Privacy Policy

Effective Date: November 16, 2025

At Rays, we are committed to protecting and respecting your privacy in connection with your use of our vitamin D optimization app.

1. Information We Collect

Information You Provide

Account Information: Email address, display name, phone number (optional), profile image

Health Profile: Age, gender, skin type (Fitzpatrick scale), vitamin D goals, supplement intake (optional)

Preferences: Notification settings, preferred exposure times, activity preferences

Support Communications: Messages, emails, and feedback you send to our support team

Information We Collect Automatically

Outdoor Detection Data: Sensor readings from your device (magnetometer, GPS accuracy, accelerometer, barometer) to automatically detect when you're outdoors

Location Information: Precise location data for outdoor detection and vitamin D tracking - general location data (geohashed to approximately 5km radius) for weather information

Usage Data: How you interact with the app, session durations, feature usage patterns

Device Information: Device type, operating system, app version, unique device identifiers

Information from Third Parties

Weather Data: UV index, cloud cover, and weather conditions from Azure Maps Weather API

Health App Integration: With your explicit permission, data from Apple HealthKit, Google Fit, or other health platforms you choose to connect

Payment Information: Subscription status and transaction details from RevenueCat (we do not directly handle payment card information)

2. How We Use Information

Core App Functions

  • • Provide personalized vitamin D recommendations
  • • Automatically detect outdoor exposure sessions
  • • Track your progress toward daily goals
  • • Send notifications and reminders
  • • Process subscription payments

Improvement & Support

  • • Improve outdoor detection accuracy through machine learning
  • • Analyze usage patterns to enhance features
  • • Provide customer support and respond to inquiries
  • • Send important updates about the app
  • • Ensure security and prevent fraud

Machine Learning for Outdoor Detection

We use sensor data from your device to train machine learning models that improve outdoor detection accuracy. This helps the app automatically start tracking when you're outside getting vitamin D synthesis. All machine learning processing happens on your device - we only store anonymized patterns to improve the experience for all users.

3. Information Sharing

We do not sell your personal information. We may share information in the following limited circumstances:

Service Providers

We share information with trusted service providers who help us operate the app:

  • • Supabase (database hosting and authentication)
  • • RevenueCat (subscription management)
  • • Azure Maps (weather data)
  • • OneSignal (push notifications)
  • • Twilio (SMS verification)

Health App Integrations

With your explicit permission, we may share your vitamin D data with health apps you choose to connect (Apple HealthKit, Google Fit, etc.). You control these integrations and can disconnect them at any time.

Legal Requirements

We may disclose information if required by law, court order, or to protect the rights, property, or safety of Rays Health Technologies LLC, our users, or others.

4. Data Security & Retention

Security Measures

  • • End-to-end encryption for data transmission
  • • Secure cloud hosting with industry-standard protections
  • • Regular security audits and updates
  • • Limited access to personal data by authorized personnel only

Data Retention

  • • Account data: Until you delete your account
  • • Health tracking data: Until you delete your account
  • • Weather cache: 1-2 hours for performance optimization
  • • Support conversations: 2 years for service quality
  • • Anonymized analytics: Retained indefinitely for product improvement and research

Account Deletion

When you delete your account, we immediately remove all personal identifying information. Anonymized usage patterns may be retained indefinitely to improve the app for other users.

5. Your Privacy Rights

You have the following rights regarding your personal information, regardless of your location:

Access

Request a copy of your personal information

Correction

Update or correct inaccurate information

Deletion

Request deletion of your personal information

Portability

Export your data in CSV format

Restriction

Limit how we use your information

No Discrimination

No penalty for exercising your rights

How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email:
Subject line: "Privacy Request" to help us process your inquiry
• Through the app settings menu
• We will respond within 30 days of verification

6. Children's Privacy

Age Requirement: 18+

Rays is intended for users 18 years and older. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from someone under 18, we will delete that information immediately.

If you are a parent or guardian and believe your child has provided us with personal information, please email us so we can delete that information.

7. Mobile App Analytics & Tracking

As a mobile app, Rays uses device-based analytics and tracking technologies to enhance your experience:

App Performance Analytics

Track app crashes, performance issues, and usage patterns to improve functionality

Device Analytics

Collect device type, OS version, and app version to ensure compatibility

User Preferences

Store your settings, preferences, and app configuration locally on your device

You can control app analytics through your device settings (iOS: Settings > Privacy & Security > Analytics, Android: Settings > Google > Usage & Diagnostics). Note that disabling analytics may affect our ability to provide technical support and app improvements.

8. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or for legal compliance. When we make significant changes, we will:

  • • Notify you through the app or via email
  • • Post the updated policy with a new effective date
  • • Give you 30 days notice for material changes
  • • Continue to protect your information as described in this policy

We encourage you to review this policy periodically to stay informed about how we protect your privacy.

9. Contact Information

Get in Touch

Privacy Questions:

(Include "Privacy Request" in subject line)

General Support:

Mailing Address:

Rays Health Technologies LLC
8 The Green, STE B
Dover, DE 19901
United States

For fastest response to privacy requests, please email us.

10. Jurisdiction-Specific Privacy Rights

Depending on your location, you may have additional privacy rights under local laws.

California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

  • • Right to know what personal information is collected and how it's used
  • • Right to delete personal information (with certain exceptions)
  • • Right to opt-out of any "sale" of personal information (we don't sell data)
  • • Right to non-discrimination for exercising these rights

We do not sell personal information to third parties. To exercise your California rights, contact with "California Privacy Request" in the subject line.

EU & UK Residents (GDPR)

Residents of the European Union and United Kingdom have rights under the General Data Protection Regulation:

  • • Right to access your personal data
  • • Right to rectification of inaccurate data
  • • Right to erasure ("right to be forgotten")
  • • Right to restrict processing
  • • Right to data portability
  • • Right to object to processing
  • • Right to lodge a complaint with supervisory authorities

Legal Basis: We process your data based on your consent, contract performance, legitimate interests, and legal obligations. You may withdraw consent at any time.

Data Transfers: Your data is processed in the United States with appropriate safeguards in place for international transfers.

Other US State Residents

Residents of Virginia, Colorado, Connecticut, Utah, and other states with privacy laws have similar rights:

  • • Right to access and delete personal information
  • • Right to correct inaccurate information
  • • Right to opt-out of targeted advertising
  • • Right to opt-out of profiling for significant decisions

We don't engage in targeted advertising or automated decision-making that produces legal or significant effects. Contact with "State Privacy Request" in the subject line to exercise your rights.

Important Health Disclaimer

Rays is not a medical device and does not provide medical advice. The app provides lifestyle recommendations for vitamin D optimization based on scientific research, but these are not substitutes for professional medical advice, diagnosis, or treatment. Always consult with qualified healthcare providers before making health-related decisions. Do not ignore professional medical advice or delay seeking treatment because of information from this app.

Last updated: June 16, 2025

This Privacy Policy is effective immediately and supersedes all previous versions.