Last updated on July 28, 2026

Raycon respects the privacy of our customers and users of our website, mobile applications, and connected devices. This Privacy Policy describes the types of personal and non-personal information we collect, how we use it, and how we protect it.

This policy applies to:

• Our website (rayconglobal.com)
• The Notes by Raycon mobile app (iOS and Android)
• The Raycon Tunes mobile app (iOS and Android)
• Connected devices, including the Raycon AI Notetaker, earbuds, and headphones
• Subscription services and cloud features
• Customer support and service interactions

Which parts apply to you

Our products differ substantially in what data they involve, so the table below tells you where to look. Each product is also covered by the general sections on security, your rights, and how to contact us.

Produkt	Account required	Audio recorded	Cloud processing	Read
rayconglobal.com store	Optional	Nein	Nein	Sections 1, 8, 9
Raycon Tunes app + earbuds/headphones	Nein	Nein	Nein	Section 2
Notes by Raycon app + AI Notetaker	Ja	Ja	Optional	Sections 1, 3, 4

Section 1 - What Information Does Raycon Collect?

Account & Registration:

We collect your name, email address, password, billing address, shipping address, phone number, and company name/title (if applicable). The Raycon Tunes app does not require or offer an account, and we do not collect any of this information through it.

Transaction Information:

We collect payment details processed securely through payment processors (we do not store full credit card numbers), order history and purchase details, and refund and return requests.

Product Registration & Usage:

We collect device serial numbers and identifiers, firmware and software versions, subscription plan type and renewal status, and usage patterns and feature interactions.

Customer Support:

We collect support requests, tickets, and correspondence, troubleshooting information you provide, and account verification details (email, order number, device ID).

Communication & Marketing:

When you consensually sign up for email and sms marketing, we collect email addresses, phone numbers for SMS notifications, preferences for promotional communications, and survey responses and feedback.

Audio Recording & Transcription Data (AI Notetaker Specific):

When you use the Raycon AI Notetaker, we collect audio recordings of conversations and calls you choose to record, metadata about recordings (timestamp, duration, recording mode, device info), transcriptions generated from your audio, and summaries, action items, and AI-generated analysis. If you enable cloud features, we collect encrypted audio files transmitted to cloud processors and speech-to-text transcripts and analysis results. You have full control over whether cloud features are used. You can record locally without uploading audio to the cloud.

Earbuds, Headphones & the Raycon Tunes App:

When you pair a Raycon audio product with the Raycon Tunes app, the app reads and writes device settings over a Bluetooth Low Energy connection. This involves the Bluetooth device identifier (MAC address) of the paired earbuds or headphones, the product model and SKU, the device serial number where the product reports one, the installed firmware version, battery level for each earbud and the charging case, equalizer presets and any custom equalizer curves you create, active noise cancellation and transparency mode state, touch and tap gesture assignments, and the outcome of firmware update attempts. Section 2 describes in detail which of these stay on your phone and which reach Raycon.

Automatically Collected Information:

When you visit our website we automatically collect your IP address and device identifiers, browser type and operating system, pages visited and time spent, and links clicked and features used. We also collect session cookies (authentication), analytics cookies (usage patterns), preference cookies (saved settings), advertising cookies (if enabled), and third-party pixels for retargeting (Meta, Google). See Section 8 for full cookie details.

From our mobile apps we automatically collect the app version, device type and operating system version, crash logs, and error data.

Device permissions differ by app:

• Notes by Raycon requires microphone access to record and local storage access to save recordings.
• Raycon Tunes requires Bluetooth access to find and connect to your earbuds or headphones, and local storage access to download firmware update files. It does not use the microphone or the camera.
• Neither app accesses your contacts, calendar, photos, call logs, SMS messages, or the list of other applications installed on your device.
• Neither app requests location permission. On Android, Raycon Tunes declares Bluetooth scanning with the neverForLocation flag so that no location permission prompt is shown and no location data can be derived from scanning.

Section 2 - Raycon Tunes & Connected Audio Products

Raycon Tunes is a companion app for Raycon earbuds and headphones. It is deliberately narrow in what it does and what it collects.

