Privacy Policy

Last Modified: April 9, 2021

Ray, LLC (collectively, “Ray,” “we”, “us”, or “our”) values its customers, their information, their privacy, and their trust. This Privacy Policy (“Policy”) applies to information collected online from users of the Ray website, www.rayisaplace.com (the “Site”), and explains how we collect, use, and protect that information. This Policy applies to Ray’s collection, use, processing, storage, and transfer of information associated with Ray’s Site. For the purposes of this Policy, unless otherwise noted, all references to the Site, includes www.rayisaplace.com, Ray’s online client portal, mobile applications, and other electronic messages between you and the Site. This Policy is also meant to address our obligations under the General Data ProtectionRegulation (“GDPR”).

Throughout this Policy, we refer to the term “Personal Information.” “Personal Information” means data which identifies, describes, is associated with, or could be linked to an individual, such as a name, birthdate, postal address, email address, telephone number, driver’s license number, Social Security Number or other government-issued identification number, credit card number, or other unique identifiers.

Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, we may collect information related to businesses, companies, institutions, or other entities rather than individuals (“Business Information”). We do not consider Business Information, such as title, employer’s name, work email, work phone number, work address, and other similar business information, to be Personal Information.

Information we Collect

We collect information about you in three ways: 1) directly from you; and 2) indirectly from you via your use of the Site.

Information Collected Directly From You
When you contact us using our Site or use the Site’s forms at time of registration or subscribing to our services, posting material, completing applications, or requesting additional services, we will collect certain Personal Information about you so that we may adequately respond to your inquiry or offer services to you such as your name, email address, phone number, and state of residence. We keep this information for the duration of your relationship with us and for an additional two (2) years after you last contact with us. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your contributions. Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons.

Information Collected Indirectly from You
When you visit our Site, we may collect information about your visit and maintain that information in our web server logs, which are records of the activities on our Site. The servers automatically capture and store the information electronically. Examples of the information we may collect include: Internet Protocol (IP) address; browser type and language; Internet ServiceProvider (ISP), referring and exit websites and applications; operating system; date/time stamp of activity; clickstream data; whether you are a first-time or a returning user; links you clicked on while in the Site; and your flow and navigation path through the Site. We use this information in a deidentified and aggregated fashion to help us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve your Site experience.

In some of our email messages, you will find a “click-through URL” linked to content on our Site. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.

Cookies

We use technologies, such as “cookies,” so we can remember certain information about you, remember your preferences, or recognize you when you return to the Site. Cookies also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Site and protect our Site from fraud.

A cookie is a text file that is stored on your computer. As text files, cookies cannot read information on your hard drive, run programs, or deliver viruses to your computer.

Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all our Site’s features.

During your browsing session, we use “session” cookies to store information and monitor Site function. These session cookies are installed during your browsing session and are deleted when the browsing session has ended.

Cookie	When Deleted	Purpose
X-Mapping-omicphef	With browser session	To manage your browser session, maintain website security and correctly benefit from the content delivery network
_ga, _ga_Q4X40G3EJ9	2 years	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assigns a randomly generated number to identify unique visitors.

We also use log files when you visit our Site. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information in our legitimate interest in administering the Site, preventing fraud, tracking website navigation in the aggregate, and gathering broad demographic information for aggregate use.

Web beacons, also known as clear GIFs, are often used in combination with cookies. Often transparent, these images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Site are used. They are not used to access Personal Information

Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to you.

We do not and will not use cookies to collect Personal Information from you that you did not intentionally provide to us. We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

Website Analytics

We use Google Analytics in connection with our Site to gather data such as age, gender, and interests to provide advertising targeted to suit your interests and preferences.

This analytics software helps us target our online ads based on information collected directly from you or by automated means, like cookies. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at https://support.google.com/adwordspolicy/answer/1316548?hl=en and edit or opt-out your Google Display Network ad preferences at https://www.google.com/ads/preferences/

Google Analytics collects anonymous information that is not used to identify a user. This information helps us better understand how visitors use our Site, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you. To learn more about how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ Site or apps”, located at https://www.google.com/policies/privacy/partners/ To learn about how to opt-out of Google Analytics, please visit https://tools.Google.com/dlpage/gaoptout/.

