Privacy Policy

1. Introduction

RaspberryPints, LLC ("RaspberryPints," "we," "our," or "us"), an Arizona limited liability company, provides brewery and taproom management software, digital taplist displays, and related hardware. This Privacy Policy explains what personal information we collect, why we collect it, who we share it with, how long we keep it, and the rights you have over it.

This policy covers our website at raspberrypints.com, our brewery admin panel, our public taplist displays, our TV applications, our Partner API, and our FlowBox hardware (collectively, the "Services").

A note on roles. For information about our own customers, such as your account and billing details, we act as a controller (or "business" under California law) and this policy governs. For information a brewery puts into the Services about its own operations, we act as a processor (or "service provider") on that brewery's behalf, and we handle it according to our agreement with them.

2. Information We Collect and Why

The table below is our full disclosure of the categories of personal information we collect, using the category names from the California Consumer Privacy Act as amended by the California Privacy Rights Act. It states the sources, the purposes, who we disclose each category to, and how long we keep it.

2.1 Sensitive Personal Information

We do not collect sensitive personal information as that term is defined under the CPRA. We do not collect government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, health information, biometric information, or the contents of your mail, email, or messages. Because we do not collect it, the right to limit the use of sensitive personal information does not apply.

2.2 Information We Do Not Want

Please do not upload images containing identifiable members of the public without their permission, and do not enter personal information about your customers into free-text fields in the Services. The Services are not designed to hold that kind of data.

3. Product Analytics and Session Replay

We use FullStory for product analytics and session replay. On our marketing site, this runs only if you consent through our cookie banner, and you can withdraw consent at any time.

In the brewery admin panel and other signed-in areas, session replay is part of how we operate and support the product, and it runs for all signed-in users. It records how you interact with the interface, including page views, clicks, scrolls, navigation, and form interactions, and it associates that activity with your account so we can correlate it with support requests. Password fields and payment details are masked and are never captured. We disclosed this in our Terms of Service and we repeat it here so it is not buried.

We do not sell this data and we do not use it for advertising. If you would prefer that we exclude your account from session recording, email privacy@raspberrypints.com and we will do so. You may also request deletion of recordings associated with your account at any time.

4. Automated Decision-Making

Images you upload are screened automatically by Amazon Rekognition for explicit nudity, graphic violence, and hate symbols before publication. A flagged image is rejected without prior human review. You can request human review of any rejection by contacting support.

This is the only automated processing we perform on content you submit. We do not use automated decision-making or profiling to make decisions that produce legal or similarly significant effects about you, including decisions about pricing, credit, or access to the Services.

5. Do Not Sell or Share My Personal Information

We do not sell your personal information for money, and we never have.

However, when you consent to advertising cookies on our marketing site, the Meta Pixel and PromoteKit receive information about your visit. Under California law this counts as "sharing" personal information for cross-context behavioral advertising, and under some other state laws it may count as a "sale," even though no money changes hands. We want to be straightforward about that rather than rely on a narrow reading.

You can opt out at any time, and there are three ways to do it:

• Use the Do Not Sell or Share My Personal Information link in our footer, which opens your cookie preferences, and turn off Advertising
• Enable Global Privacy Control in your browser or extension. We treat a GPC signal as a valid, binding opt-out and we apply it automatically without requiring you to create an account or verify your identity. When GPC is present, advertising tags do not load and the setting is locked off
• Email privacy@raspberrypints.com

We do not share the personal information of anyone we know to be under 16.

Some browsers offer a "Do Not Track" signal. There is still no common standard for what DNT means, so we do not respond to it. GPC is different, has a defined legal meaning, and we do honor it.

6. Who We Share Information With

We disclose personal information to the service providers below, each of which is contractually restricted to using it only to provide services to us:

We may also disclose personal information to comply with a court order, law, or legal process, including a government or regulatory request; to enforce our Terms of Service; and where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of RaspberryPints, our customers, or the public.

If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction. We will notify you before your information becomes subject to a materially different privacy policy.

We may share aggregated or de-identified information that cannot reasonably be used to identify you. Where we do, we maintain that information in de-identified form and do not attempt to re-identify it.

7. Legal Bases for Processing (EEA and UK)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR:

• Performance of a contract for creating and running your account, providing the Services, and processing payments
• Legitimate interests for securing the Services, preventing fraud and abuse, understanding how the Services are used, and direct marketing to existing customers. We balance these against your rights and you may object at any time
• Consent for non-essential cookies, session replay on the marketing site, and marketing emails to people who are not existing customers. You may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal
• Legal obligation for retaining transaction records for tax and accounting purposes and for responding to lawful requests

8. International Data Transfers

We are based in the United States and our servers are located there. If you access the Services from outside the United States, your personal information will be transferred to and processed in the United States, which may not provide the same level of data protection as your home country.