No account, no sign-in:

Raycon Tunes has no account system. You do not register, you do not provide an email address or phone number, and there is no profile associated with your use of the app. Your settings are stored on your phone and on the earbuds themselves.

Why the app needs Bluetooth:

Bluetooth access is required to discover nearby Raycon products, establish a connection, read device state such as battery level and firmware version, and write your settings to the device. Without it the app cannot function. Raycon does not use Bluetooth scanning to detect other nearby devices, beacons, or people, and does not build any profile from Bluetooth data.

No location tracking, and no device-finding by location:

Raycon Tunes does not request location permission and does not collect, store, or transmit your location or the location of your earbuds. The app does not offer a map-based or location-based device finding feature. Some Raycon products can play a sound to help you find them when they are within Bluetooth range; this works entirely over the local Bluetooth connection and involves no location data.

What stays on your phone and your earbuds:

The following are stored locally on your device and on the paired product, and are not transmitted to Raycon: the Bluetooth identifier of your paired product, your equalizer presets and custom curves, your noise cancellation and transparency preference, your gesture assignments, and battery readings.

What reaches Raycon:

• Firmware update checks. When the app checks for a firmware update, it sends the product model and the currently installed firmware version to our update service so we can tell the app whether a newer version exists. We do not send your Bluetooth identifier or serial number with this request.
• Firmware update outcomes. Whether an update succeeded or failed, and an error code if it failed, along with the product model and firmware versions involved. We use this to detect firmware problems affecting a batch of products.
• Crash reports and stability data. If the app crashes, a crash report is generated containing the app version, operating system version, device model, and a stack trace. Crash reports do not contain your settings or your earbud identifiers.
• Aggregate feature usage, if you leave usage sharing enabled. This tells us which features are used and how often, not who used them.

None of the above is linked to your name, email address, or any account, because Raycon Tunes has no account.

Firmware updates:

Firmware update files are hosted by Raycon and delivered over an encrypted connection. Update packages are signed, and the app verifies the signature before installing. Raycon does not push firmware to your product without your action - you choose when to install an update. Your saved settings, including equalizer presets and noise cancellation preferences, are stored in a separate region of the product's memory from the firmware and are not erased by a firmware update.

Third-party components in Raycon Tunes:

We restrict what third-party software may be included in the Raycon Tunes app. The app contains only the chipset manufacturer software libraries required to communicate with the audio hardware, and a crash reporting library. It contains no advertising software, no advertising or tracking identifiers, no social media integrations, no push notification services, and no analytics libraries that collect device identifiers. Any addition to this set requires written approval from Raycon in advance, and this policy is updated before any such addition ships. Section 6 lists the specific providers.

What Raycon Tunes does not collect:

To be explicit, the app does not collect your name, email address, phone number, or postal address; your location; your contacts, calendar, photos, or call history; the list of applications installed on your phone; your advertising identifier (IDFA on iOS, Advertising ID on Android); audio from your microphone; your IMEI, IMSI, SIM serial number, or Android ID; or any biometric or health data.

Deleting your Raycon Tunes data:

Because settings are stored locally, uninstalling the app removes them from your phone. To clear settings stored on the earbuds themselves, perform a factory reset on the product using the instructions in your product manual, or use Reset Device in the app. To request deletion of crash reports or usage data associated with your app installation, email privacy@rayconglobal.com - see Section 5 for how to make a request without an account.

Section 3 - How Do We Use Your Information?

Core Service Delivery:

We use your information to create and manage your account, process payments and manage subscriptions, deliver recordings to your mobile device and cloud storage, provide transcription, summarization, and analysis features, send you transactional notifications (order confirmation, delivery, subscription renewal), and provide customer support and technical assistance.

AI Notetaker Specific Uses:

We transfer audio from device to Notes by Raycon app, generate transcriptions and summaries (if you enable this feature), analyze content for action items and key points, and store recordings securely on your device and/or cloud. We analyze aggregate, anonymized transcription patterns to improve accuracy, identify common errors or edge cases, and test new AI features (with your consent only). Important: Raycon employees do not listen to, review, or access your individual recordings unless you request support or we are legally required to do so. Your recordings are not used to train our AI models without explicit consent.

