Privacy Policy

2. Who We Are

Raffine operates as both a data controller (for data we collect directly from Merchants who use our platform) and a data processor (for Subscriber data that Merchants pass to us in order to perform payment recovery services).

For enquiries about how we handle data, contact us at: privacy@raffine.app.

3. Information We Collect

3.1 Information from Merchants (our direct customers)

• Account Data: Name, business name, email address, phone number, website URL.
• Billing Data: Payment method details for your Raffine subscription, processed via Paystack. We do not store raw card numbers.
• Integration Credentials: Payment processor API keys (encrypted at rest), email sender credentials, webhook secrets.
• Configuration Data: Branding settings, email templates, retry schedules, playbook configurations.
• Usage Data: Log data, session information, feature usage patterns, and analytics.

3.2 Information about Subscribers (processed on behalf of Merchants)

When Merchants use Raffine to recover failed payments, we process data about their customers on their behalf. This includes:

• Identity Data: Name, email address.
• Payment Data: Subscription status, failed payment details, card expiry information, payment method tokens. We do not store full card numbers — all payment data is tokenised through the Merchant's payment processor.
• Communication Data: Email open rates, click events, delivery status relating to recovery communications sent on behalf of the Merchant.
• Transaction History: Payment attempt records, recovery outcomes.

3.3 Automatically Collected Data

• IP addresses, browser type, device type, operating system.
• Pages visited, time spent, referral source.
• Webhook events received from connected payment processors.

4. How We Use Your Data

4.1 To deliver the service

• Authenticating Merchant accounts and managing access.
• Executing payment retry logic on behalf of Merchants.
• Sending recovery communications (emails, SMS) to Subscribers on behalf of Merchants.
• Tracking communication delivery and engagement for recovery analytics.
• Calculating and billing the success fee owed by Merchants.

4.2 To improve the platform

• Analysing recovery performance to optimise retry schedules and playbook logic.
• Monitoring platform reliability and diagnosing errors.
• Understanding feature usage to guide product development.

4.3 To communicate with Merchants

• Sending transactional emails (account activity, billing summaries, onboarding).
• Sharing product updates, new features, and relevant announcements.
• Responding to support requests.

We do not sell personal data to third parties. We do not use Subscriber data for any purpose other than providing the payment recovery service on behalf of the relevant Merchant.

5. Legal Basis for Processing

Where applicable under GDPR or POPIA, we rely on the following legal bases:

• Contract performance: Processing necessary to provide the services you have contracted with us for.
• Legitimate interests: Analytics, fraud prevention, platform security, and product improvement, where these do not override your rights.
• Legal obligation: Where we are required to process data to comply with applicable law.
• Consent: Where you have explicitly opted in to specific processing activities such as marketing communications.

For Subscriber data processed on behalf of Merchants, Raffine acts as a data processor. The Merchant is the data controller and is responsible for ensuring they have a valid legal basis for sharing Subscriber data with us.

6. Sharing & Disclosure

We share data only in the following circumstances:

• Sub-processors: We use trusted third-party services to operate the platform. Our current sub-processors include:
  • Supabase — Database hosting and authentication
  • Paystack — Payment processing and subscription management
  • Postmark — Transactional email delivery
  • Hookdeck — Webhook management and reliability
• Legal requirements: Where we are required by law, court order, or governmental authority.
• Business transfers: In the event of a merger, acquisition, or sale of assets, data may be transferred to the acquiring entity subject to equivalent privacy protections.
• With your consent: For any other purpose with your explicit consent.

We do not share, sell, rent, or trade personal data with third parties for their marketing purposes.

7. International Data Transfers

Raffine operates internationally and our sub-processors may store and process data in various jurisdictions. Where data is transferred outside of the European Economic Area (EEA) or South Africa, we ensure that appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission.
• Transfers to countries recognised as providing adequate data protection.
• Other lawful transfer mechanisms as required by applicable law.

8. Data Retention

We retain data for as long as necessary to provide our services and comply with legal obligations:

• Merchant account data: Retained for the duration of your subscription and for 3 years after account closure for legal and billing purposes.
• Recovery session data: Retained for 2 years to support analytics and dispute resolution.
• Subscriber data: Retained only as long as the Merchant's account is active. Deleted within 90 days of Merchant account closure unless legal obligations require otherwise.
• Payment records: Retained for 7 years in accordance with financial record-keeping requirements.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your personal data ("right to be forgotten"), subject to legal retention obligations.
• Restriction: Request that we restrict processing of your data in certain circumstances.
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdraw consent: Where processing is based on consent, withdraw it at any time without affecting the lawfulness of prior processing.

For Subscribers: If you are a customer of a business that uses Raffine and wish to exercise your rights, please contact that business directly as they are the data controller for your personal data. If they are unable to assist, you may contact us at privacy@raffine.app.

To exercise your rights as a Merchant, contact us at privacy@raffine.app. We will respond within 30 days.

10. Cookies

We use cookies and similar tracking technologies to operate and improve our platform. These include:

• Strictly necessary cookies: Required for authentication and core platform functionality. Cannot be disabled.
• Analytics cookies: Help us understand how the platform is used. You may opt out via your browser settings.

We do not use advertising or third-party tracking cookies.

11. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include:

• Encryption of sensitive credentials (API keys, webhook secrets) at rest.
• TLS encryption for all data in transit.
• Role-based access controls and row-level security on our database.
• Regular security reviews of our infrastructure and dependencies.

In the event of a data breach that affects your rights and freedoms, we will notify affected parties and relevant supervisory authorities within the timeframes required by applicable law.

12. Children's Privacy

Raffine is a business-to-business platform not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us and we will promptly delete it.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify Merchants via email or a prominent in-app notice at least 14 days before the changes take effect. Continued use of the platform after the effective date constitutes acceptance of the updated policy.