Privacy Policy

This PRIVACY POLICY (the «Privacy Policy») explains how BotBit, Inc. (through its brand «RAY», «we», «our» or «us») collects, uses, shares and protects the personal information of individuals who interact with our website, rayapp.io («Site»), mobile application («App») or platform («Platform») (the Site, Application and Platform will collectively be the «Service»), and transactional information of individuals who make purchases from merchants who have subscribed to our Platform («Rewards Providers»).

Even if you do not register as a RAY customer, we may still collect, process, use, store and share your transactional data in accordance with this Privacy Policy. By using the Service, you agree to the policies and practices described in this Privacy Policy and Terms of Use. If you do not agree with our policies and practices, you may choose not to use the Service.

RAY may offer certain products and/or services for a fee or for evaluation purposes. In such situations, additional terms or requirements may apply to our collection and use of personal information, and if there is any conflict between such additional terms and this Privacy Policy, the additional terms shall control.

1. Processing of personal data by RAY

In accordance with EU Regulation 2016/679 on data protection («GDPR»), RAY will process personal data that is collected through contact forms, contracting services or any other means related to our website and our application. RAY declares itself responsible for this data. The customer’s personal data that is collected will be treated with absolute confidentiality and in accordance with the duty of secrecy.

Similarly, RAY informs its customers that the personal data collected will be stored in a record of processing activities that is the exclusive property of RAY. We have implemented appropriate technical and organizational measures to ensure the security of your personal data and prevent such data from being destroyed, lost, unlawful or unlawfully altered. In determining these measures, RAY has taken into account the scope, context and purpose of the processing; the current state of the art and the risks involved in developing such measures.

RAY will also access the databases of its clients that you share on the platform in order to carry out the provision of services. In this case, RAY will be called a data processor. The personal data of its clients will be treated with absolute confidentiality and in compliance with the duty of secrecy.

The data controller is the Customer, who contracts the services provided by RAY.

The legitimate basis for processing your data by the data controller is your consent, while the legitimate basis for RAY processing is the performance of the contract.

Information We Collect

As we mentioned earlier, we handle information from different sources.

Information Customer Provides

We collect personal information from you when you voluntarily provide it, such as when you register to access the Service and create an account, use certain aspects of the Service, contact us with inquiries, or respond to one of our surveys. For example, we may collect your name, phone number, email address, photograph, date of birth, location information, Third Party Service login credentials (defined below), other information (such as your online activity or IP from which you are contacted) based on your registration and privacy settings on those Third Party Services, economic and transactional data (e.g. payment or credit card details).

Information Collected Automatically

We collect transactional information automatically when you transact with one of our rewards providers. Transactional information may include details of your receipt (e.g., subtotal, total, and tip amount), payment card information (e.g., the last four digits of your payment card number and payment card expiration date), invoice, and order ticket data (e.g., items purchased and their purchase price) from printers and point-of-sale devices («Terminals») used by Rewards Providers.

When you interact with the Service, we may also use various technologies, including cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other tracking technologies, to automatically collect certain general user data and information, including aggregate measures of Service usage and aggregated technical and other data about your use of the Service that does not personally identify you. For example, we may track the total number of visitors or users of the Service, the number of visitors to each page of our Site or Application, the domain names of our visitors’ Internet service providers, and how end customers use and interact with the service.

Combination of Information Collected by Third Party Services

We may combine personal information we receive from or about you, including information you provide to us and information we automatically collect through the Service, as well as information from other computers or devices you use, with information we collect or receive about you from other online and offline sources, or from other third-party sources.

In addition, one of the special features of the Service is that it allows you to integrate various online third-party services, such as social media and social networking services («Third Party Services»), directly into your RAY experience. To take advantage of this feature, we will ask you to provide us with your username and password for the applicable Third Party Services. By enabling such Third Party Services, you allow us to pass your login information from the Third Party Service to these Third Party Services for this purpose. When you add a Third Party Service account to the Service, we will collect your Third Party Service login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that Third Party Services may use, store and disclose your personal information differently, as described in their policies, and RAY shall have no responsibility or liability for the privacy practices or other actions of any Third Party Services.

In addition, one of the special features of the Service is that it allows you to integrate various online third-party services, such as social media and social networking services («Third Party Services»), directly into your RAY experience. To take advantage of this feature, we will ask you to provide us with your username and password for the applicable Third Party Services. By enabling such Third Party Services, you allow us to pass your login information from the Third Party Service to these Third Party Services for this purpose. When you add a Third Party Service account to the Service, we will collect your Third Party Service login information and other relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. However, please remember that Third Party Services may use, store and disclose your personal information differently, as described in their policies, and RAY shall have no responsibility or liability for the privacy practices or other actions of any Third Party Services.

2. Purposes for which RAY will process your data

RAY uses the personal information you provide in a manner consistent with this Privacy Policy. If you provide information for a particular reason, we may use that information in connection with the reason it was provided. For example, if you contact us by email, we will use the information you provide to answer your question or resolve your problem. In addition, if you provide information to gain access to the Service, we will use your information to provide you with access to such services and to monitor your use of such services.

RAY uses transactional data to facilitate your transactions with rewards providers. If you are a RAY account holder, the rewards providers will use the transactional data to automatically award you reward points and/or to provide you with other offers that may be of interest to you. We may also remove your personal information from transactional data and aggregate it with other anonymous data, aggregate and/or combine aggregated data with other information, and share aggregated data with rewards providers, affiliates, service providers, agents, and business partners. RAY may also disclose de-identified aggregated data to describe our services to current and potential business partners, and to other third parties for other lawful purposes.

