Privacy notice
Last updated 5 November 2026. This notice covers neaion.com, its pre-orders and its free list. Our products are in development and not offered yet; they will come with their own privacy notices.
Who we are
Rawly OÜ, Narva mnt 5, 10117 Tallinn, Estonia (registry code 17484887), is the controller of the personal data described here. Write to us at hello@neaion.com. We have not appointed a data protection officer.
The free list
What we keep: your email address, the product you are most curious about, the words of the consent you gave, when you gave and confirmed it, the language of the page you signed up on (our emails use it) that page’s address on neaion.com and, if the link you followed was marked with a campaign name (such as “linkedin”), that name: to learn which pages and channels bring people. No cookies, no tracking across sites.
Why: to email you when Lychnos Ring and Alkyon launch, and occasionally about their development.
Legal basis: your consent (Article 6(1)(a) GDPR). We first send one email asking you to confirm. If you do not confirm within 30 days, we delete the entry.
How long: until you unsubscribe or withdraw your consent, and at most 12 months after the products launch. We keep the record of your consent, and of its withdrawal, for up to three years, to show that we had it.
Giving us your email is voluntary; without it we cannot put you on the waitlist. Every email we send has an unsubscribe link.
Pre-orders
What we keep: your email address, your name as Stripe collects it with the payment, the finish, size and country you chose, the amount and the payment's references at Stripe, the version of the pre-order terms you accepted, whether you also asked for news (with the words of that box), and when.
Why and on what basis: to manage your pre-order, refund it when you ask, and offer you the purchase (the contract, Article 6(1)(b) GDPR); to keep the accounting records the law requires (Article 6(1)(c) GDPR). News only if you ticked the box (consent, Article 6(1)(a)).
Card details: Stripe processes the payment; we never see or keep your card. Stripe Payments Europe, Ltd. (Ireland) also processes payment data on its own account, for example to prevent fraud and meet its legal duties.
How long: for as long as the pre-order runs; accounting records for seven years, as Estonian law requires. For a pre-order from the United States, the record of the conditional sale (your name, email, the product and the date) for 60 months, as the US Federal Communications Commission’s rules require (47 CFR 2.803); we keep it on the basis of our legitimate interest in meeting that duty (Article 6(1)(f) GDPR).
Visiting the site
The site uses no analytics, no advertising and no tracking, and sets no cookies of its own, so it shows no cookie banner. Our host, Cloudflare, processes your IP address and the details of each request to deliver the site and to protect it from abuse, and may set strictly necessary security cookies (such as __cf_bm). Legal basis: our legitimate interest in a site that works and stays secure (Article 6(1)(f) GDPR). The fonts and code are served from neaion.com itself; the page loads nothing from other sites.
One setting is kept in your browser’s local storage if you use it: whether you paused the page’s motion. It never leaves your device.
Emails to us
If you write to us, we use your message and address to answer, on the basis of our legitimate interest in replying (Article 6(1)(f) GDPR), and keep them as long as the conversation needs.
Who receives the data
- Cloudflare, Inc.: hosting, and the database of pre-orders and the list, which is stored in the EU.
- Stripe Payments Europe, Ltd.: payments for pre-orders.
- Infomaniak Network SA, Geneva, Switzerland: sending the confirmation and the launch emails, from its servers in Switzerland.
All three act on our instructions under data processing agreements. Cloudflare is a US company: transfers outside the EU rely on the EU-US Data Privacy Framework and the European Commission’s standard contractual clauses. Infomaniak keeps the emails in Switzerland, which the European Commission recognises as protecting personal data adequately.
Your rights
You may ask for access to your data, its correction or deletion, a restriction of its use, or a copy in a portable format, and you may object to processing based on our legitimate interest. You may withdraw your consent at any time; this does not affect what we did before. We make no automated decisions about you.
You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or to the authority where you live.