Children’s Information

Our Site is not directed at children. We do not knowingly collect Personal Information from children under the age of 18. If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us by using the information in the “Questions and Contact Information” section, below, and we will take steps to remove such Personal Information from our systems.

Use of Personal Information

We only use your Personal Information for the original purposes it was given and to further our legitimate business interests, such as to transact business, to provide information about our company and products, and to communicate with Site visitors. Personal Information is used also to provide you with a more enjoyable, convenient online experience. We may use your Personal Information to send you requested information, to personalize content for you, to compile, analyze, and better understand user data, demographics and behavior, and to detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about products and services we believe you might find of interest and to administer marketing materials and surveys in which you might participate.

We also use the information automatically collected about you during your use of the Site, as described above, to improve the effectiveness of our website, operations, mobile experience, or marketing efforts, to prevent against fraud and theft, and otherwise to protect our Site’s visitors and our business.

Our employees and agents may view your Personal Information to perform their jobs and address your needs. We authorize their access to your Personal Information on a need-to-know basis to provide you with our products or services, or for one of the other reasons listed in this section, and always in connection with a contractual obligation to protect the privacy of that information.We may also share your information with our affiliates for the purpose of being able to offer you related or additional products and services. Any affiliates receiving such Personal Information from us, will be required by contract, to adhere to the terms of this Policy.

We may also use information you provide to us to communicate with you in the future. If you do not wish to receive such communications, you may opt out (unsubscribe) as described below in the “Access and Consent to Use of Your Personal Information” and “Questions and Contact Information” section.

You may have the right to object to our processing of your Personal Information. If you choose to object to our processing of your information, or if you wish to withdraw your consent to the processing of your Personal Information, you can email us at connect@rayisaplace.com or by mail to: 375 Park Avenue, Suite 2501, New York, NY 10152.

Disclosure of Your Information

We will not sell, rent, or lease any information we collect from you to others. We will not make your Personal Information available to any unaffiliated parties, except as follows:

• To employees, contractors, agents, website vendors, and/or contractors who may use it on our behalf or in connection with their relationship with us;
• To our affiliates, service providers, and third-parties (e.g., Google Analytics and others as described in this Policy) for marketing purposes and building targeted ad campaigns.
• To others, including law enforcement, if we believe such release is reasonably necessary to comply with law or legal process; enforce or apply the applicable Ray Terms of Use per Ray application, if reasonably necessary to protect our operations, clients, or users; detect, prevent or otherwise address fraud, security, or technical issues; protect the rights, property, or safety of others; in a matter of public safety or Policy; or as needed in connection with the transfer of our business assets (for example, if we are acquired by another firm or if we are liquidated during bankruptcy proceedings). In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

In addition, we may share aggregate, non-individual information, incapable of identifying a person, with third parties for lawful purposes. We will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under circumstances described in this Policy.

Access and Consent to Use of Your Personal Information

If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, please see the contact information in the “Questions and Contact Information” section.

If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, please use the contact information provided in the “Questions and Contact Information” section. In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.

Denying or withdrawing consent may not allow us to provide you with some or all the products, services, or information you request.

You may opt-out of receiving marketing-related emails, targeted advertising messages, or promotional offers from Ray by clicking the “unsubscribe” link at the bottom of any email you receive from us or emailing us at connect@rayisaplace.com.

If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your account, orders, customer service inquiries, and other matters. If you agreed to receive future marketing communications directly from a third party through our Site, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s privacy policy. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Your California Privacy Rights

If you are a California resident, you may have certain rights with respect to your Personal Information including the following rights:

1. The right to know, by way of our Policy and any specific inquiries you direct to us, where Personal Information we have about you comes from, what we use that information for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;
2. The right to “opt-out” of Ray’s sale of your Personal Information to any third parties, in the event Ray sells data;
3. The right, with some exceptions, to have your Personal Information deleted from Ray’s possession or control; and
4. The right to receive equal service and pricing from Ray even if you exercise any of your privacy rights.

