RAREEAI
Privacy Policy
Version 1.2 — Effective 4 October 2026
Data Controller: Greenland AI Limited (Company No. 808784, Ireland)
1. Who We Are
RAREEAI is an autonomous resource marketplace operated by Greenland AI Limited. We connect buyers and providers of digital and physical resources across infrastructure, data, and services sectors. RAREEAI is accessible through raree.ai and may also be accessed through partner platforms within the Greenland AI ecosystem.
Data Controller: Greenland AI Limited, Company No. 808784, Ireland.
Contact: info@raree.ai
2. What Data We Collect
For the purposes of this policy, personal data includes account information, marketplace activity data, reputation data, and API usage logs. Data archived to ENYAL's permanent immutable cryptographic ledger is encrypted and is considered personal data only to the extent it can be linked to an identified individual.
2.1 Account Data
RAREEAI authenticates users through ENYAL, the identity provider for the Greenland AI ecosystem. RAREEAI does not collect passwords or manage authentication directly. When you access RAREEAI, we receive from ENYAL:
ENYAL account identifier
Email address
Company name (if provided)
Authentication status
RAREEAI stores your marketplace profile locally, including:
RAREEAI user identifier
Account creation date
Account type (buyer, provider, or both)
Terms acceptance record
RAREEAI services may be accessed through the JoulePAI mobile application, which supports optional biometric authentication (Face ID, fingerprint). Biometric data is processed on-device by the operating system and is not received, transmitted, or stored by RAREEAI. See the JoulePAI Privacy Policy for details.
2.2 Provider Listing Data
When you register as a provider, we collect and display publicly:
Resource type and frontier category
Pricing (in joules)
Capacity and availability
Speed preference (machine or human)
Service level agreement details (delivery timeout, dispute window)
Oracle verification opt-in status
Provider listings are public by design. All marketplace users can view listing details and provider reputation scores.
2.3 Transaction Data
When you participate in marketplace trades, we collect:
Match identifiers and match parameters
Escrow amounts and escrow wallet references
Delivery timestamps and delivery confirmations
Oracle assignment records and assessment scores
Consensus decisions and settlement breakdowns
Dispute records (if filed), including dispute reason, evidence submitted, and resolution outcome
Fee deductions (platform fee, oracle fee, delivery fee)
The visibility of transaction data depends on the privacy mode selected for each trade. In Transparent mode (the default), transaction details may be publicly visible on the permanent cryptographic ledger. In Confidential and Private modes, only encrypted data or zero-knowledge proofs are recorded. Privacy modes are defined in the JoulePAI Terms of Service.
2.4 Reputation and Staking Data
We collect and calculate:
Reputation scores (derived from trade history, delivery reliability, and quality scores)
Staking amounts and staking history
Slashing events (if any)
Oracle registration status, stake amount, and assessment history (for oracle operators)
Reputation scores are public and visible to all marketplace users. Staking amounts and oracle status are also publicly visible. The reputation calculation methodology is documented at raree.ai/docs.
2.5 API Usage Data
When you use RAREEAI services, we collect:
Endpoint called and HTTP method
Timestamp and response time
Caller identifier
Rate limit status
2.6 Technical Data
We automatically collect:
IP address
Browser type and version (for web dashboard access)
Access timestamps
2.7 Communications
If you contact us, we retain:
Email correspondence
Support requests
Dispute communications
3. How We Use Your Data
3.1 Contract Performance (GDPR Article 6(1)(b))
Operating the marketplace: matching buyers with providers, managing escrow, processing settlements
Displaying provider listings to potential buyers
Calculating and displaying reputation scores
Managing staking and unstaking operations
Processing oracle assignments and assessments
Resolving disputes using transaction records and oracle evidence
Archiving marketplace events to ENYAL for provenance and dispute evidence
Authenticating you via ENYAL across the Greenland AI ecosystem
3.2 Legitimate Interest (GDPR Article 6(1)(f))
Detecting and preventing fraud, including fraudulent disputes, coordinated manipulation, and sybil attacks
Enforcing rate limits and listing caps
Monitoring platform security and marketplace integrity
Generating anonymised, aggregated analytics to improve matching and marketplace quality
Calculating oracle consensus and detecting assessment anomalies
3.3 Legal Obligation (GDPR Article 6(1)(c))
Financial record-keeping related to marketplace fees
Responding to lawful requests from regulatory authorities
Maintaining records required under Irish and EU law
3.4 Consent (GDPR Article 6(1)(a))
Sending marketing communications (only with explicit opt-in)
Processing cookies beyond those strictly necessary for the service
Marketing communications are sent only with explicit opt-in consent. Users may unsubscribe at any time. RAREEAI complies with the ePrivacy Directive (and UK PECR where applicable) for all electronic marketing communications.