Raycon Tunes Specific Uses:

We use the firmware version and product model you send during an update check to determine which firmware applies to your product. We use update outcomes to identify firmware that is failing in the field so we can withdraw or fix it. We use crash reports to fix defects. We use aggregate usage data to decide which features to improve. We do not use any Raycon Tunes data for advertising, and we do not combine it with your store account or your Notes account.

Product Improvement & Analytics:

We use non-personal usage data to understand how features are used, identify bugs and performance issues, prioritize improvements, and measure product health and reliability.

Marketing & Communications:

With your consent, we use your email or phone to send product updates and new features, promotional offers and discounts, re-engagement campaigns, and newsletters and company news. You can unsubscribe from marketing at any time using the link in any marketing email or by emailing unsubscribe@rayconglobal.com. We do not send marketing through the Raycon Tunes app.

Legal & Security:

We use your information to comply with legal obligations (court orders, subpoenas, government requests), detect, prevent, and investigate fraud or misuse, enforce our Terms of Service, protect the security of our systems and users, and resolve disputes.

Section 4 - Recording Consent & Legal Compliance (AI Notetaker only)

This section applies to the Raycon AI Notetaker and the Notes by Raycon app. It does not apply to Raycon earbuds, headphones, or the Raycon Tunes app, none of which record audio.

Your Responsibility for Recording Laws:

You acknowledge that the Raycon AI Notetaker is designed to record audio conversations and calls. You are solely responsible for complying with all applicable recording laws. Recording laws vary significantly by location and context, and many jurisdictions require consent from all parties before recording. Before you record, research recording consent laws in your jurisdiction, obtain written consent from all participants if required by law, understand that Raycon does not verify, monitor, or enforce compliance with recording laws, and know that you assume all legal risk for non-compliant recordings.

Multi-Party Recording Notice:

For conversations with multiple people, inform participants that you are recording, obtain their explicit consent before recording, note that some jurisdictions (e.g., California, Canada) require all-party consent, and use the recordings only for the purpose participants consented to.

Call Recording Specifics:

When recording phone calls, the Raycon AI Notetaker must be securely attached to your phone or phone case, inform the other party that the call is being recorded, obtain their consent as required by your jurisdiction, and follow your telecommunications provider's policies on call recording.

Raycon's Liability:

Raycon is not responsible for non-compliant recordings made with the device, misuse of recordings after they are created, legal consequences of recording without consent, or disputes between recording parties about the recording. If you have questions about recording consent laws in your area, consult a local attorney.

Section 5 - Data Retention & Deletion

Retention by Data Type:

Data type	Retention period	Notes
Audio recordings (AI Notetaker)	Until you delete, or your account closes	Deletable anytime in the Notes by Raycon app
Transcripts (AI Notetaker)	Until you delete, or your account closes	Deletable anytime in the Notes by Raycon app
Account information	Until you close your account	Deleted within 30 days of a verified request
Cloud processing logs	90 days	Automatic deletion
Third-party backups	24-48 hours	See Third-Party Processor Retention below
Order and transaction records	7 years	Retained for tax and accounting obligations
Analytics and metadata	12 months	Anonymized or aggregated
Support tickets	2 years	Retained for dispute resolution
Cookies	Per cookie specification	Deletable via your browser - see Section 8
Raycon Tunes settings (EQ, ANC, gestures)	Not retained by Raycon	Stored on your phone and earbuds only
Firmware update check requests	30 days	Server logs, then deleted
Firmware update outcome records	24 months	Retained to track firmware defects across a production batch
Raycon Tunes crash reports	12 months	Not linked to any account
Raycon Tunes aggregate usage data	12 months	Aggregated, not linked to any account

Third-Party Processor Retention:

Data retention by our third-party processors is governed by their respective privacy policies. AssemblyAI retains transcription data as necessary to provide transcription services (see assemblyai.com/legal/privacy-policy). AssemblyAI's full Privacy Policy can be found, here. OpenAI retains data as necessary to provide summarization and analysis services (see openai.com/policies/privacy-policy). AWS retains audio and transcript data in your cloud account until you request deletion. Shopify handles e-commerce transactions per the Shopify privacy policy (shopify.com/legal/privacy). RevenueCat handles subscription data per the RevenueCat privacy policy (revenuecat.com/privacy). For specific retention timelines, consult each processor's privacy policy directly.

