of a breach of the security of your Personal Data, RAVEN GROUP FILIP MACIEJEWICZ shall notify you of such breach in accordance with applicable law.  

CHILDREN RAVEN GROUP FILIP MACIEJEWICZ does not knowingly collect Personal Data online from children under the age of 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us at contact@alpharavenhouse.com. If RAVEN GROUP FILIP MACIEJEWICZ becomes aware that a child under the age of 13 has provided us with Personal Data without parental consent, then the Company will take steps to remove the data and cancel the child’s account.