Adray Privacy Policy

Adray (“Adray,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, retain, delete, and otherwise process personal information when you visit our marketing website, request a demo, communicate with us, create or use a merchant account or merchant dashboard, use our plugins, first-party pixel, conversion reporting, or other tools, or otherwise interact with us online or offline (collectively, the “Services”), and when we collect or process personal information relating to current or former employees, individual contractors, and similar personnel in the ordinary course of business.

This Privacy Policy also explains our role in relation to data we handle for merchants. When we process personal information about merchant representatives, prospects, website visitors to our own properties, users of our own accounts and dashboards, and our current or former employees and individual contractors, we generally act as a controller or business. When we process shopper or end-customer data that a merchant directs us to collect, receive, or analyze through the Services, we generally act as a processor or service provider on the merchant’s behalf, and the merchant is responsible for its own privacy notices and legal obligations.

1. Personal Information We Collect

The personal information we collect depends on how you interact with Adray, the products or features you use, and whether you are acting for a merchant, working with us as an employee or contractor, or otherwise interacting with Adray.

We may collect the following categories of personal information:

• Information You Provide Directly. We collect personal information you submit when you fill out forms on our website, request a demo, create or administer a merchant account, connect integrations, communicate with us, respond to surveys, sign up for marketing updates, or otherwise interact with us. This may include your name, company name, role, email address, phone number, mailing address, login credentials, billing information, the contents of your communications, and any other information you choose to provide.
• Information We Collect Automatically. We and our service providers may automatically collect personal information when you visit our website, use the merchant dashboard, or interact with our plugins, pixel, or related tools, including through cookies, pixels, local storage, logs, and similar technologies.
  • Device and Usage Information. This may include hashed IP address, browser and device type, operating system, language, time zone, referring URL, pages viewed, links clicked, session identifiers, timestamps, and similar usage data.
  • Merchant, Transaction, and Conversion Data. When merchants use our Services, we may receive merchant-account information and business records, as well as shopper or transaction-related information the merchant directs us to process, such as order or event identifiers, purchase or conversion events, product or cart attributes, campaign or referral information, and related analytics or attribution data.
  • Session Replay and Similar Diagnostics. Where we use or enable session replay or similar tools, those tools may collect information about your interactions with our website or dashboard, such as page views, clicks, scrolling, navigation paths, and information entered into forms. We use these tools for troubleshooting, analytics, and service improvement, and their operation may vary by product, configuration, and applicable law.
• Information From Third Parties and Integrations. We may receive personal information from advertising, analytics, identity, hosting, CRM, e-commerce, and other technology providers, as well as from merchant-directed integrations and publicly available sources.
• Workforce and Contractor Information. We may collect personal information in the ordinary course of managing our relationships with employees and individual contractors, such as names and contact details, job titles and responsibilities, work history and qualifications, onboarding and offboarding records, tax, payroll, payment, and benefits information, emergency contact information, device, network, and access credentials, and other information reasonably necessary to administer the relationship, protect our business, and comply with law.
• Sensitive Information. We do not ask consumers to provide sensitive personal information through our marketing site, and we do not use sensitive personal information to infer characteristics about individuals. However, in the ordinary course of administering employment and contractor relationships, we may collect or process limited sensitive personal information, such as government identifiers, financial or tax information, or health-related information, where reasonably necessary for payroll, benefits, accommodations, security, or legal compliance. If sensitive information is included in communications, transaction records, or other content submitted through the Services, we process it only as reasonably necessary to provide the Services, comply with law, or protect rights and security.

2. How and Why We Use Your Information

• To Provide and Operate the Services. We use personal information to operate our website and merchant dashboard, provision accounts, authenticate users, manage plugins and pixel implementations, provide conversion reporting, deliver support, and otherwise provide the Services.
• To Communicate With You. We use personal information to respond to inquiries, send service-related communications, administer your account, provide onboarding and technical support, and, where permitted, send marketing communications about our products and services.
• To Secure the Services and Prevent Misuse. We use personal information to monitor, investigate, detect, and prevent fraud, abuse, unauthorized access, security incidents, and other harmful or illegal activity, and to enforce our terms, agreements, and policies.
• To Measure and Improve Performance. We use personal information to understand how our website and Services are used, evaluate marketing campaigns, measure conversions, troubleshoot issues, improve functionality, and develop new features.
• To Support Merchant Analytics and Reporting. When merchants use our Services, we may process personal information and event data to provide attribution, reporting, dashboard insights, and other merchant-requested analytics or operational outputs.
• To Support AI-Enabled Features. We may use personal information to provide AI-enabled features, such as summarization, classification, recommendations, forecasting, or similar outputs requested within the Services. These features may rely on models or tools provided by us or our service providers, and their availability and operation may vary by product or customer configuration.
• To Comply With Law and Manage Our Business. We may use personal information to comply with applicable law, respond to lawful requests, maintain appropriate records, administer employee and contractor relationships, support onboarding, offboarding, payroll, payments, benefits, and internal administration, protect our rights and the rights of others, and evaluate or complete actual or proposed financing, merger, acquisition, sale, or similar business transactions.
• Legal Bases for Processing. Where GDPR or similar laws apply, we generally process personal information based on one or more of the following legal bases: performance of a contract, compliance with legal obligations, our legitimate interests, and your consent where required. If we rely on consent, you may withdraw it at any time, subject to applicable law.