How to Delete Your Data:

Delete individual recordings (AI Notetaker): Open the Notes by Raycon app, select the recording and swipe left or tap delete, then confirm deletion.

Delete Raycon Tunes settings: Uninstall the app to remove settings stored on your phone. To clear settings stored on the product, use Reset Device in the app or perform a factory reset following your product manual.

Delete all data and close your account: Email privacy@rayconglobal.com with the subject "Account Deletion Request", include your email address and account ID, and verify your identity (we may request additional information). Upon confirmation, we will delete all recordings and transcripts from Raycon servers, instruct third-party processors to delete their copies, close your account, and remove your profile from our databases.

Requests without an account: Because Raycon Tunes has no account, we normally have no way to link data to you. If you want us to try to locate and delete crash reports or usage records associated with your app installation, email privacy@rayconglobal.com and tell us the approximate date, your device model, and your operating system version. Where we cannot identify data as relating to you, we will tell you so rather than guess.

Processing time is 30 days, or 14 days for residents of the EU, the UK, and Canada. After deletion, your data cannot be recovered. Backups and third-party copies may take additional time to fully purge, typically 24-48 hours.

Section 6 - Third-Party Data Processors & Cloud Services

Who processes data from the store and the Notes by Raycon app:

AssemblyAI (assemblyai.com/legal/privacy-policy) for converting audio to text, OpenAI (openai.com/policies/privacy-policy) for generating summaries and analysis, Amazon Web Services (aws.amazon.com/privacy) for cloud storage and compute, Shopify (shopify.com/legal/privacy) for e-commerce and payment processing, and RevenueCat (revenuecat.com/privacy) for subscription management. Analytics and marketing processors include Mixpanel (mixpanel.com/legal/privacy-policy) for product analytics, Amplitude (amplitude.com/privacy) for user behavior analytics, Meta Pixel (facebook.com/privacy/policy) for conversion tracking, Google Analytics (policies.google.com/privacy) for website analytics, and Zapier (zapier.com/privacy) for workflow automation.

Who processes data from the Raycon Tunes app:

Amazon Web Services (aws.amazon.com/privacy) hosts firmware update files and the update manifest. Google Firebase Crashlytics (firebase.google.com/support/privacy) processes crash reports. Chipset manufacturer software libraries are embedded in the app to communicate with the audio hardware over Bluetooth; these operate on your device and do not transmit data to the chipset manufacturer.

The Raycon Tunes app does not include, and Raycon does not permit in it, any advertising network, advertising attribution service, social media software library, push notification service, or analytics service that collects persistent device identifiers. Software from any provider not named in this section may not be added to the app without prior written approval from Raycon, and this policy is updated before any such addition is released.

Data Processing Agreements:

All third-party processors handling personal data are subject to Data Processing Agreements. These agreements require processing data only on our instructions, implementing industry-standard security measures, maintaining confidentiality, assisting with your data subject rights (access, deletion, portability), and notifying us of breaches. If you need a copy of our agreement with a specific processor, email privacy@rayconglobal.com.

Your Rights With Third Parties:

Each processor has its own privacy policy. You have the right to review their privacy policies (links above), request access to your data held by them, request deletion of your data held by them, and understand how they use your data. We are responsible for selecting processors and for requiring that they comply with applicable law. We are not responsible for their independent processing practices beyond what we contractually require.

