Effective Date: September, 1st, 2024

At Ray Fitness, Inc. (“Ray,” "Company" or "We", “Us” or “Our”) we are committed to protecting the privacy and security of personally identifiable information ("Personal Information") you ("User", "you" or "your") may provide using any of our products or services (collectively "Services"). This Privacy Policy describes how Ray collects, uses, and shares your personal information in connection with our website(s), mobile application(s), and other related online or offline offerings (collectively, the “Services”). By using the Services, you acknowledge that you have read and understood this Privacy Policy, which applies to all persons who access or use the Services and who meet our eligibility requirements.

Please read this policy carefully to understand our policies and practices regarding your Personal Information and how we will process it. If you disagree with our policies and practices, do not use the Services. By using the Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to This Privacy Policy). Your continued use of the Services after we revise this Privacy Policy means you accept those changes, so please check the policy periodically for updates.

This Privacy Policy applies only to information we collect via the Services. This policy DOES NOT apply to information that You provide to or is collected by any third party (see Third-Party Links and Services).
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1. Scope and Eligibility

Ray provides a platform for personalized fitness-related content, including exercise routines, progress tracking, and limited social features. Our Services are currently available to individuals in the United States and Canada. If you choose to use our Services from outside these regions, please note that your data may be transferred to, and processed in, the United States or Canada, where data protection laws may differ from those of your home jurisdiction.

You must be at least eighteen (18) years of age to access or use our Services. We do not knowingly collect personal information from anyone under the age of 18, and if we discover that such information has been submitted, we will promptly remove it unless required by law to retain it.

2. Personal Information We Collect

We collect information in three primary ways: information you provide directly, information automatically collected when you use the Services, and information from integrations such as Apple Watch.

When you create a Ray account, we may request your name, email address, phone number, and date of birth to confirm eligibility. You may optionally provide other details, including gender, injuries or limitations affecting your fitness routine, and fitness goals. This information helps us personalize your workouts.

You may upload a photo (avatar) as part of your profile, which is visible to friends you add within the Ray environment. However, no additional user-generated content is posted publicly in the app. If you contact us (by email or through support channels), we may collect the content of your communications and related contact details.

We automatically gather information about your device type, operating system, device[CC1]  identifiers (e.g., IP address), and usage details, such as pages visited and session durations. We use a computer vision feature to track your exercise reps and form accuracy by collecting “key point” motion data. We do not store actual videos or images of you without explicit permission; instead, we rely on anonymized motion markers solely for workout analysis.

Where permitted, we integrate with Apple Watch to collect health or activity data for personalized workout recommendations. Health data is used solely to enhance the Services and is never used for marketing or shared with third parties for advertising. All subscription payments or in-app purchases are processed via Apple’s payment system, so we do not collect or store your payment details.

3. How We Use Your Information

We use personal information to deliver and personalize our Services, including generating exercise programs that account for any injuries or goals you specify. Our rep-tracking features use anonymized motion markers to provide feedback on form and performance. We also send you updates, reminders, or notices about upcoming workouts through email or text messages, and you can opt out of these communications if you wish.

We rely on aggregated or anonymized data to analyze user behavior, enhance the overall user experience, and create new product offerings. We also use personal information to provide customer support and to comply with legal requirements. Where necessary to protect our rights, property, or users’ safety, we may utilize or disclose personal information pursuant to valid legal processes or relevant laws.

4. How We Share Your Information

We share personal information only under specific circumstances. We engage trusted service providers to assist in tasks such as hosting or analytics, and they may access data strictly for these services on our behalf. If Ray is involved in a merger, acquisition, or sale of assets, your personal information may be transferred to the successor entity, subject to the same privacy safeguards.

In limited situations, we may disclose personal information to ensure compliance and/or fulfill a legal obligation, such as complying with a court order or other lawful requests, or to protect the rights and safety of our users or the public. We also respect any explicit consent you provide regarding the disclosure of your personal data.

5. Your Privacy Choices and Rights

You may update or correct your account information, including details about injuries, goals, or your avatar photo, within the Ray application settings. Users can also request access to or correction of their personal information by contacting us at the address listed below. If you wish to delete your account, please let us know and we will remove your data from active use, although certain information may be retained for the following calendar year to fulfill backup or legal obligations.

You may opt out of marketing communications at any time. Choosing to unsubscribe from these marketing messages will not affect essential service communications, which include notifications required for operational or transactional purposes. If you prefer not to receive SMS or email workout reminders, you can disable them in the app settings or reply “STOP” to a text message, and the application will continue to function normally.

You retain control over device permissions, including the camera functionality used for motion analysis or the Apple Watch integration. Restricting these permissions may limit the personalization features available to you.

6. How We Protect Your Information

We use industry-standard security measures to safeguard your personal information, including encryption in transit, restricted access controls, and secure hosting environments. We retain your data for as long as your account remains active and for the following calendar year for backup or legal obligations. After this period, or once the data is no longer needed, we securely delete or anonymize it.

Unfortunately, information transmission via the Internet and mobile services is not 100% secure. Although we do our best to protect your personal information, we cannot guarantee the absolute security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumventing any privacy settings or security measures we provide.

Third-Party Links and Services
‍Our Website and Services may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy does not apply to those third-party websites or services. We encourage you to review their privacy policies before interacting with them.

7. Data Transfers

Ray primarily operates in the United States and Canada. By using the Services, you acknowledge that your personal data may be transferred to and stored in these countries, which may have less stringent data protection laws than those of your jurisdiction. We strive to maintain appropriate safeguards to protect your personal information during any such transfers.

8. Children’s Information

Our Services are not intended for users under the age of 18. We do not knowingly collect personal information from minors. If we discover that a user under 18 has provided us with personal data, we will delete it unless we are legally obligated to retain it.

9. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our practices, technologies, or legal requirements. The date at the top of this policy indicates when it was last revised. If we make significant modifications affecting how we handle personal information, we may provide additional notice, such as sending a service notification or displaying a notice in the Ray application. Your continued use of the Services after changes are posted constitutes acceptance of the updated policy.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or Ray’s data practices, please contact us at:

Ray Fitness Systems Inc.
867 Boylston St, Suite 500
Boston, MA 02116
United States

Email: help@rayfit.com

We will do our best to address your inquiries and requests promptly.

11. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS[

We are providing this supplemental privacy notice to California consumers pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”).

California Privacy Rights. If you are a California resident, you have the following rights:

• Information: The Privacy Policy describes the types of Personal Data we collect in the “Personal Data We Collect ” section above and the sources through which we collect Personal Data in the “How We Collect Personal Data section above. We describe the purposes for which we use and share this data in the “How We Use Personal Data section above and the “How We Share Personal Data section above.

• Access: You can request a copy of the personal information that we maintain about you.

• Deletion: You can ask to delete the personal information that we have collected from you.

Please note that the CCPA limits these rights. For example, it prohibits businesses from providing certain sensitive information in response to an access request and limits the circumstances under which they must comply with a deletion request.

You are entitled to exercise the rights described above free from discrimination.