Privacy Policy

 

This Privacy Policy, available at https://callray.ai/privacy, governs the use of our services which include, but are not limited to, our website located at https://callray.ai, our mobile application "CallRay," and other related services, features, content, or applications we offer. This policy is applicable regardless of how you access our services, such as through mobile devices or desktops. By engaging with our services, you consent to the practices described in this Privacy Policy and our Terms of Use.

 

We encourage you to read this Privacy Policy thoroughly. If you have questions or need further clarification about our privacy practices or wish to exercise your rights related to your personal data, please reach out to us as detailed in the "Contact Information" section of this document.

 

We may update this Privacy Policy occasionally to reflect changes in law or our service operations. If there are any significant changes, we will notify you either by prominently posting a notice on our website or through direct communication. Continued engagement with our services after these updates take effect will imply your acceptance of the revised Privacy Policy.

 

This policy does not extend to the activities of third parties that are not owned or controlled by us, nor does it apply to third parties to whom we do not provide data processing instructions. Should you choose to disclose your information to these third parties in relation to the service, please review their respective privacy policies to ensure your understanding and agreement. We are not responsible for the privacy practices of these external entities.

 

Contact Information

References to "we," "us," and "our" in this Privacy Policy pertain to Lighter Life Limited. For compliance with the General Data Protection Regulation (GDPR) and any applicable data protection laws, Lighter Life Limited acts as the data controller of your information managed through our services.

 

Should you have any questions or need to manage your personal data, please contact us via:

• Email: support@callray.ai
• Postal Address: Rm.1801, Easey Comm. Bldg., 253-261 Hennessy Road, Wanchai, Hong Kong

 

Children’s Privacy

We prioritize the privacy of both young users and their guardians. This section of our Privacy Policy is dedicated to helping children and their guardians understand how we handle children's personal information when they use our services.

 

Our app "CallRay" is designed for children, and as such, we implement strict parental controls and consent mechanisms. Only a parent or legal guardian is authorized to set up and manage a child's account, install the app, authorize payments, and provide any child-specific information as needed for the use of our services.

 

To prevent unauthorized sharing of personal information by children, we employ a Parental Gate feature—a mechanism that includes a knowledge-based quiz to verify adult status before accessing certain parts of our service. This feature may require a user to verify their age, which helps ensure that no personal data from children is inadvertently collected without parental consent.

 

We collect minimal information from children necessary for them to use our services effectively, such as their name, age, and gender, and ensure that areas of our service requiring personal information are accessible only to adults and secured by Parental Gate.

 

We actively prevent any direct marketing to children and allow guardians to manage or delete their child's personal information by contacting us directly.

 

In the event a child's personal data is collected without appropriate guardian consent through our service, please contact us immediately so we can take necessary actions, including data deletion.

 

Why We Collect Your Information

 

We gather and utilize your data for several purposes:

 

1. Contractual Necessity:We collect data essential to fulfill our contractual obligations, allowing us to deliver our products and services efficiently to you.
2. Legitimate Interests:Our operations necessitate data collection for functions such as account management, service personalization, maintenance, customer and technical support, processing transactions, notifying you of significant policy changes, and other administrative purposes. Additionally, data analysis and market research help us enhance service quality and develop new offerings.
3. Consent:With your permission, we send updates about service enhancements, promotions, and other communications that might interest you.

 

Information We Collect About You

 

Personal Data You Provide:

 

• Account Setup and Service Use:When you create an account or engage with our services, we collect details like your email address and phone number. For age verification purposes, we may ask for your date of birth, but we do not store this information permanently.
• Child-Related Information:If applicable, we collect a child's name, age, and gender as necessary for the use of our services.
• Payment Information:Payment details are processed by third-party payment processors and are not stored on our servers.
• Interactions and Feedback:We collect information when you interact with our service, including feedback, comments, and other communications.

 

Automatically Collected Data:

• Device and Usage Information:We gather data about the devices you use to access our services, such as hardware models, operating system versions, and unique device identifiers.
• Location Data:We collect coarse location data (e.g., country or city level) based on your IP address to enhance service functionality.
• Service Use Details:Information about your interactions with our services, including the types of services used and the timing and frequency of your interactions, is collected to improve our offerings.

 

Data From Third Parties:

• We may receive information about you from third parties, such as social media platforms and payment processors, when you link or integrate third-party services with our app.
• Analytical and Marketing Data:External partners may provide us with additional information that helps us tailor our marketing efforts and better understand our user base.