Where we transfer personal information out of the EEA, the UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with supplementary technical measures including encryption in transit and at rest. You may request a copy of the relevant transfer mechanism by emailing privacy@raspberrypints.com.

For customers in Australia, we handle personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth). By using the Services you acknowledge that your information will be stored and processed in the United States, and that we have taken reasonable steps to require our overseas recipients to handle it consistently with the Australian Privacy Principles.

9. Data Retention

Retention periods for each category are stated in the table in Section 2. In general:

• Account and brewery data is retained for the life of your account and deleted 30 days after termination. You may request an export during that window
• Transaction and billing records are retained for 7 years to meet tax and accounting obligations
• Session replay recordings are retained for 1 month
• Analytics data is retained for 14 months
• Server and security logs are retained for 90 days

We may retain information for longer where required to comply with a legal obligation, resolve a dispute, or enforce our agreements. Where we no longer need information but cannot immediately delete it, for example because it exists in a backup, we isolate it from further processing until deletion.

10. Data Security

We implement technical and organizational measures designed to protect personal information, including encryption in transit and at rest, role-based access controls, tenant isolation between brewery accounts, and audit logging of critical actions. Our Security page describes these in detail, including an honest account of what we have not implemented.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and the relevant regulators as required by applicable law.

11. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights. We honor these rights for all users regardless of location, except where doing so would conflict with a legal obligation.

• Know and access: Request the specific pieces and categories of personal information we hold about you, the sources, the purposes, and the categories of third parties we disclose it to
• Correct: Request that we correct inaccurate personal information
• Delete: Request that we delete personal information we collected from you, subject to legal exceptions
• Portability: Receive a copy of your information in a structured, commonly used, machine-readable format
• Opt out of sale or sharing: As described in Section 5
• Limit use of sensitive personal information: Not applicable, because we do not collect it
• Object or restrict: Object to or ask us to restrict processing based on legitimate interests
• Withdraw consent: Where processing is based on consent, withdraw it at any time
• Non-discrimination: We will not deny you service, charge you a different price, or provide a different quality of service because you exercised any of these rights. We do not offer financial incentives in exchange for personal information

11.1 How to Exercise Your Rights

Email privacy@raspberrypints.com with the request and the email address associated with your account. To protect your information, we will verify your identity before acting, typically by confirming control of your account email and matching details we already hold. We do not require you to create an account to submit a request.

We will acknowledge your request within 10 business days and respond substantively within 45 days. If we need more time, we will tell you why and may extend by a further 45 days. There is no fee unless your request is manifestly unfounded or excessive, in which case we will explain the charge before proceeding.

11.2 Authorized Agents

You may use an authorized agent to submit a request on your behalf. We will ask the agent for written proof of your authorization, and we may ask you to verify your identity directly with us or to confirm that you granted the agent permission.

11.3 Appeals

If we decline your request, you may appeal by replying to our decision or emailing privacy@raspberrypints.com with the subject line "Privacy Appeal." A different person than the one who made the original decision will review it, and we will respond within 45 days with our decision and the reasons for it. If we deny your appeal, we will tell you how to contact your state attorney general to lodge a complaint.

11.4 Complaints to a Regulator

If you are in the EEA or UK, you have the right to lodge a complaint with your local supervisory authority. If you are in Australia, you may complain to the Office of the Australian Information Commissioner. We would appreciate the chance to address your concern first.

12. Cookies and Tracking

We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies are set only after you opt in through our cookie banner, and you can change your choices at any time using the Cookie Preferences link in our footer.

13. Children's Privacy

Given the nature of alcoholic beverage management, the Services are intended for business users aged 21 and over. They are not directed to children, and we do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, contact privacy@raspberrypints.com and we will delete it.

14. Third-Party Links and Integrations

The Services may contain links to third-party websites and may let you connect third-party tools such as Untappd or a point-of-sale system. We do not control those services and are not responsible for their privacy practices. Review their privacy policies before connecting them.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make a material change to how we handle personal information, we will notify you by email to the address on your account and by posting a notice on our website at least 30 days before the change takes effect. The "Last Updated" date above always reflects the current version.

16. Contact Us

For any privacy question or to exercise your rights:

RaspberryPints, LLC
18402 N 19th Ave #1062
Phoenix, AZ 85023
United States
Privacy: privacy@raspberrypints.com
Legal: legal@raspberrypints.com

Email is the fastest way to reach us about a privacy request, and it is the method we monitor most closely. You may also write to us at the address above.

We have not appointed an EU or UK representative under Article 27 of the GDPR, on the basis that our processing of EEA and UK personal data is occasional and low risk. If that changes, we will appoint one and update this policy.