Privacy Policy

Effective date: 2021-05-01

Thanks for using the Graphite platform!

This Privacy Policy covers the information we collect about you when you use the Graphite platform.

“Graphite”, “we” and “us” refers to Graphite Note Limited with its principal place of business located at Loreto Road, Muckross, Killarney, Co Kerry, Ireland (European Union), and any of our corporate affiliates. 

“Service”, “Application”, “App” refer to the Graphite software platform. Third-party means unaffiliated persons to Graphite.

You must read and agree to the following Privacy Policy, otherwise, you must not use the App, since only by accepting this Policy you may obtain your end-user license.

User data

For EU data protection legislation (European Data Protection Regulation – GDPR), Graphite is the controller of your personal information. The controller is an entity that determines the purposes and means of the processing of personal data. This purpose is to be able to deliver our service to you and to further enhance and improve your user experience.

The data you provide us is stored with the necessary security measures and preventions, according to EU laws. We make all reasonable efforts to prevent any unauthorized access or disclosure of personal data. However, there are no guarantees on anti-hacker protection, or hardware failure, or other potential unpredictable events that may cause any disclosure.

While accessing the application, App also stores a certain amount of user data on your computer, more precisely in your computer browser. As soon as you close the browser tab or window from where the application is accessed, that data should be deleted by your browser. This is the usual functioning of a browser, but we are not managing it or in control.

We will not share your personal information with any third parties, in any form, except if:

• Being authorized by you (expressly and in advance of such disclosure to a third party).

• To provide you with our service, in any way reasonably required for that service.

• As may be required by law or regulatory requirement, or court order or other judicial authorization, in which case we shall not legally examine such order or try to set it aside.

As mentioned, we may share your data with our trusted partners, being the data processors, to help us provide you with quality service at the level expected or has been agreed upon:

• Data processors, e.g. vendors that provide us with server infrastructure. The processor is an entity that processes personal data, provided by and on behalf of the controller (Graphite).

• Vendors that provide us with analytical and other tools reasonably required in our work.

• Vendors that provide us with email and other communication tools to help us manage our email, etc. communication, e.g. to inform users of new versions, server maintenance, etc.

All our trusted partners as data processors are fully compliant with the GDPR and are also taking your privacy seriously, but we do not have control over their systems in operations.

Your particular data may also be collected by mistake, either by the system erroneously taking unwanted data instead of the wanted one, or by collecting more information than needed. In any case, no information will be collected which is not listed below in the section on the Data we collect, and all the collected Data is preserved equally, regardless if taken unintentionally.

Data that we collect

We are collecting the following user data in general, not necessarily all of them in your case:

Email address, Full name, Any other data you decide to provide/supply. 

Purpose: To create an account and to perform/execute the agreement.

Legal basis: Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject before entering into a contract. Legitimate interest (e.g. to create an account)


The app is not directed at any children under the age of 16. We do not knowingly collect personal information from children under the age of 16, or concerning such children.


Cookies are small text files that websites and web applications, such as ours, may place in visitors’ computer browsers to store various data, e.g. user preferences. The information which we receive through cookies is specific to your computer or mobile phone or another device used and includes the IP address, date and time when your browser loaded the App, which App pages have been seen, etc. We use cookies to learn more about the way you interact with App and, and all aimed to help us improve your experience while using it.

We use Google Analytics services for performing and processing (semi) anonymous detailed statistics regarding App users: their behavior and page visits in the App. Thus, through Google Analytics we will collect and process information regarding the visitor’s browser, the operating system, and the device with which the visitor access the App, and then we will use it only for our purpose. No personal data like any user name or email address is shared with Google, nor would Google be able to identify you based on the data exchanged in this way.

We guarantee that when using Google Analytics, we will process the collected information for each visitor in the terms of strict confidentiality and will not provide any information that will allow Google to personally identify the visitor as an individual human person.

If you wish to delete or reject cookies you may change your browser’s settings and still use our services. However, it is important to note that if you thus change your settings and block certain cookies you may not be able to take full advantage of all of the application’s features.

Ad tracking

We do not allow advertising companies to collect data through our service for ad targeting. We do not track our customers over time and across any such third-party websites, then to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

Notwithstanding the foregoing, the address provided can feed analysis for targeting ad placement. Therefore, by accepting this Policy you are explicitly providing your consent that we use the information on your address, which may lead to you being advertising targeted.

Data rights

If you are from certain territories (such as the European Union), you may have additional data protection rights, such as broader rights to access and delete your provided personal information and to file a complaint with the governmental authority, as well as rights to:

• Restriction: You can ask us to restrict the processing of your information in certain circumstances.

• Objection: You can object to the further processing of any of your personal information in certain circumstances, provided by the applicable data protection legislation in your jurisdiction.

• Withdrawal of consent: Where and while we rely on your consent to process your personal information, you have the right to decline consent and/or if provided, to withdraw it at any time. This will not affect the lawfulness of the processing before the withdrawal of your consent.

• Portability: You can ask us to provide your information in a structured, commonly used, and machine-readable form in certain circumstances, as set by the applicable data legislation.

If you would like to exercise the above rights, please contact us at hello@graphite-note.com and we will consider your request per applicable data protection laws. We may ask you to verify your identity by producing proof, to help us respond to your request.

Complaints and objections

You can get in touch with us on our website form here or on hello@graphite-note.com .

When we receive a formal written complaint, we respond by trying to contact the person who made the complaint. We will also work with the appropriate regulatory authorities or agencies, including local data protection authorities, to resolve any complaints regarding the use or transfer of your Data that we cannot resolve with you directly in a reasonable time.

You are also eligible to directly submit your complaint to the national data protection body of agency or authority, and if within the European Union, you may submit your complaint to the European Data Protection Supervisor (https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en) [validity of the provided link was confirmed on 01.08.2019]


We will post changes to this privacy policy on our website and will inform you via e-mail. Such change will be deemed effective within 7 days from posting. You can opt out of the new policy within 30 days by not using App. The use shall construe you to accept the changes.