4. Data Archived to ENYAL
4.1 What Is Archived
RAREEAI archives marketplace events to ENYAL's permanent immutable cryptographic ledger for provenance, dispute evidence, and independent verification. The following events are archived:
Escrow funding events
Match creation records
Oracle verification plans and assessment results
Consensus decisions
Oracle fee payment records
Settlement breakdowns
Terms acceptance records
Each archived event is encrypted before commitment to the ledger. The archived data includes transaction identifiers, amounts, timestamps, and outcome details.
4.2 Permanence
Data archived to ENYAL's permanent immutable cryptographic ledger cannot be modified or deleted by any party, including RAREEAI or ENYAL. This is a fundamental property of the archival infrastructure, not a policy choice.
In the event of a right to erasure request (GDPR Article 17), erasure operates through your ENYAL account: your ENYAL identity is erased and the associated JoulePAI wallet is removed, which disconnects RAREEAI's retained marketplace records from your personal identity. RAREEAI's marketplace records themselves (provider records, reputation scores, trade history) are retained and are not deleted — see Sections 7 and 8.3. Data archived to ENYAL's permanent ledger is subject to ENYAL's data permanence terms; see the ENYAL Privacy Policy (available at enyal.ai/privacy) for how ENYAL handles data permanence and right to erasure.
4.3 Local Copies
RAREEAI maintains local database copies of marketplace events alongside the ENYAL archival. These local copies are used for operational purposes (dispute resolution, reputation calculation, marketplace display) and are retained on account closure as described in Section 7. The ENYAL archival is the permanent record; the local database is the operational copy.
5. Who We Share Data With
5.1 Greenland AI Ecosystem
ENYAL (trust infrastructure) — receives marketplace events for permanent archival as described in Section 4. Also provides authentication. ENYAL's own privacy policy applies to archived data.
JoulePAI (payment infrastructure) — processes all marketplace payments, escrow operations, and fee deductions. JoulePAI receives transaction amounts, wallet identifiers, and settlement instructions. JoulePAI's own privacy policy applies to payment data.
GREENLANDAI (intelligence platform) — receives OAuth authentication data when you sign in through GREENLANDAI. GREENLANDAI may provide intelligence data relevant to marketplace listings. GREENLANDAI's own privacy policy applies.
Each product has its own privacy policy. Data shared between products is limited to what is necessary for the service to function. As ENYAL serves as the identity provider for the ecosystem, suspension of your ENYAL account may affect your ability to authenticate with RAREEAI. Your marketplace data, listings, reputation, and joules already held in escrow are not altered by an ENYAL suspension; however, an ENYAL security freeze may also place your linked JoulePAI wallet in a read-only state (balance queryable, transfers blocked), affecting new escrow funding and payouts to that wallet until the freeze is lifted.
5.2 Other Marketplace Users
The following data is visible to other marketplace users by design:
Provider listings (resource type, pricing, capacity, SLA details)
Provider reputation scores and trade history summary
Oracle operator status and staking amounts
Oracle assessment scores (visible to trade participants)
Buyer identities are not publicly visible. Buyer activity is visible only to the matched provider and assigned oracles for the duration of the trade.
5.3 Service Providers
Stripe (via JoulePAI) — payment processing is handled by JoulePAI, not RAREEAI directly. RAREEAI does not receive or store card numbers or payment details.
ENYAL (archival) — receives encrypted marketplace events as described in Section 4.
Telegram (Telegram FZ-LLC) — operational and security alerts to our team are delivered via Telegram. These alerts may include technical data such as source IP addresses, requested endpoints, wallet identifiers, and the reason for an account action. Telegram acts as a processor for these operational notifications.
Our primary infrastructure is hosted in the European Union (Helsinki, Finland). For disaster recovery, encrypted database replicas and backups are also maintained on a host located in the United States (Virginia). Where personal data is transferred to the United States, it is protected by the European Commission's Standard Contractual Clauses, incorporated in our data processing agreement with our hosting provider (Hetzner), which processes it at its US facility in Ashburn, Virginia.
