RawaHub

Reckon Ball Privacy Policy

  • Last Updated: 2025 Jun 6

Effective Date: 2025 Jun 15

This Privacy Policy describes how Rawa Team (“we,” “our,” or “us”) collects, uses, and discloses your information when you use our mobile application Rawa Team (the “App”) available on Google Play. By using the App, you agree to the terms of this Privacy Policy.

1. Information We Collect

1.1 Personal Information

We may collect the following personal information when you use the App:

  • Account Information (if applicable): Email address, username, or other registration details.
  • Device Information: Device model, operating system, unique device identifiers (e.g., IMEI, MAC address), IP address, and mobile network information.
  • Usage Data: App interactions, crash reports, and performance logs.

1.2 Non-Personal Information

We may collect anonymized or aggregated data that does not directly identify you, such as:

  • Analytics data (e.g., session duration, feature usage).
  • Cookies or similar tracking technologies (if applicable).

2. How We Use Your Information

We use the collected information for the following purposes:

  • To provide, maintain, and improve the App.
  • To troubleshoot and fix errors.
  • To analyze usage trends and optimize performance.
  • To comply with legal obligations.
Why We Process Your Data
We only process personal data when a valid legal basis exists, including:  
- **To fulfill contracts** (e.g., deliver purchased services);  
- **Comply with laws** (e.g., tax records);  
- **With your consent** (e.g., marketing emails);  
- **For legitimate interests** (e.g., fraud prevention, analytics*).  

*You may object to "legitimate interest" processing by contacting email.

3. Right to Know About Data Sharing & Disclosure

We do not sell your personal information. However, we may share data in the following cases:

  • Service Providers: Third-party vendors assisting in analytics (e.g., Google Firebase).
  • Legal Compliance: If required by law (e.g., court orders, government requests).
  • Business Transfers: In case of a merger or acquisition.

You have the right to know:

  1. Whether we share your personal data
  2. Categories of third parties we share with (e.g., advertisers, analytics providers)
  3. Purposes for sharing (e.g., targeted advertising, service functionality)
  4. Specific data elements shared (upon verifiable request)

How We Share Data:

  • With service providers under strict contracts (data processors)
  • With advertising partners (when you consent to cookies)
  • With law enforcement when legally required

How to Exercise This Right:

  • Submit a request via: admin@rawahub.com
  • We will respond within [30/45] days with:
    • Confirmation of whether sharing occurs
    • Categories of recipients
    • Purposes for sharing

Special Cases:

  • California residents: “Sharing” has specific meaning under CCPA for cross-context behavioral advertising
  • EU/UK residents: Right to information under GDPR Article 15(1)(c)
  • Brazil: LGPD Article 18 lists right to information about shared data

Examples of Sharing (customize to your practices):
“We may share device identifiers with advertising networks to show relevant ads, but never sell your name or contact information.”

How to Opt-Out (where applicable):

4. Data Security

We implement industry-standard security measures to protect your data. However, no method is 100% secure, and we cannot guarantee absolute security.

5. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access, correct, or delete your personal data.
  • Opt out of data collection (via device settings).
  • Request a copy of your data.

To exercise these rights, contact us at admin@rawahub.com.

5.1 Your Rights Under CCPA

California residents have the right to:

Know whether their personal data is shared (as defined by CCPA: disclosed to third parties for cross-context behavioral advertising without monetary compensation);

Request details about data categories, sources, purposes, and third parties involved;

Opt-out of data sharing via a “Do Not Share My Personal Information” link or email request.

Submit requests to admin@rawahub.com. We respond within 45 days.

5.2 Opt-Out Rights

You have the right to opt out of: (1) the sharing or sale of your personal data (as defined under CCPA/CPRA); (2) targeted advertising; and (3) automated profiling that produces legal or similarly significant effects. To exercise these rights, click the “Do Not Sell/Share My Personal Information” link in our website footer, submit a request via email to admin@rawahub.com, or use third-party tools like the NAI or DAA opt-out platforms for advertising. We will process your request within 15 days (VCDPA) or 45 days (CCPA). Your choice will not affect your access to our services.

5.3 Under the Virginia Consumer Data Protection Act (VCDPA), Virginia residents have the right to:

  1. Access, correct, or delete their personal data;
  2. Obtain a portable copy of their data;
  3. Opt out of:
    • Targeted advertising;
    • Sale of personal data;
    • Profiling for decisions with legal/significant effects.
      To exercise these rights, submit a request via [email/webform]. We will respond within 45 days.

5.4 Virginia Residents’ Rights Under VCDPA


If you are a Virginia resident, the Virginia Consumer Data Protection Act (VCDPA) grants you:

1. **Access & Control**
– Request a copy of your personal data we hold;
– Correct inaccuracies or delete non-essential data.

2. **Data Portability**
– Receive your data in a machine-readable format (e.g., CSV).

3. **Opt-Out Choices**
You may opt out of:
– Targeted advertising (e.g., ads based on your browsing activity);
– “Sale” of your data* (*as defined by VCDPA, including non-monetary exchanges);
– Automated profiling that significantly affects you (e.g., credit/employment screening).

**How to Exercise Rights**
Submit a verified request:
– Email: admin@rawahub.com (Subject: “VCDPA Request”)
We will respond within 45 days (or 90 days if extended).

*Note:* We may require proof of Virginia residency to process requests.

5.5 Supervisory authority

If you believe our processing of your personal data violates applicable laws, you have the right to lodge a complaint with a supervisory authority in your country/region. Examples include:

California Users: File a complaint with the California Privacy Protection Agency (CPPA).