Section 7 - Data Security & Protection

Encryption & Security Standards:

In Transit: All audio transfers use AES-256 encryption, HTTPS/TLS encryption for all web communications, and TLS for sensitive data. Firmware update files and update manifests are delivered over HTTPS. At Rest: Recordings are encrypted with industry-standard encryption, account data is encrypted in databases, access is restricted to authorized systems and personnel, and we conduct regular security audits and penetration testing. Third-Party Security: AssemblyAI and OpenAI maintain SOC 2 Type II compliance, AWS uses ISO 27001 certified data centers, and all processors use encryption and access controls.

Firmware Integrity:

Firmware packages distributed through the Raycon Tunes app are cryptographically signed. The app verifies the signature and the integrity of the package before installation, and refuses packages that fail verification. This is intended to prevent modified or substituted firmware from being installed on your product.

Access Controls:

Raycon Employee Access: Raycon staff do not routinely access user recordings, access is restricted to engineers troubleshooting technical issues, all access is logged and audited, and data requests from employees require manager approval. Your Device Security: You are responsible for securing your mobile device, using a strong device passcode or biometric lock, and enabling remote wipe if your device is lost. Raycon cannot access recordings stored locally on your device, and cannot access Raycon Tunes settings stored on your phone or earbuds.

Breach Notification:

If we become aware of a personal data breach, we will assess it without undue delay. Where the breach is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of it, as required by Article 33 of the GDPR and the equivalent UK provision. Where the breach is likely to result in a high risk to you, we will notify you directly and without undue delay, describing what happened, what data was involved, what we are doing about it, and what you can do to protect yourself. We will also comply with applicable United States state breach notification laws and with Canadian requirements under PIPEDA. Where we act as a processor rather than a controller, we will notify the relevant controller without undue delay.

Limitations:

No Guarantee of Perfect Security: No method of transmission or storage is completely secure, internet transmission carries inherent risks, and you use our services at your own risk for data confidentiality. Your Responsibilities: Maintain secure access credentials for your account, use a strong and unique password, do not share your password with others, notify us immediately if you suspect unauthorized access, and maintain backups of important recordings outside our system.

Section 8 - Cookies & Tracking Technologies

What Are Cookies:

Cookies are small data files stored on your device that websites and apps use to remember you between visits, keep you logged in, measure usage patterns, and personalize content and ads.

Cookies We Use:

Tracker Name / Provider	Functional Purpose	Type & Lifespan	Regional Legal Standard
_session_id (Shopify)	Authenticates the user session.	First-party Session	Strictly Necessary
_secure_session_id (Shopify)	Secures the session token over HTTPS.	First-party Session	Strictly Necessary
storefront_digest (Shopify)	Verifies access to a password-protected store.	First-party Indefinite	Strictly Necessary
cart (Shopify)	Retains shopping cart contents.	First-party 14 days	Strictly Necessary
preferences (Raycon)	Remembers user display and site preferences.	First-party 1 year	Funktional
_shopify_visit (Shopify)	Tracks the duration of a single site visit.	First-party 30 minutes	Analytics
_shopify_uniq (Shopify)	Counts unique visitors to the store.	First-party 24 hours	Analytics
_ga (Google Analytics)	Measures traffic and usage habits.	Third-party 2 years	Analytics
_gid (Google Analytics)	Distinguishes users within a session.	Third-party 24 hours	Analytics
mxpnid, mxpnrs (Mixpanel)	Measures product and feature engagement. (Notes by Raycon app only)	Third-party 1 year	Analytics
amplitude_id (Amplitude)	Analyzes on-site user behavior over time. (Notes by Raycon app only)	Third-party 10 years	Analytics
_fbp (Meta Platforms, Inc.)	Serves tailored ads on social media.	Third-party 90 days	Targeting

Mobile App Tracking:

Notes by Raycon uses mobile software libraries from Mixpanel and Amplitude for usage analytics, and uses device advertising identifiers (IDFA on iOS, Advertising ID on Android). On iOS we display an App Tracking Transparency prompt asking for your permission, and we honor your answer. You can change it in Settings > Notes by Raycon > Allow Tracking.

Raycon Tunes does not track you. It does not read or transmit the IDFA or the Android Advertising ID, does not use advertising or attribution software, and does not display an App Tracking Transparency prompt because it has nothing to ask permission for. It collects no data that is linked to your identity.