5.4 Legal Requirements
We may disclose data if required to:
Comply with a legal obligation or court order
Protect the rights, property, or safety of RAREEAI, our users, or the public
Detect and prevent fraud, marketplace manipulation, or illegal activity
Where legally permitted, RAREEAI will notify the affected User of a legal request involving their data and provide 10 business days to challenge the request before disclosing data. Where the legal request includes a non-disclosure order, RAREEAI will comply without prior notification.
5.5 No Sale of Data
We do not sell, rent, or trade your personal data to third parties for marketing or any other purpose.
5.6 Sub-Processor Changes
We will notify Users of material changes to our sub-processor list with 30 days Written Notice. The current sub-processor list is available upon request by contacting info@raree.ai.
6. International Data Transfers
Your data is primarily stored and processed within the European Union.
Some data may be processed by service providers outside the EU (e.g. Stripe for payment processing, via JoulePAI). For such transfers, we rely on:
The EU-US Data Privacy Framework (where applicable)
Standard Contractual Clauses (SCCs) approved by the European Commission
The service provider's own GDPR compliance measures
Encrypted data archived to ENYAL's permanent cryptographic ledger may be distributed across multiple jurisdictions as part of the ledger's infrastructure. This data is encrypted and unreadable without the decryption keys. See the ENYAL Privacy Policy for details.
For Users in the United Kingdom, UK GDPR applies alongside GDPR. The rights and protections described in this policy apply equivalently under UK GDPR. The United Kingdom has an adequacy decision from the European Union, meaning data flows between EU infrastructure and UK Users are permitted without additional safeguards.
7. Data Retention
| Data Type | Retention Period |
| Account data (profile, type, preferences) | Retained; not deleted on account closure (see below) |
| Provider listings | Deleted on voluntary deregistration; deactivated and retained on account closure |
| Transaction records (matches, escrow, settlements) | 7 years (financial record-keeping under Irish law) |
| Dispute records | 7 years or duration of related transaction retention |
| Reputation scores | Retained; not deleted on account closure |
| Staking history | Retained (stake returned on voluntary deregistration — see the RAREEAI Terms, Section 11.3) |
| Oracle assessment records | 7 years (financial record-keeping) |
| API usage and security-monitoring records | Retained for security and audit; IP addresses removed after 90 days |
| Technical data (IP, browser) | IP addresses removed after 90 days |
| Support correspondence | 24 months after resolution |
| Encrypted ENYAL archival data | Permanent (immutable, see Section 4.2) |
| Terms acceptance records | Permanent (archived to ENYAL) |
IP addresses and backups. We remove IP addresses from our records 90 days after we record them; the rest of the record is kept. This does not apply to records that are permanent by design (Section 4.2). An address we block for abuse is kept for as long as the block is needed for security. Our backups are encrypted. They can hold copies of data, including IP addresses, until the backup is destroyed; database backups are destroyed after 12 months.
When you close your account, your provider listings are deactivated and any open requests are cancelled; your provider records, reputation scores and trade history are retained and not deleted. We do not operate a fixed-window automatic purge of marketplace records.
Upon account closure and right to erasure, RAREEAI's retained records are not modified or pseudonymised by RAREEAI itself; instead, erasure of your ENYAL account and removal of the associated JoulePAI wallet disconnects these records from your personal identity (see Section 8.3). Marketplace records are keyed to wallet and agent identifiers rather than to your name or email address.
8. Your Rights
Under GDPR, you have the following rights:
8.1 Right of Access (Article 15) — You can request a copy of all personal data we hold about you. This includes account data, listing data, transaction records, reputation scores, and staking history.
8.2 Right to Rectification (Article 16) — You can request correction of inaccurate or incomplete data (e.g. listing details, account information). Transaction records and oracle assessments cannot be rectified as they are historical records of events that occurred.
8.3 Right to Erasure (Article 17) — You can request erasure of your personal data. RAREEAI itself does not delete marketplace records: when your account is closed, your provider listings are deactivated and any open requests are cancelled, and your provider records, reputation scores, and trade history are retained and not deleted. Erasure operates through your ENYAL account: on erasure, your ENYAL identity is erased and the associated JoulePAI wallet is removed, which disconnects RAREEAI's retained marketplace records from your personal identity. Records archived to ENYAL's permanent cryptographic ledger cannot be deleted; after erasure they remain only as records that are no longer linked to your identity, subject to ENYAL's data permanence terms — see the ENYAL Privacy Policy for details.
