Last updated August 12, 2026 · Version 1.3
Privacy Policy
This Privacy Policy for RAITON, LLC ("RAITON," "we," "us," or "our") explains how we collect, use, disclose, and retain personal information when you use our services ("Services"), including when you:
- Visit our website at https://www.raiton.co or any website of ours that links to this Privacy Notice
- Apply for early access or communicate with us
- Use a RAITON web or mobile application that links to this Policy
- Use RAITON to organize or participate in a rotating savings and credit association (a "Circle") while members continue to exchange funds outside RAITON
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@raiton.co.
Summary of Key Points
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process sensitive personal information? The current track-only MVP does not require government identification, Social Security numbers, bank credentials, or payment-card information. We will update this Policy and provide any required notice or consent before collecting such information for a future feature.
Do we collect information from third parties? We may receive basic referral or campaign information when you follow a tagged link. We do not currently supplement user profiles with information purchased from data brokers or collected from public databases.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We use reasonable organizational and technical safeguards designed to protect personal information. No system is completely secure. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting https://www.raiton.co, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
1. What Information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- telephone numbers
- waitlist role or interest, such as Circle member or organizer
- account credentials and authentication data when account access is available
- communications, support requests, feedback, and event information
- SMS consent status, consent source and time, disclosure version, opt-out status, and message-delivery information
Circle and reliability information. If you use the product, we may collect information needed to operate a Circle and create a reliable record, including:
- Circle name, membership, contribution amount and cadence, rotation order, and rules
- recorded contribution status, including whether an expected contribution was recorded as received, due, late, or missed
- payout-turn and real-world handoff confirmations
- Circle history, participation, completion, disputes, corrections, and organizer or member confirmations
- reliability progress or SFR-related metrics derived from Circle participation
Sensitive and payment information. RAITON's current track-only MVP does not collect government-issued identification, Social Security numbers, bank credentials, payment-card information, or financial account and routing numbers. RAITON does not hold, move, process, custody, or disburse Circle funds. If a future feature changes these practices, we will update this Policy and provide any legally required notice or consent before the feature is enabled.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Our hosting and security providers receive basic technical information when you use the Services.
When you visit or use the Services, we and our providers may automatically receive limited technical information such as your IP address, browser and device type, operating system, language, referring URL, requested pages, and access date and time. We use this information to deliver the Services, maintain security, diagnose errors, and understand basic usage. The current public website does not request GPS access or intentionally collect precise geolocation.
If you reach a waitlist page through a tagged campaign link, the page may include UTM source, medium, campaign, content, or term values with your submission so we can understand how you found RAITON.
The information we collect includes:
- Log and usage data. Basic request, diagnostic, security, and performance records generated when you access the Services.
- Device and browser data. General characteristics needed to display and secure the Services. We do not currently claim to collect persistent mobile advertising identifiers or precise GPS location.
2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To manage early-access applications and relationships. We use waitlist and campaign information to review interest, respond to applicants, plan pilots, and communicate about access.
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To operate Circles and preserve their records. We process Circle membership, schedules, statuses, confirmations, history, and related information to provide the track-only coordination Service.
- To generate private reliability progress. We may use Circle participation records to calculate or display SFR-related progress as described below. We do not currently furnish that information for credit, insurance, employment, housing, or other eligibility decisions.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send communications you request. We may send email, SMS, or other communications based on your request, account activity, or communication preferences. Optional SMS enrollment is described below.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
3. When and With Whom Do We Share Your Personal Information?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
Service providers. We disclose personal information to providers that perform services for us under appropriate restrictions. Current categories include website hosting and content delivery, Google services used to receive or store waitlist submissions, email and support tools, security providers, and—only for users who enroll—SMS messaging providers and telecommunications carriers.
Other Circle participants. We disclose limited Circle information to the organizer and members of a Circle as necessary to provide the shared coordination features described in Section 12.
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Legal and safety reasons. We may disclose information if reasonably necessary to comply with law, protect rights or safety, investigate fraud or misuse, or enforce our Terms.
We do not sell personal information or share personal information for cross-context behavioral advertising. We do not provide mobile numbers or SMS consent records to third parties or affiliates for their own marketing.
Mobile Messaging and SMS Privacy
In Short: SMS enrollment is optional, and we do not share mobile opt-in information for third-party marketing.
If you separately choose to receive SMS messages from RAITON, we collect and process your mobile phone number, consent status, the date, time, source, and disclosure version associated with your consent, opt-out status, and message-delivery information. Messages may concern your RAITON account, security alerts, contribution reminders, admin-recorded contribution confirmations, payout or rotation updates, and other Circle activity. RAITON does not use this SMS program for marketing or authorize unrelated third-party promotional messages.
Your SMS consent is optional. Providing a mobile number, applying for early access, creating an account, or joining a Circle does not by itself enroll you in SMS messages. Where a web or app form is used, SMS consent is requested through a separate affirmative choice that is unchecked by default. You can apply for and use RAITON even if you decline SMS messages.
Mobile information is not shared for marketing. We do not share, sell, rent, or otherwise provide your mobile phone number, SMS opt-in data, or messaging consent information to third parties or affiliates for their marketing or promotional purposes. We may disclose this information to messaging service providers, telecommunications carriers, and other vendors only as necessary to deliver and support the messages you requested, maintain security, comply with law, or protect rights.