California Civil Code Section 1798.83 permits users of the Site who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. A California resident may also use an authorized agent to submit a right to access request or a request to delete. To make such a request, to learn more, or if you have any questions or concerns about your California privacy rights, please visit the Privacy Notice for California Residents.

If you are a California resident, you may exercise these rights by emailing us at connect@rayisaplace.com and providing your name, address, and your request. You may be asked to verify your identity before we can respond to your request. If you cannot provide enough information to allow us to verify your identity, we may not be able to respond to your request. Otherwise, if we are able to verify your identity, Ray will respond to your request within forty-five (45) days or as otherwise allowed pursuant to California law.

European Economic Area

The following section, in conjunction with the information above, describes Ray’s data practicesin accordance with the GDPR.

Legal Basis of Processing

We will only process the Personal Information subject to the GDPR as it is described in this Privacy Policy if we have a lawful basis for doing so.

• Individuals have given their consent for one or more specific purposes. Note: Under some jurisdictions, Personal Information may be processed until the individual objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to United Kingdom and European data protection laws;
• Provision of Personal Information is necessary for the performance of an agreement and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation;
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Ray; and
• Processing is necessary for the purposes of the legitimate interests pursued by Ray or bya third party.

Access to Information and Your Rights

For United Kingdom and EU residents subject to the GDPR, you have certain rights relating to your Personal Information, subject to local data protection laws. These rights may include:

• To access your Personal Information held by us (right to access);
• To rectify inaccurate Personal Information and, taking into account the purpose of processing the Personal Information, ensure it is complete (right to rectification);
• To erase/delete your Personal Information, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
• To restrict our processing of your Personal Information to the extent permitted by law(right to restriction of processing);
• To transfer your Personal Information to another controller or processor, to the extent possible (right to data portability);
• To object to any processing of your Personal Information carried out on the basis of our legitimate interests (right to object). Where we process your Personal Information for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
• To the extent we base the collection, processing, and sharing of your Personal Information on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.

To exercise these rights, please submit your specific request by using the information in the “Questions and Contact Information” section below.

Timeframe for Responding to Requests

Ray will respond to your request within thirty (30) days of receipt. The period of response maybe extended to forty-five (45) or sixty (60) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

Fee

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Security of your Personal Information

We are committed to protecting the information we receive from you. We take appropriate security measures to protect your information against unauthorized access to or unauthorized alteration, disclosure or destruction of data. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we maintain appropriate physical, electronic, and managerial procedures to safeguard and secure the information and data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.

Links to Other Websites

Our Site may contain links to, or advertisements about, non-Ray websites. Other sites may also reference, advertise, or link to the Ray Site. You may be able to post content to third party Social Networking Sites on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Site(s), and receive information from them, in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the applicable terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of third-party Social Networking Sites.

While you are using the Site, you may be linked or directed to other third-party websites that are beyond our control. These third-party websites may have privacy policies and terms of use which differ from ours. Please carefully review these policies. We are not responsible for any actions or policies of such third parties.

Retention and Accuracy of Personal Information

We do our best to ensure that the Personal Information we hold, and use is accurate. We rely on the individuals we do business with to disclose to us all relevant information and to inform us of any changes. Personal Information is kept only for so long as is required, in accordance with our records retention policy and legal and regulatory requirements. If Personal Information is no longer required, we destroy it or render it anonymous. In any event, all Personal Information collected by us will be deleted within 24 months of your having last interacted with us or theSite.

Data Transfer

We may maintain your Personal Information on computers and servers located outside of your state of residence, country, or economic region. However, we only process, store, and collect data, including Personal Information, in the United States and will do so only where the privacy and security of your information are adequately protected.

Changes to the Policy

From time to time, we may change this Policy and will notify you of material changes by posting the changed or modified Policy on our Site.

Questions and Contact Information

If you have any questions, wish to access, correct, or amend your Personal Information or unsubscribe, want to register a complaint or simply want more information, you may contact us at:

connect@rayisaplace.com