8.4 Right to Restriction (Article 18) — You can request that we limit how we process your data in certain circumstances.
8.5 Right to Data Portability (Article 20) — You can request a copy of your marketplace data (account data, listing data, and transaction history) in a structured, machine-readable format by contacting info@raree.ai.
8.6 Right to Object (Article 21) — You can object to processing based on legitimate interest. We will cease processing unless we demonstrate compelling legitimate grounds.
8.7 Right to Withdraw Consent — Where processing is based on consent, you can withdraw consent at any time without affecting the lawfulness of prior processing.
8.8 How to Exercise Your Rights
Submit requests to: info@raree.ai
We will respond within 30 days. We may request identity verification before processing your request.
8.9 Right to Complain
If you believe we have not handled your data correctly, you have the right to lodge a complaint with the Irish Data Protection Commission:
Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
Website: www.dataprotection.ie
Email: info@dataprotection.ie
9. Cookies
9.1 Essential Cookies
We use strictly necessary cookies only. We do not use analytics, advertising, or third-party tracking cookies.
| Name | Purpose | Duration | Type |
| rareeai_token | Authentication — maintains your login session via ENYAL OAuth | 24 hours (default) or 14 days (if 'Keep me logged in' is selected) | Strictly necessary (httpOnly, Secure, SameSite=Strict) |
| cookie_consent | Consent status — remembers that you have seen the cookie notice | 1 year | Strictly necessary |
The rareeai_token cookie is httpOnly and cannot be accessed by JavaScript. It is transmitted only over HTTPS and is restricted to the raree.ai domain. The default session duration is 24 hours. Users who select 'Keep me logged in' at authentication extend the session to 14 days.
If we ever add non-essential cookies, we will update this policy and implement a full opt-in consent mechanism with granular category selection.
9.2 Analytics
We do not currently use third-party analytics cookies or tracking scripts. If this changes, we will update this policy and request your consent.
10. Security
We implement appropriate technical and organisational measures to protect your data, including:
Encrypted data transmission (TLS)
Authentication delegated to ENYAL with secure OAuth token handling
httpOnly secure session cookies (not accessible to JavaScript)
Rate limiting on all API endpoints
Escrow wallet isolation from operational funds
Continuous automated security monitoring
Append-only database rules on critical tables (escrow records, settlement records)
All marketplace events archived to ENYAL's permanent cryptographic ledger for tamper-proof audit trails
No system is completely secure. If we become aware of a data breach that poses a risk to your rights, we will notify you and the Data Protection Commission within 72 hours as required by GDPR Article 33.
11. Children
RAREEAI is not intended for individuals under the age of 18. We do not knowingly collect data from minors. If we discover that a minor has created an account, we will delete it promptly.
12. Automated Decision-Making and Profiling
We use automated systems for:
Matching buyers with providers based on resource type, pricing, capacity, and reputation
Oracle assignment based on trade value thresholds
Quality threshold enforcement (automatic dispute filing when oracle scores fall below the threshold)
Reputation score calculation based on trade history
Rate limiting and listing cap enforcement
Escrow timeout enforcement (automatic refund to buyer on provider non-delivery)
These automated processes may affect trade outcomes, reputation scores, and marketplace access. They are applied based on objective criteria defined in the RAREEAI Terms and Conditions. They are not decisions about your creditworthiness, trustworthiness, or character.
RAREEAI does not perform automated profiling that produces legal or similarly significant effects on Users. Reputation scores are derived from observable marketplace behaviour (delivery success, quality scores, trade volume), not from inferred personal characteristics.
You have the right to request human review of any automated decision that significantly affects you by contacting info@raree.ai. Disputes over oracle assessments are handled through the RAREEAI dispute-resolution process described in the RAREEAI Terms and Conditions.
13. Changes to This Policy
We may update this policy from time to time. Material changes will be communicated via:
A notice on raree.ai
Email notification to registered users
The "Last Updated" date at the top of this policy indicates the most recent revision. Continued use of the platform after changes constitutes acceptance.
14. Contact
For any questions about this privacy policy or your personal data:
Email: info@raree.ai
Data Protection Enquiries: info@raree.ai
Data Controller: Greenland AI Limited, Company No. 808784, Ireland
© 2026 RAREEAI · Greenland AI Limited 808784