How to Opt Out:

Browser Cookies: Go to your browser settings > Privacy/Cookies, delete existing cookies, or disable cookies (some features may not work).

Advertising Tracking: iOS - Settings > Privacy & Security > Tracking; Android - Settings > Google > Ads; Meta - facebook.com/ads/preferences; Google - myaccount.google.com/ads-settings.

Email Marketing: Unsubscribe link in every marketing email, or email privacy@rayconglobal.com.

Notes by Raycon analytics: Open the app > Settings > Privacy, and toggle "Share Usage Data" off. Essential analytics for app stability remain enabled.

Raycon Tunes usage data: Open the app > Settings > Privacy, and toggle "Share Usage Data" off.

Global Privacy Control: If your browser sends a GPC signal, we treat it as a valid request to opt out of the sale or sharing of your personal information and disable advertising cookies. Learn more at globalprivacycontrol.org.

Section 9 - Shopify & Payment Processing

Shopify Hosting:

Our e-commerce store is hosted on Shopify Inc., which provides platform infrastructure, payment processing, order fulfillment support, and customer relationship management. Your transaction data is stored through Shopify's secure servers behind a firewall. They comply with PCI-DSS for payment security.

Payment Security:

Credit Card Information: Payment information is never stored by Raycon in full form, it is encrypted using industry-standard TLS, processed through PCI-DSS compliant payment gateways, and deleted from our systems after transaction completion. Shopify retains encrypted tokens for recurring billing only. Payment Processor Policies: Read Shopify's privacy policy (shopify.com/legal/privacy) and review your payment processor's terms. For subscriptions, Shopify and RevenueCat maintain tokenized payment information.

Section 10 - Data Sharing & Disclosure

When We Share Your Information:

We do not sell your personal information or your recordings. We share information only in these circumstances. With Service Providers: Only to third-party processors necessary to deliver services, under Data Processing Agreements requiring confidentiality, and only the minimum data needed for that service. For Legal Compliance: Where required by law (court order, subpoena, legal process), with regulatory authorities investigating violations, with law enforcement for criminal investigations, to protect our rights, privacy, safety, or property, and to enforce our Terms of Service. In Business Transitions: If Raycon is acquired, merged, or restructured, the buyer assumes this Privacy Policy and its protection obligations, you have the right to delete your data before transfer, and we provide notice before data transfer. With Your Consent: For partnerships or special integrations, for research or analytics using anonymized data only, and for any use not described in this policy.

Cross-border processing:

Raycon works with software development partners outside the United States, including in China, for the development of our mobile applications and device firmware. These partners work on our source code and on pre-release builds. They do not receive customer personal information, and no customer or device data collected through our apps is transmitted to or stored on servers located in mainland China.

Third-Party Links & Services:

Our website may contain links to third-party sites. We are not responsible for their privacy practices. Review their privacy policies before providing information.

Section 11 - International Data Transfers, GDPR, PIPEDA & U.S. State Privacy Rights

Data Storage Location:

Your data is processed and stored on servers located in the United States (AWS, US-East region).

EU and UK General Data Protection Regulation:

If you are located in the European Union or the United Kingdom, you have the right to access your personal data, correct inaccurate data, request deletion, restrict processing, receive your data in a portable format, object to processing, withdraw consent at any time where processing is based on consent, and lodge a complaint with your data protection authority.

Legal Basis for Processing: Performance of a contract, for providing the products and services you have bought; your consent, for marketing and for optional features including app usage sharing; our legitimate interests, for fraud prevention, product improvement, and identifying firmware defects affecting product safety and reliability; and legal compliance, for required disclosures and record-keeping.

EU Representative: We have appointed Prighter Group as our EU Representative under Article 27 GDPR. Website: prighter.com. Portal: app.prighter.com/portal/raycon.

UK Representative: Prighter Group also acts as our UK Representative under Article 27 of the UK GDPR, reachable through the same portal.

