Privacy Policy

Draft for counsel review. Not yet published. Placeholders in [brackets]. To be served at https://launcherro.com/privacy and linked from every campaign page, signup form, email footer and wallet pass.

Last updated: [date]

Who we are

Launcherro is operated by [legal name], [address], [country] ("Launcherro", "we"). Contact: [privacy@launcherro.com].

Launcherro provides signup pages, email updates and wallet passes for companies raising money through investment crowdfunding ("issuers"). When you sign up on an issuer's page, the issuer is the data controller for your personal data and decides why and how it is used. Launcherro is the issuer's data processor: we hold and process your data on the issuer's instructions and under a data processing agreement with them. The issuer's name and contact details are shown on the page where you signed up and in every email we send on their behalf.

Launcherro is the controller only for the limited technical data described under "Security and abuse prevention" and for this website itself.

What we collect

When you sign up on an issuer's page:

• Your email address, and your name if you choose to give it.
• Whether and when you consented to receive updates, and the wording you agreed to.
• Whether and when you verified your email address.
• How you arrived: the referring website's domain (not the full address) and campaign tags in the link you used (UTM parameters).
• An anonymous visitor identifier set by our analytics (see below).

If you add a pass to Apple Wallet or Google Wallet:

• A random pass serial number linked to your signup.
• For Apple Wallet, the device registration Apple sends us so we can update the pass (a device library identifier and a push token). We do not receive your device name, Apple ID or location.
• Whether you tapped the link on the pass.

If you invest through the issuer's offering page:

• The issuer may tell us that you did, so we stop sending you launch emails. This is matched by email address and by the issuer's investor platform user ID.

We do not collect payment details, identity documents, or your IP address in any stored form (see below). We do not ask for a phone number.

How we use it

On the issuer's instructions, to:

• Send you a verification email and, once verified, updates about the issuer's raise (for example, that it has opened or is about to close).
• Update your wallet pass and show you a notification when its status changes.
• Stop contacting you when you unsubscribe, when you invest, or when you ask us to delete your data.
• Measure how the issuer's page performs (visits, signups, verifications, clicks) in aggregate.

Legal basis under the GDPR: your consent for marketing emails and wallet notifications (Article 6(1)(a)), which you can withdraw at any time; the issuer's legitimate interest in running and measuring its campaign for the technical and aggregate data (Article 6(1)(f)).

We never sell your data and never share it with other issuers. Each issuer sees only the people who signed up on its own pages.

Analytics and session replay

Campaign pages use PostHog analytics, served through our own domain. We record page views, form starts and signups, with a random visitor identifier, the referring domain and campaign tags. We also use session replay, which records how a page is used (scrolling, clicks, taps). All text you type into any field, including your email, is masked before recording and never leaves your browser. Full page addresses, verification links and tokens are never sent to analytics.

You can opt out of analytics on any campaign page via the link in its footer, and by enabling "Do Not Track" in your browser.

Email

Emails are sent through Resend (Resend, Inc., USA). Every marketing email includes an unsubscribe link and supports one-click unsubscribe from your mail client. Verification and confirmation emails are transactional and are sent even if you have unsubscribed from updates, but only when you request them.

We record delivery events (delivered, bounced, complained) to keep our sending reputation and to stop sending to addresses that bounce or complain.

Wallet passes

Apple Wallet passes are updated through Apple's push service; Google Wallet passes through Google's Wallet API. Apple and Google process the data needed to deliver the pass and its notifications under their own privacy policies. You can remove a pass at any time from the Wallet app; for Apple Wallet this also removes your device registration from our systems.

Security and abuse prevention

Signup forms are protected by Cloudflare Turnstile, which may process technical data about your browser to tell people from bots. To limit abuse we count requests per network address for 24 hours using a one-way keyed hash; the address itself is not stored. Our servers run on Cloudflare's network; data is encrypted in transit and at rest.

Where your data is stored and transferred

Data is stored on Cloudflare's infrastructure (Cloudflare, Inc., USA) and processed by Resend, PostHog (PostHog, Inc., USA; [EU or US cloud: to confirm]), Apple and Google as described above. Where data leaves the EU/EEA or UK, transfers rely on the EU–US Data Privacy Framework and/or Standard Contractual Clauses. [Counsel to confirm the sub-processor list and transfer mechanism per vendor.]

How long we keep it

We keep your signup for as long as the issuer runs campaigns that you have consented to hear about, because film and other projects can take years. We delete it when you ask us to, and we may delete it earlier if the issuer's agreement with us requires it. After a deletion we keep only a one-way hash of your email address on a suppression list, so that we never email you again by mistake.

Your rights

Depending on where you live you may have the right to access, correct, delete or export your data, to object to or restrict processing, to withdraw consent, and to complain to a supervisory authority. California residents have the rights set out in the CCPA/CPRA, including to know, delete and opt out of sale or sharing (we do neither).

To exercise any right:

• Unsubscribe: use the link in any email.
• Delete everything: use the "delete my data" link on any campaign page or email, or write to the issuer or to us. We send a confirmation link to your address and complete the deletion across our systems, Resend and PostHog within 7 days, and in any case within the 30 days the law allows.
• Anything else: contact the issuer (controller) or us at [privacy@launcherro.com]; we will pass the request on and help fulfil it.

We do not knowingly collect data from anyone under 18. Offerings are for adults.

Changes

We will post changes here with a new date. Material changes will be announced on the campaign pages.