PRIVACY POLICY

PRIVACY POLICY

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