Data Transfer Mechanism: We rely on the European Commission's Standard Contractual Clauses, and the UK International Data Transfer Addendum for UK transfers, for transfers of personal data to the United States, together with supplementary technical and organizational measures.

Automated Decision-Making: We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you.

Canada's PIPEDA:

If you are a Canadian resident, you have the right to access your personal information held by us, request correction of inaccurate information, request deletion subject to legal holds, withdraw consent for our use of your data, obtain a portable copy of your data, and lodge a complaint with the Privacy Commissioner.

Recording Consent: You are responsible for complying with Canada's recording laws. Most provinces require consent from all parties before recording. You must obtain consent before using the AI Notetaker to record. Violations can result in civil and criminal penalties. Contact a Canadian lawyer if you are unsure about your jurisdiction.

Data Handling: Your data is processed in the United States. Cross-border transfers are governed by PIPEDA, we implement equivalent safeguards as required in Canada, and you have the right to know about cross-border transfers.

Privacy Commissioner of Canada: priv.gc.ca, or 1-800-282-1376.

California Consumer Privacy Act (CCPA/CPRA):

If you are a California resident, you have the right to know what personal information we collect and how we use it, delete your personal information, correct inaccurate information, opt out of the sale or sharing of your personal information, limit the use of sensitive personal information, and not be discriminated against for exercising these rights.

Categories of Personal Information We Collect:

• Identifiers - name, email address, phone number, postal address, account identifier, IP address, and device identifiers. Collected through the store and the Notes by Raycon app. Not collected through Raycon Tunes.
• Commercial information - purchases, transactions, and subscription status.
• Internet or network activity - browsing history on our site, cookie data, app version, crash logs, and feature usage.
• Audio and electronic information - audio recordings and transcripts, if you use the AI Notetaker.
• Professional information - job title and company name, if you provide them.
• Product and device information - product model, SKU, serial number, firmware version, and Bluetooth device identifier of paired Raycon audio products. Bluetooth identifiers and settings from Raycon Tunes remain on your device and are not transmitted to Raycon.
• Geolocation data - we derive approximate location from IP address for fraud prevention, tax, and shipping purposes on the store. We do not collect precise geolocation, and neither the Notes by Raycon app nor the Raycon Tunes app requests location permission.
• Biometric information - none. We do not use fingerprints, facial recognition, or voiceprints.

Sources: directly from you, automatically from your browser or app, and from our service providers and payment processors.

Business and Commercial Purposes: providing services and customer support, fraud prevention and security, product improvement and analytics, and marketing and advertising with consent.

Sensitive Personal Information: audio recordings you create with the AI Notetaker may contain sensitive personal information depending on what you record. We use it only to provide the recording, transcription, and summarization features you have asked for, and not to infer characteristics about you. You may limit our use of sensitive personal information by disabling cloud features in the Notes by Raycon app or by contacting us.

Sale and Sharing: we do not sell personal information for money. We do engage in "sharing" as CCPA defines it, meaning disclosure for cross-context behavioral advertising, through Meta Pixel and Google Ads on our website. We do not share any Raycon Tunes data for advertising. Opt out by contacting us at privacy@rayconglobal.com, or by sending a Global Privacy Control signal from your browser.

Exercising Your Rights: Email privacy@rayconglobal.com to submit any requests. Include proof of identity. We respond within 45 days and may extend once by a further 45 days where necessary, with notice to you. You may authorize an agent to make a request on your behalf with written permission.

Financial Incentives: we may offer discounts or free trial minutes in exchange for your email address. Participation is voluntary and you can withdraw at any time using the unsubscribe link.

Other U.S. State Privacy Rights:

Residents of other states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Florida, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island, have rights to confirm whether we process their personal data, access it, correct it, delete it, obtain a portable copy, and opt out of targeted advertising, the sale of personal data, and certain profiling. We honor recognized universal opt-out mechanisms, including Global Privacy Control, where the applicable state law requires it. To exercise these rights, email privacy@rayconglobal.com. If we deny your request, you may appeal by replying to our decision with the subject "Privacy Request Appeal"; we will respond within 45 days and will tell you how to contact your state attorney general if you disagree with the outcome.

