Ray Solutions Ltd, a company registered in the UK with registration number 08183303, understands the importance of protecting your privacy. As such, we comply with the UK Data Protection Act 2018 (the Data Protection Act). This Privacy Policy is issued on behalf of Ray Solutions Ltd, and when we refer to “we”, “us”, or “our” in this Privacy Policy, we are referring to the Ray Solutions Ltd company that is responsible for processing your Personal Information. Ray Solutions Ltd is the controller (as defined in the Data Protection Act) and is responsible for this website.

Some of the information you provide us as part of your dealings with us is “Personal Information” or “Personal Data” under the Data Protection Act. This Privacy Policy sets out how we collect, handle, use, transmit, and disclose your Personal Information. This Privacy Policy applies to you unless you give us explicit consent to act otherwise. By providing us with Personal Information, registering an Account, or otherwise using the website or our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and consent to us collecting, handling, using, transmitting, and disclosing your Personal Information as set out in this Privacy Policy. Please use the “Definitions” section to understand the meaning of capitalised terms within this Privacy Policy.

If you would like to know more about data protection generally in the UK and European Economic Area, there is information available from the:

UK Information Commissioner’s Office (at www.ico.org.uk); and

European Commission Data Protection Officer (at www.ec.europa.eu/dataprotectionofficer/).

WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

The Personal Information we collect from you will depend on how you use the Website, whether you have created an account for the Website, or are just visiting the Website. The following is a list of the Personal Information we may collect, along with details of how we use that Personal Information:

Customer Account Information: This is information about you that identifies you with an Account that you have created with us, or with an Account that your employer has created with us and for which you are a contact person. This information may include your name, email address, and telephone number. We will process this information to maintain and manage your account with us and to properly manage our business (our legitimate interest). Where you have entered into a contract with us, we will process your Personal Information to fulfill our contract with you.

Registration information: When you register to use our Website and/or if you report an issue with our Website, we will process the Personal Information you provide. This may include your name, contact details, and Website login information. We will process this information to manage your registration, correspondence, or to address your question or concern. The purpose for processing this data is to ensure the proper administration of your registration, correspondence, or inquiry, and to manage our business (our legitimate interest).

Transaction Data: If you purchase our services from us, you must provide us with certain information. This may include your name, billing information, credit card number and expiration date, and other information necessary to process your payment and provide you with the services you have purchased. We will process this information in order to fulfill our contract with you and to complete the transaction (our legitimate interest).

Correspondence Data: If you communicate with us, we may process the data contained in your correspondence, such as your name and contact information, the content of your correspondence, and any metadata generated by our Website when you communicate with us using the contact form on our Website. We will process this data in order to communicate with you and to ensure that we operate our business properly (our legitimate interest).

Regulatory Data: We may process your information if we are required to do so by law or regulation, or in order to protect your or another individual’s vital interests.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will use your Personal Information for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy or the User Agreement. Unless specifically set out in this Privacy Policy and the User Agreement, we will not sell or disclose your Personal Information to any person located in the UK, European Union, or overseas, or use your Personal Information for any other purpose without your prior consent, unless authorized or required by law. Generally, we will only collect, use, and disclose your Personal Information for the following purposes:

• To register your account or otherwise register you to use the Website.
• To provide you with information you request about us or our services.
• To provide you with the services you request.
• To process and obtain payment for any services you order from us.
• To understand your needs and Website usage to help us improve the Website, our marketing, or the way we do business.
• To verify your identity or age (if necessary).
• To contact you for direct marketing and promotional purposes, including providing you with information about new products or services, events, and special offers. You can tell us that you do not wish to receive this type of information at any time.
• To conduct surveys and questionnaires. You can tell us that you do not wish to be involved in such surveys or questionnaires at any time.
• To send you electronic marketing messages updating you about products, services, free trials, and other offers. We will only send you such electronic marketing messages if you have consented to receive them or it can be inferred from your existing business relationship with us that there is a reasonable expectation of receiving those electronic marketing messages. All electronic marketing messages will identify us. You can unsubscribe from such electronic marketing messages at any time.

We will get your express consent before we share your Personal Information with any third party for marketing purposes or any other business purposes.

HOW DO WE USE INFORMATION THAT IS NOT PERSONAL INFORMATION?

From time to time, we may sell or disclose non-Personal Information to any person for any purpose at our sole discretion. Non-Personal Information is information that does not identify you or any other individual. For example, we may sell, disclose, or use non-Personal Information to determine what advertising, promotional materials, products, or services are likely to be of most interest to you or other Website visitors, or to help merchants and other third parties monitor general consumer trends in various areas.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect Personal Information from you in the following ways:

• When you subscribe to our newsletter.
• When you fill any form on our website.
• When you create an Account and register to use the Website.
• When you pay for a service provided by us.
• When you contact us.
• When you participate in surveys or questionnaires.
• When you upload information to the Website.

WHAT HAPPENS IF YOU DON’T PROVIDE US WITH THE INFORMATION WE REQUIRE?