EU Users: Contact your local EU member state’s Data Protection Authority (list: https://edpb.europa.eu);

5.6 Rights of EU/EEA Users Under GDPR

5.6.1 Your Legal Rights

Under the EU General Data Protection Regulation (GDPR), users located in the European Union and European Economic Area (EEA) have the following rights regarding their personal data:

  1. Right of Access
    To request a copy of your personal data we hold, including information about how we process it.
  2. Right to Rectification
    To correct inaccurate or incomplete personal data.
  3. Right to Erasure (“Right to Be Forgotten”)
    To request deletion of your data when:
    • It’s no longer necessary for its original purpose
    • You withdraw consent and no other legal basis exists
    • The data was unlawfully processed
  4. Right to Restriction of Processing
    To temporarily restrict processing while:
    • Data accuracy is disputed
    • Processing legality is under review
  5. Right to Data Portability
    To receive your provided data in a structured, machine-readable format and transmit it to another controller.
  6. Right to Object
    • To object to processing based on legitimate interests (e.g., direct marketing)
    • To refuse fully automated decision-making with legal/significant effects
  7. Right to Withdraw Consent
    To withdraw previously given consent at any time (without affecting prior lawful processing).

5.6.2 How to Exercise These Rights

  • Submit a Request:
  • Identity Verification: We may require account details and identity confirmation (e.g., redacted ID copy).
  • Response Timeline: We will respond within 30 days (extendable to 60 days for complex cases with prior notice).

5.6.3 Right to Lodge Complaints

If you believe we’ve violated GDPR, you have the right to file a complaint with:

5.6.4 Special Provisions

  • Automated Decision-Making: For algorithmic decisions impacting you (e.g., credit scoring), you may request human intervention and explanation.
  • Children’s Data: Processing data of users under 16 requires parental consent (some EU states may set this at 13).

5.7. Rights of Brazilian Users Under LGPD

5.7.1 Your Rights Under Brazil’s Data Protection Law

Under Lei Geral de Proteção de Dados (LGPD), Brazilian users have the following rights regarding their personal data:

  1. Confirmation & Access
    • Confirm whether we process your data
    • Request a copy of your personal data
  2. Correction
    • Update incomplete, inaccurate, or outdated information
  3. Anonymization, Blocking or Deletion
    • Request removal when:
      • Data is unnecessary or excessive
      • You withdraw consent (when consent was the basis)
      • Processing violates LGPD
  4. Data Portability
    • Receive your data in a structured format for transfer to another service
  5. Information About Sharing
    • Know which third parties we share your data with
  6. Revocation of Consent
    • Withdraw previously given consent at any time
  7. Opposition to Processing
    • Object to processing when we rely on legitimate interest

5.7.2 How to Exercise Your Rights

  • Submit Requests To:
    admin@rawahub.com
  • Required Information:
    • Full name
    • CPF (Brazilian ID) number
    • Detailed description of your request
  • Response Time:
    We will respond within 15 business days (extendable with notification)

5.7.3 Complaint Rights

If unsatisfied with our response, you may contact:

  • Brazil’s National Data Protection Authority (ANPD):
    www.gov.br/anpd
  • Public Consumer Defense Agencies:
    e.g., PROCON in your state

5.7.4 Key LGPD Principles We Follow

  1. Purpose Limitation: Only process data for clear, legitimate purposes
  2. Necessity: Collect only minimum required data
  3. Non-Discrimination: Won’t deny services for exercising LGPD rights
  4. Security: Maintain appropriate technical/organizational measures

Implementation Notes

  1. Language Requirement:
    • Provide this section in Brazilian Portuguese (add “Versão em português disponível [here]”)
  2. Special Cases:
    • For children’s data: Must obtain parental consent for <12 years old
    • Sensitive data: Requires extra protections (racial, health, biometric data etc.)
  3. Coordination with Other Laws:
    “When similar rights exist under both LGPD and GDPR/CCPA, we will apply the most protective standard.”

Concise Alternative:
“Brazilian users have rights under LGPD including access, correction, deletion and portability of personal data. To exercise these rights or file complaints, contact nosso encarregado de dados (DPO) at admin@rawahub.com  or ANPD at www.gov.br/anpd.”

6. Data Retention & Deletion

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy (e.g., to provide services, comply with legal obligations, or resolve disputes). Specific retention periods are as follows:

  1. Account Data: Retained for 12 months after account deletion (for backup recovery or dispute resolution);
  2. Transaction Records: Retained for 7 years as required by tax laws;
  3. Browsing Activity Data: Anonymized and retained for 3 months (for service optimization and analytics);
  4. Customer Support Records: Retained for 2 years (for service quality improvement).

Exceptions:

  • Legal requirements (e.g., investigations, tax audits) may extend retention periods;
  • Anonymized or aggregated data may be retained for statistical analysis.

How to Request Deletion:

We will respond within 30 days and notify you if deletion is not possible due to legal obligations.

7. Children’s Privacy

The App is not intended for children under 13 (or the applicable age in your region). We do not knowingly collect data from minors.

8. Third-Party Services

The App may use third-party services (e.g., Google Analytics) with their own privacy policies. We recommend reviewing their policies.

9. Changes to This Policy

We may update this Privacy Policy. You will be notified of significant changes via the App or our website.

10. Contact Us

For privacy-related questions, contact us at:

**DATA CONTROLLER contact information**

**Data Protection Officer (DPO) Contact**  
To comply with data protection laws (e.g., GDPR), we have appointed a Data Protection Officer:  

- **Name**: eraway hamend
- **Role**: Data Protection Officer  
- **Email**: admin@rawahub.com
- **Postal Address**: Hongkong