PRIVACY POLICY
Effective Date: 04/28/2026
This Privacy Policy describes how Gradual Holdings Inc., operating as Rawstate.ai (“Rawstate”, “we”, “us”, or “our”) collects, uses, and protects personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).
1. INFORMATION WE COLLECT
We may collect the following types of information:
A. Information You Provide
Name, email address, phone number
Business information
Messages or inquiries submitted through forms
B. Client Data
When providing services, we may process data on behalf of clients, including:
Customer contact data
Lead and CRM data
Communication records
C. Automatically Collected Data
IP address
Browser type and device information
Website usage data (analytics)
2. HOW WE USE INFORMATION
We use personal information to:
Provide and improve our services
Build and manage automated workflows and systems
Communicate with clients and users
Analyze performance and usage
Comply with legal obligations
We do not sell personal information.
3. DATA PROCESSING ROLE
Rawstate may act as a data processor when handling client data.
Our clients remain the data controllers of their data.
We process such data only for purposes defined by our agreements with clients.
4. USE OF AI AND AUTOMATION
Our services may involve the use of AI systems and automation tools.
You acknowledge that:
Data may be processed through third-party AI platforms
AI-generated outputs may be based on patterns and may not be fully accurate
We use AI systems as assistive tools, not as independent decision-makers
5. THIRD-PARTY SERVICES
We may use third-party providers to deliver services, including:
Cloud infrastructure providers
AI model providers
Analytics and communication platforms
These providers may process data in Canada or other jurisdictions.
We take reasonable steps to ensure appropriate safeguards are in place.
6. DATA SECURITY
We implement commercially reasonable safeguards, including:
Controlled access to systems
Use of secure platforms and infrastructure
Data minimization practices
However, no system can guarantee complete security.
7. DATA RETENTION
We retain personal information only as long as necessary to:
Fulfill the purposes outlined in this policy
Meet legal and contractual obligations
8. YOUR RIGHTS
Under Canadian privacy law, you have the right to:
Request access to your personal information
Request correction of inaccurate information
Withdraw consent where applicable
Requests may be submitted using the contact information below.
9. COOKIES AND TRACKING
We may use cookies or similar technologies to:
Improve user experience
Analyze website traffic
You may control cookie settings through your browser.
10. INTERNATIONAL DATA TRANSFERS
Data may be stored or processed outside of Canada.
When this occurs, it may be subject to the laws of those jurisdictions.
11. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time.
Updates will be posted on this page with a revised effective date.
12. CONTACT INFORMATION
For privacy-related inquiries, requests, or complaints, please contact:
Gradual Holdings Inc. (Rawstate.ai)
Email: welcome@gradualholdings.com
Address: Unit 713:285 Dufferin St, ON, M6K 0J2