 

How We Keep and Protect Your Data

We implement robust technical and organizational measures to safeguard the personal information we handle. Access to your data is limited to authorized personnel only, and sensitive data is protected through encryption during transmission over the Internet. Despite our efforts, please note that no security system is infallible, and we recommend using our services within a secure environment.

 

Data Retention

We retain your personal information as long as necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law. If there is no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not feasible, securely store your personal data and isolate it from any further processing until deletion is possible.

 

Voice Collection

 

Our application, "CallRay," interacts with users through voice commands and responses. This feature involves capturing audio recordings, which, when containing personal data like children's voices, are considered personal information under privacy laws such as COPPA.

• Android System:For Android users, audio recordings are processed by Apple for transcription. We receive the text of these recordings to provide our services but do not retain the audio files.
• iOS System:For iOS users, audio recordings are processed by Apple for transcription. We receive the text of these recordings to provide our services but do not retain the audio files.

 

Please note that all recordings and their transcriptions are stored in an aggregated and de-identified form to maintain privacy and improve the app's effectiveness.

 

How We Share Your Data

We respect your privacy and limit the sharing of your personal data:

• Service Providers:We may share your information with trusted third-party service providers to facilitate the functioning of our services. These providers are bound by strict confidentiality agreements and can use the information only to perform the tasks we've assigned to them.
• Legal Obligations:If required by law, such as through a court order or to protect our rights and the safety of others, we may disclose your information.
• Business Transfers:In the event of a merger, acquisition, or sale of assets, personal data may be part of the transferred assets.

 

To enhance our services and provide essential infrastructure, we collaborate with the following trusted third-party service providers:

 

1. com, Inc.
   • Service Provided: Cloud Storage Solutions
   • Privacy Policy: Amazon Privacy Policy
   • Data Privacy FAQ: AWS Data Privacy
2. OpenAI, L.L.C.
   • Service Provided: AI-Generated Content Processing
   • Privacy Policy: OpenAI Privacy Policy
3. Firebase (Google LLC)
   • Service Provided: User Authentication, Analytics, and Marketing Services
   • Privacy Policy: Google Privacy Policy
   • Firebase Privacy Details: Firebase Privacy Support

 

Data Sharing Compliance

 

We ensure that all data shared with these providers adheres strictly to our privacy practices and complies with the relevant legal frameworks, safeguarding user privacy and data integrity.

 

 

Your Rights

You have several rights regarding your personal data:

• Access and Correction:You can review, correct, or update your personal data at any time by contacting us.
• Deletion:You can request the deletion of your personal data from our systems, subject to necessary legal exceptions.
• Object or Restrict Processing:Particularly under the GDPR, you have the right to object to or restrict the processing of your personal data.
• Complaints:If you believe that we are not processing your personal data in accordance with the law, you have the right to lodge a complaint with a supervisory authority.

For any of these requests, please contact us using the contact information provided earlier in this policy.

 

California Consumer Privacy Act (CCPA) Compliance

In accordance with the California Consumer Privacy Act (CCPA), we recognize and respect the privacy rights of California residents by providing a transparent notice regarding the categories of personal information we collect and the purposes for which we use such information.

 

Rights Under CCPA: California residents have the right to:

• Request disclosure of our data collection and sales practices, including the categories of personal information we collect, the source of the information, how we use it, and if the information was disclosed or sold to third parties, including the categories of personal information disclosed or sold and the categories of third parties.
• Request a copy of the specific personal information collected about them during the 12 months before their request.
• Request deletion of their personal information, subject to certain exceptions set forth by law.
• Not be discriminated against for exercising their rights under the CCPA.

 

How to Exercise Your Rights: California residents may make a verifiable consumer request to exercise their rights under the CCPA by contacting us at:

• Email:support@callray.ai
• Postal Address:1801, Easey Comm. Bldg., 253-261 Hennessy Road, Wanchai, Hong Kong

Requests for disclosure or deletion can be made by the consumer or by a person registered with the California Secretary of State who is authorized to act on their behalf.

 

 

Cookies and Tracking Technologies

 

To enhance our service and provide a more personalized user experience, we use various tracking technologies, including cookies. These technologies help us understand user behavior and improve our service offerings.

• Third-Party Analytics:We may use third-party analytics tools to help us measure traffic and usage trends for our services.
• Managing Preferences:You can set your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of our services may not function properly without the aid of cookies.