RAY and its subsidiaries and affiliates (the «Related Companies») may use data automatically collected through your use of the Service to analyze, improve, support and operate the Service, to help us improve the content and functionality of the Service, to better understand our users, for distribution in general benchmarking data and industry reports and/or other uses and demographics, and other commercial purposes.

RAY and its subsidiaries and affiliates (the «Related Companies») may use data automatically collected through your use of the Service to analyze, improve, support and operate the Service, to help us improve the content and functionality of the Service, to better understand our users, for distribution in general benchmarking data and industry reports and/or other uses and demographics, and other commercial purposes.

RAY and its subsidiaries and affiliates (the «Related Companies») may use data automatically collected through your use of the Service to analyze, improve, support and operate the Service, to help us improve the content and functionality of the Service, to better understand our users, for distribution in general benchmarking data and industry reports and/or other uses and demographics, and other commercial purposes.

When making a purchase from a Rewards Provider using RAY Terminals, your transactional information will be used in accordance with this Privacy Policy. RAY account holders’ transactional data may be used to provide you with RAY reward points and other offers from our Rewards Providers. Transactional data of non-account holders will be collected, processed, used, stored and shared to facilitate the transaction and to fulfill any other lawful purpose.

When making a purchase from a Rewards Provider using RAY Terminals, your transactional information will be used in accordance with this Privacy Policy. RAY account holders’ transactional data may be used to provide you with RAY reward points and other offers from our Rewards Providers. Transactional data of non-account holders will be collected, processed, used, stored and shared to facilitate the transaction and to fulfill any other lawful purpose.

3. Rights that customers may exercise against RAY or the competent authority

Any Client who wishes to exercise their rights of access, rectification, erasure, restriction of processing, data portability or objection must notify RAY upon a written request sent to the email address: [email protected] with the subject “GDPR”. In accordance with the provisions of GDPR, the contents of the rights to which Customers are entitled are as follows:

• Right of access: The Customer may request RAY to disclose what data relating to it is subject to processing by RAY, as well as the source from which the data was collected and the purpose for which the data is processed.

• Right of access: The Customer may request RAY to disclose what data relating to it is subject to processing by RAY, as well as the source from which the data was collected and the purpose for which the data is processed.

• Right to erasure: The Client may request that RAY delete his personal data unless there are justified and valid reasons that allow RAY to keep the data. The Right to Erasure implies a period in which personal data will remain blocked in order to comply with any legal obligations that may arise before its definitive deletion.

• Right to erasure: The Client may request that RAY delete his personal data unless there are justified and valid reasons that allow RAY to keep the data. The Right to Erasure implies a period in which personal data will remain blocked in order to comply with any legal obligations that may arise before its definitive deletion.

• Right to restrict processing: Customer may ask RAY to highlight that their personal data is restricted to the specific purposes Customer agreed to.

• Right to data portability: Customer may request RAY to provide information held by RAY in an interoperable computer-compatible format.

• Right to data portability: Customer may request RAY to provide information held by RAY in an interoperable computer-compatible format.

RAY will comply with any right request from the Client within a maximum period of 30 days after the rights were exercised. RAY informs that this period could be extended up to a maximum of 90 days with a valid justification.

4. Third parties who may have access to customers’ personal data

4. Third parties who may have access to customers’ personal data

However, RAY may allow access to the Customer’s personal data to third parties who provide a relevant service to the Customer. These third parties will acquire the status of Data Processors. As such, they may only process the Customer’s personal data in accordance with RAY’s instructions. In no event will the data processors use the customer’s personal data for any purpose other than those detailed in section 2 of this policy.

From RAY we ensure that third parties effectively comply with the GDPR regulations as you can read below:

     

    5. Cookies

    This website uses its own cookies and those of third parties that are necessary to allow the customer to enjoy all the functionalities of the website, as well as to control and control the customer’s activity on the website. Cookies are small text files that are installed in the Customer’s browser and are used to record their activity on the website, to allow a smoother and more personalized web navigation or to provide additional functions, such as viewing interactive videos or graphics or enabling access to the Customer’s private profile.

    Customers can set and order their browser not to accept cookies, block them and, if necessary, delete them. In accordance with article 22 (2) of Law 34/2002 («LSSI»), the Customer may refuse to install cookies when accessing the website. However, RAY informs you that some of the functions of its website require the installation of cookies in order for it to function properly. As such, customers understand that uninstalling or rejecting cookies may limit their web browsing activities.

    6. Change your browser preferences

    You can change your browser preferences to choose which cookies you should allow access to. These preferences are usually in the «options» or «preferences» menu of your browser.

    You can change your browser preferences to choose which cookies you should allow access to. These preferences are usually in the «options» or «preferences» menu of your browser.

    Internet Explorer: Tools > Internet Options > Settings. For more information, see Microsoft support or the Help tab.

    Firefox: Tools > Options > Privacy > History > Custom settings. For more information, see Mozilla Support or the Help tab.

    Chrome: Settings > Show advanced options > Privacy > Content settings. For more information, see Google Support or the Help tab.

    Safari: Security > Preferences. For more information, see Apple Support or the Help tab.

    However, if you change your preferences and block these cookies, some functions of our website will be cancelled and you will not be able to take full advantage of the functions of our website.

    7. Changes to this Privacy Policy

    The Service and our business may change from time to time. As a result, it may be necessary for RAY to make changes to this Privacy Policy. RAY reserves the right to update or modify this Privacy Policy at any time and from time to time without notice. If we change this Privacy Policy in a material way, we will provide you with appropriate notice. Please review this Privacy Policy periodically, and especially before providing us with any information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Service following any changes or revisions to this Privacy Policy will indicate your acceptance of the terms of such revised Privacy Policy.