Program disclosures. Message frequency varies based on your account and Circle activity. Message and data rates may apply. Reply STOP to opt out or HELP for help, or email hello@raiton.co with a reasonable revocation request. We may send one confirmation message after an opt-out. Opting out of SMS does not prevent non-SMS communications that are necessary to operate or secure your account.
4. Do We Use Cookies and Other Tracking Technologies?
In Short: The current public website does not intentionally use advertising cookies or tracking pixels.
Our hosting, security, and font-delivery providers may use limited technical mechanisms needed to deliver and protect the site. We do not currently use those mechanisms for cross-context behavioral advertising. If we add analytics, advertising, or other non-essential tracking, we will update this Policy and provide any choices required by law.
5. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We retain each category of personal information only for as long as reasonably necessary for the purpose for which it was collected, taking into account the relationship, the need to provide Circle history, security and dispute needs, legal obligations, and the feasibility of deletion from backups.
- Waitlist and inquiry records: until the access, pilot, or relationship purpose is complete and for a limited period afterward needed for follow-up, suppression, recordkeeping, or legal claims.
- Account, Circle, and reliability records: while the account or Circle is active and afterward for as long as needed to provide requested history, address corrections or disputes, prevent fraud, enforce agreements, or comply with law.
- SMS consent and opt-out records: while messages are sent and afterward for as long as needed to honor opt-outs and document consent and compliance.
- Technical logs: for a limited operational period appropriate to security, troubleshooting, and system integrity.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
7. Do We Collect Information From Minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
The Services are intended only for people who are at least 18 years old. We do not knowingly collect personal information from anyone under 18. If we learn that we collected personal information from a person under 18, we will take reasonable steps to delete it. If you believe a person under 18 provided information to us, contact hello@raiton.co.
8. What Are Your Privacy Rights?
In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at hello@raiton.co.
9. Controls For Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
10. Do United States Residents Have Specific Privacy Rights?
In Short: Depending on where you live and which law applies, you may have rights to know, access, correct, delete, or obtain a copy of personal information, and to opt out of certain processing. These rights are subject to legal limitations and exceptions.
Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information as defined in the California Customer Records statute | Name and contact information, including telephone number | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial or service activity | Waitlist interest and Circle participation, schedules, recorded contribution status, and payout-turn history | YES, when using those features |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Approximate location inferred from IP address; precise GPS location | Approximate only |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Reliability progress or SFR-related metrics derived from Circle participation | YES, when enabled |
| L. Sensitive personal Information | Financial information including account access details, passport numbers, social security numbers, state id card numbers, account login information and drivers' licenses | NO |
The current track-only MVP does not collect government identification, Social Security numbers, bank credentials, payment-card information, or financial account and routing numbers. We will revise this table before enabling a feature that changes that statement.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We retain these categories using the criteria described in Section 5. RAITON does not currently apply a five-year BSA or KYC retention period to track-only users.
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"
How We Use and Share Personal Information
RAITON does not currently use automated processing or SFR-related information to make decisions that produce legal or similarly significant effects concerning credit, insurance, employment, housing, or access to essential services.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not sold personal information or shared it for cross-context behavioral advertising in the preceding twelve (12) months. We have disclosed the following categories to service providers for business purposes:
- Category A. Identifiers
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
- Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
- Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting https://www.raiton.co, by emailing us at hello@raiton.co, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@raiton.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
11. SFR Score
RAITON may use recorded Circle participation—such as contribution consistency, completion, tenure, and confirmations—to generate private reliability progress or SFR-related metrics. The current MVP does not furnish this information to Equifax, Experian, TransUnion, another consumer reporting agency, or an institution for use in credit, insurance, employment, housing, or another eligibility decision. Calling a metric an "SFR Score" does not by itself determine its legal status; RAITON will obtain legal review, update this Policy, and implement any required consent, access, correction, and dispute process before permitting such use. SFR-related information is not visible to other Circle members and is not intended for social punishment. You may contact hello@raiton.co to ask about or dispute your SFR-related information.
12. Circle Member Data Visibility
A Circle organizer can see member identity and the operational information needed to manage that Circle, such as membership, contribution status, rotation position, confirmations, and history. Circle members may see shared membership, schedule, pool, rotation, and status information made available by the product for their Circle. RAITON limits this visibility by role and feature design, but Circle information is shared-group information and should not be treated as private from the organizer. SFR-related information remains private to the individual member and authorized RAITON personnel. Before launch, the final product permissions must be tested against this description.
13. Payments and Identity Verification
RAITON's current Service tracks and coordinates Circle activity while members exchange funds directly using methods outside RAITON. RAITON does not currently collect identity-verification documents, Social Security numbers, bank credentials, or account and routing numbers; provide banking services; or hold, process, custody, transmit, or disburse Circle funds. We will revise this Policy and the Terms before enabling any feature that changes these practices.
14. Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Policy from time to time. The updated version will be identified by the "Last updated" date and version at the top. If changes are material, we will provide additional notice when required or appropriate. A new date will reflect when the revision becomes operative; we will not silently backdate a policy.
15. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at hello@raiton.co or contact us by post at:
RAITON, LLC
325 West Adams Boulevard
Unit 3089
Los Angeles, CA 90007
United States
16. How Can You Review, Update, or Delete the Data We Collect From You?
Depending on applicable law, you may request access to, correction of, deletion of, or a copy of personal information we maintain about you, or withdraw consent where processing relies on consent. These rights may be limited by law. Submit a request to hello@raiton.co. We may verify your identity before completing a request.