Section 12 - Age of Consent & Children

Minimum Age Requirements:

Raycon services are intended for users 13 and older, or older where your jurisdiction requires it. Users Under 13 (US): We do not intentionally collect information from children under 13. If we discover we have collected data from a child under 13 without parental consent, we will delete it. Parents and guardians can contact us at privacy@rayconglobal.com. Users Under 16 (EU/UK): We do not intentionally collect information from users under 16. Users aged 13 to 16 may use our services with parental or guardian consent, and we may ask for parental verification for certain features. Users Under the Age of Majority: Some features, especially audio recording, may not be lawful for minors. Parents and guardians should review recording consent laws in their jurisdiction and monitor a minor's use.

Section 13 - Disclosure & Legal Process

We may disclose your information where required by law, court order, or legal process, in responding to government or regulatory requests, in investigating fraud, security breaches, or illegal activity, in protecting our legal rights or the safety of our users, or in enforcing our Terms of Service.

Government Requests: when we receive a government request for user data, we evaluate the legal validity of the request, provide only the minimum information legally required, notify you of the request where legally permitted, and do not provide encryption keys or backdoor access.

Section 14 - Your Responsibilities

By using Raycon services, you agree to comply with all recording consent laws in your jurisdiction, maintain confidentiality of your password and account credentials, use our services only for lawful purposes, ensure you have consent from all recording participants, take responsibility for content you create and share, maintain your own backups of important recordings, secure your mobile device with a passcode or biometric lock, and notify us immediately of security breaches or unauthorized access.

Section 15 - Reporting a Security Vulnerability

If you believe you have found a security vulnerability in a Raycon product, application, or service, including in device firmware or in the over-the-air update process, report it to security@rayconglobal.com. Include enough detail for us to reproduce the issue, and tell us whether you intend to disclose it publicly and on what timeline.

We will acknowledge your report, keep you informed of our assessment, and will not pursue legal action against researchers who report vulnerabilities in good faith, who do not access, modify, or delete data belonging to other users, and who give us a reasonable opportunity to remediate before public disclosure. Where a vulnerability affects products placed on the European Union market, we report to the relevant authorities as required by applicable law, including the Cyber Resilience Act.

Section 16 - Changes to This Privacy Policy

Material Changes:

Material changes include expanded data collection, the addition of a new processor or third-party software library, and changes that affect your rights. Where we hold an email address for you, we will notify you at least 30 days in advance by email, and where the change requires your consent under applicable law we will ask for it rather than relying on your continued use. If you disagree, you can request account deletion before the change takes effect.

Apps without accounts: the Raycon Tunes app has no account and we hold no email address for its users, so email notice is not possible. For that app, we will present material changes to this policy in the app on next launch, with the change summarized, before the change takes effect.

Non-Material Changes:

For clarifications, link updates, and corrections, changes are effective on posting and we update the "Last updated" date.

You can always review the current policy at rayconglobal.com/pages/privacy-policy.

Section 17 - Data Processing Agreements & Enterprise

If your organization requires a Data Processing Agreement for GDPR compliance, SOC 2 audits, or enterprise contracts, email privacy@rayconglobal.com with your organization name and the Raycon services you use. We will provide a standard template within 10 business days. The agreement covers scope and types of processing, processor obligations and security measures, sub-processor disclosures and oversight, data subject rights and assistance, international data transfers under SCCs and the UK IDTA, audit and compliance mechanisms, and liability and indemnification.

Section 18 - Contact Us

General privacy questions
privacy@rayconglobal.com

California privacy requests (CCPA/CPRA)
privacy@rayconglobal.com - include proof of identity

Canadian privacy requests (PIPEDA)
privacy@rayconglobal.com - processed within 30 days

EU and UK data subject requests
Prighter Group, our Article 27 Representative - app.prighter.com/portal/raycon

Security vulnerability reports
security@rayconglobal.com

Legal notices
legal@rayconglobal.com

Postal address
Raycon, Inc.
1115 Broadway, Suite 12
New York, NY 10010
United States