We may require you to provide certain Personal Information in order to provide you with the information, products, or services you request. If you do not provide this Personal Information, we may be unable to provide you with the information, products, or services you wish to buy or receive.

INTERNATIONAL TRANSFERS

We share your Personal Information with our Related Companies within the Ray Solutions Ltd. This involves transferring your Personal Information outside the UK and the European Economic Area (EEA). We ensure your Personal Information is protected by requiring our Related Companies to comply with the same rules when processing your Personal Information. These rules are called “binding corporate rules”.

• Transferring Personal Information Outside the UK and EEA: Wherever we transfer your Personal Information out of the UK and the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for your Personal Information by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection as it has in Europe.
• Where we use providers based in the US, we may transfer Personal Information to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Information shared between the EEA and the US.

PERSONAL INFORMATION SECURITY

We will take reasonable and appropriate steps to protect your Personal Information from risks such as loss, unauthorized access or use, destruction, modification, or disclosure. Apart from the disclosure or transfer of your Personal Information to OVH, Azure, and AWS and between our Related Companies (see “Where your information is stored” below), we only allow our authorized personnel to access your Personal Information. They will only process your Personal Information on our instructions and are subject to a duty of confidentiality.

Internet Security: The internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the internet or for any unauthorized access, use, or modification of that information.

Third-Party Websites: The website may provide links or references to other third-party websites and resources. These websites and resources are not subject to this Privacy Policy. You should review the privacy policy of each third-party website and resource accessed via links from our website, and assess whether the policy of each website and resource is satisfactory to you before you use the website or resource. You acknowledge and agree that we are not responsible for any Personal Information you choose to disclose to a third party through a third-party website referred to by or linked to our website and that such third parties may store your Personal Information in any location in accordance with their own security standards.

PAYMENT CARD INFORMATION

We may store your credit or debit card number if you choose to pay us directly for the services we offer through the Website or any other method, especially if you wish to have payments automatically debited from your nominated bank account at fixed intervals. We may also store your credit or debit card expiry dates and credit limit in order to provide you with the products and services we offer through the Website.

WHERE YOUR INFORMATION IS STORED

We use cloud services like OVH Web Services (OVH), Microsoft Azure, and Amazon Web Services (AWS) to provide data storage services, cloud computing services, to host our website and to store your content, data, and information submitted by you through your use of our website. OVH, Azure, and AWS may transmit, maintain, and store all or parts of your content, data, and information (including Personal Information) on multiple servers across various jurisdictions in addition to servers in the United States. Your content (including Personal Information) may also be transferred between Related Companies of Ray Solutions Ltd that are located in different jurisdictions, including the UK, the European Economic Area (EEA), Australia, and the United States.

Servers in which your information (including Personal Information) may be stored by OVH, Azure, and AWS are likely to be located in the United States, South America (Sao Paulo), Europe (Ireland, The Netherlands, Germany, England, Spain, Italy, France, and Sweden), and the Asia Pacific (Singapore, Japan, China, Korea, and Australia), although additional or other locations may be used by OVH, Azure, and AWS in the future.

Personal Information that you provide to us will be processed by us or other Related Companies located in the UK and/or the EEA (Ray Solutions Ltd), and we and related companies may transmit your Personal Information from the UK and/or the EEA to other Ray Solutions Ltd Related Companies or OVH, Azure, and AWS outside of the UK and/or EEA, including in Australia and the United States.

Ray Solutions Ltd and cloud services like OVH, Azure, and AWS others are subject to domestic European privacy laws enacted under the EU Data Directive, including the General Data Protection Regulation EU 2016/679 and the Data Protection Act 2018 (UK) (together the EU Privacy Laws). EU Privacy Laws permit us, and OVH, Azure, and AWS to transfer your Personal Information from the UK and/or the EEA to countries and territories outside of the UK and/or the EEA with your consent provided that we process your Personal Information in accordance with the requirements of EU Privacy Laws.

Your Consent to Cross-Border Data Transfer:

By providing us with information (including Personal Information), using our service or our website, or registering an Account, you:

(a) consent to us disclosing and transferring your content, data, and information (including the categories of Personal Information listed in this Privacy Policy) to OVH, Azure, and AWS located in the United States for the purpose of allowing OVH, Azure, and AWS to host all data necessary to support the website and for us to provide the our service to you;

(b) consent to us, and OVH, Azure, and AWS transmitting, your content (including the categories of Personal Information listed in this Privacy Policy) from the UK and/or EEA, to servers, OVH, Azure, and AWS located outside of the UK and/or the EEA, to maintaining and storing Your content, data and information (including the categories of Personal Information listed in this Privacy Policy) between and on servers located outside of the UK and/or EEA, including in the regions referred to above; and exchanging such information between our Related Companies in those regions to assist us to perform the User Agreement and otherwise provide the Service to you.

You acknowledge and agree that the transmission of your Personal Information disclosed by you to us between us, OVH, Azure, and AWS located outside of the UK and/or EEA (including Australia and the United States), is necessary for us to maintain the website, provide you with our service, and for the performance of the User Agreement generally.

Limitations on Cross-Border Data Transfer:

You also acknowledge that any data storage functionality associated with our service is not intended for the storage of national insurance numbers, credit or debit card numbers, financial account numbers, driver’s licence numbers, medical information, health insurance information, sensitive data about personal characteristics such as race, religion, or sexual orientation, personal data that may pose a risk of harm to the individual if improperly disclosed.

We may engage other data storage providers or store your information on servers in other locations in the future and will update this Privacy Policy if that is the case. We suggest that you visit our website regularly to keep up to date with any changes.

HOW LONG DO WE USE YOUR PERSONAL INFORMATION FOR?

We will only retain your Personal Information for as long as is reasonably necessary for the purposes for which we collected it, including the purpose of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Information for a longer period if there is a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. To determine the appropriate retention period for Personal Information, we consider the following factors:

• The amount and sensitivity of the Personal Information
• The potential risk of harm from unauthorized use or disclosure of your Personal Information
• The purposes for which we process your Personal Information
• Whether we can achieve those purposes through other means
• Applicable legal, regulatory, tax, accounting, or other requirements

YOUR LEGAL RIGHTS

You have the right to access your Personal Information that we have collected from you and to ensure that it is accurate and up-to-date, in accordance with the requirements of the Data Protection Act. If you wish to access your Personal Information or believe that any of the Personal Information we hold about you is incorrect, incomplete, or outdated, please contact us at the email address provided at the bottom of this Privacy Policy. We will take steps to correct any inaccurate, incomplete, or outdated Personal Information upon your request, where legally required. We may retain or deny you access to your Personal Information if we are legally authorized to do so or where its disclosure to you is restricted by law, is the subject of legal proceedings, or may prejudice the security of another person.

You have the right to access your Personal Information without charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We may also refuse to comply with your request in these circumstances.

Additional Rights: In addition to the right of access to Personal Information, you also have the following rights:

• The right to request that we erase your Personal Information;
• The right to object to the processing of your Personal Information;
• The right to request that we restrict the processing of your Personal Information;
• The right to request that we transfer your Personal Information to you;
• The right to withdraw your consent to our processing of your Personal Information;

Unsubscribe Mechanism: If you receive marketing information from us via electronic messages, there will be a functional “unsubscribe” mechanism included in the message.

HOW CAN YOU STOP RECEIVING MARKETING INFORMATION?

Where marketing information is forwarded to you via electronic messages, there will be a functional ‘unsubscribe’ mechanism contained in the message.

If you no longer wish to be reached by us or get such marketing information, you can exhort us:

• by emailing us at [email protected]; or
• by clicking the ‘unsubscribe function’ (where marketing information is sent electronically).

We will track your record to guarantee you don’t get that information in the future. You can’t decline to get information which we are required to give you by law.

COOKIES

Cookies are small files of data that are sent by a website and stored on your computer’s hard drive when you visit the website. A cookie can contain certain information that the website uses to track the pages you have visited. The only Personal Information a cookie can contain is information that you personally provide. A cookie cannot read data off your hard disk or read cookie files created by other websites.

Our Website uses cookies to help us manage your account and identify you on return visits. Most internet browsers automatically accept cookies, but you can usually change your browser to notify you when you receive a cookie or to reject cookies altogether. However, while most of the content on our Website can be viewed without accepting cookies, full functionality for the Website requires the use of cookies.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time by posting the amended version on our Website at www.ray-solutions.co.uk. We suggest that you visit our Website regularly to keep up to date with any changes.

CONTACTING US

If you would like more information about this Privacy Policy or if you have any queries or complaints, please contact us by email at [email protected]. We will take reasonable steps try to resolve any complaints with you as quickly as practicable. Complaints may also be made directly to the office of the UK Information Commissioner’s Office through its website located at https://ico.org.uk/make-a-complaint.

DEFINITIONS

Unless otherwise defined in this Privacy Policy, words beginning with capital letters are defined in the our User Agreement.

For the purposes of this Privacy Policy:

Personal Information means any data or information that identifies or can be used to identify a living person. This includes information that is directly identifiable, such as a person’s name, address, or date of birth, as well as information that is indirectly identifiable, such as a person’s IP address or online activity.

Personal Information also includes any inferences or opinions about a person, as well as any information about a person’s expectations or the expectations of others in relation to that person.

This definition of Personal Information is broad and includes a wide range of information. It is important to note that Personal Information can be combined with other information to create a more complete picture of a person. For example, a person’s name and address may not be considered Personal Information on their own, but when combined with other information, such as their date of birth or occupation, they may be used to identify that person.

Here are some examples of Personal Information:

• Name
• Address
• Date of birth
• Email address
• Phone number
• IP address
• Online activity
• Medical information
• Financial information
• Employment information
• Political affiliation
• Religious beliefs
• Racial or ethnic origin

It is important to note that not all information about an individual is Personal Information. For example, information that is aggregated or anonymized is not considered Personal Information.

our User Agreement implies the our User Agreement accessible on the Website at www.ray-solutions.co.uk as refreshed now and again which you should peruse and acknowledge as a state of enrolling an Account and in any case getting to and utilising the our Service.