3. Information Sharing, Disclosures, and Transfers

We may disclose personal information to the following categories of recipients, depending on the Services used and the purposes described above:

• Merchants and Merchant-Directed Recipients. If you interact with a merchant that uses our Services, or if you are a representative of a merchant, we may disclose personal information to that merchant and to other parties the merchant directs us to work with.
• Service Providers and Subprocessors. We may disclose personal information to vendors that host, support, secure, analyze, or help operate our business and Services, including providers of cloud infrastructure, customer relationship management, identity and authentication, data storage, analytics, customer support, communications, session replay, artificial intelligence, payroll, payment, benefits, human resources, and similar tools.
• Advertising, Analytics, and Measurement Partners. On our marketing site and other Adray-controlled properties, we may disclose online identifiers, device information, cookie data, and related activity information to partners that help us measure traffic, understand engagement, attribute leads or conversions, and evaluate the effectiveness of campaigns. Depending on the context and applicable law, these disclosures may be made through cookies, our first-party pixel, plugins, or similar technologies.
• Integrations and Platform Partners. We may disclose information to e-commerce platforms, payment, messaging, or other technology partners when a merchant enables or directs those integrations, or when disclosure is necessary to provide requested functionality.
• Legal, Compliance, and Transactional Disclosures. We may disclose personal information to courts, regulators, law enforcement, professional advisers, insurers, auditors, financing sources, or transaction counterparties where reasonably necessary to comply with law, protect rights or safety, collect amounts owed, or support an actual or proposed corporate transaction.
• International Transfers. We and our service providers may process personal information in the United States and other countries where we or they operate. Those countries may have data protection laws that differ from those of the country in which you reside. Where required by law, we use appropriate safeguards for cross-border transfers.

4. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. These measures may include access controls, encryption in transit, network security controls, authentication measures, logging, and vendor management practices.

No method of transmission over the Internet or method of electronic storage is completely secure. As a result, although we work to protect personal information, we cannot guarantee absolute security.

If you believe your interaction with us is no longer secure, please contact us promptly using the information in the “How to Contact Us” section below.

5. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain merchant relationships, administer employee and contractor relationships, manage our operations, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the type of information, whether the information relates to a merchant, website visitor, employee, or contractor, the relevant product or feature, and legal, operational, and contractual requirements.

Information we process on behalf of a merchant is generally retained according to the merchant's instructions, our contract with the merchant, and applicable law. Personal information relating to employees and contractors is generally retained for as long as needed to administer the relationship, maintain required business and security records, and comply with employment, tax, benefits, accounting, and other legal obligations. When personal information is no longer needed, we will delete, de-identify, anonymize, or otherwise place it beyond active use, subject to backups, technical limitations, and legal requirements.

6. Children's Privacy

Our Services are intended for businesses and adult users and are not directed to children. We do not knowingly collect personal information directly from children under 13 through our own marketing site or consumer-facing interactions. If you believe a child has provided us personal information in violation of applicable law, please contact us so we can review and address the issue.

7. Privacy Rights and Choices

Depending on where you live and the context in which we process your personal information, you may have certain rights regarding your personal information. If we process your personal information on behalf of a merchant, we may direct your request to that merchant because the merchant controls that processing.

• Access and Portability. You may have the right to request confirmation of whether we process your personal information and to request access to, or a copy of, that information in a portable format.
• Correction or Rectification. You may have the right to request that we correct inaccurate or incomplete personal information we maintain about you.
• Deletion or Erasure. You may have the right to request deletion of personal information we maintain about you, subject to exceptions permitted by law.
• Objection, Restriction, and Withdrawal of Consent. Depending on applicable law, you may have the right to object to certain processing, request restriction of processing, or withdraw consent where we rely on consent.
• Marketing and Cookie Choices. You can opt out of marketing emails by using the unsubscribe link in the message. Depending on your location and applicable law, you may also be able to adjust cookie settings, use browser-based controls such as Global Privacy Control where available, or follow merchant-provided controls to limit certain analytics and advertising technologies on our site or through merchant implementations.
• Non-Discrimination. We will not discriminate against you for exercising privacy rights available under applicable law.

Where applicable, you may also have the right to lodge a complaint with your local data protection authority or regulator. If you reside in the European Economic Area, you may contact the supervisory authority in the country where you live, work, or believe a violation occurred.

To submit a privacy request, please contact us using the information in the “How to Contact Us” section below. Please describe your request with enough detail for us to understand, evaluate, and respond to it.

To protect personal information, we may need to verify your identity before processing your request. The verification information we request will depend on the nature of the request and our relationship with you.

Where permitted by law, you may designate an authorized agent to make a request on your behalf. We may require proof of the agent's authority and may also ask you to verify your identity directly with us.

We will respond to verified requests within the time required by applicable law. If we deny a request, you may have the right to appeal or complain, depending on your jurisdiction, and we will tell you about any applicable process when required.

8. Notice to California Residents

This section supplements the rest of this Privacy Policy and applies to California residents to the extent the California Consumer Privacy Act, as amended (“CCPA”), applies to our processing.

In the last 12 months, we may have collected the following categories of personal information:

• identifiers, such as name, email address, phone number, online identifiers, account credentials, IP address, and similar identifiers;
• personal information described in California Civil Code section 1798.80, commercial information, and other records, such as company name, business contact details, billing information, transaction details, merchant account information, and records of products or services requested, obtained, or considered;
• Internet or other electronic network activity information, such as browsing history, search history, interactions with our website or dashboard, cookie data, log data, session information, and information about how you use our Services;
• audio, electronic, visual, or similar information, such as support recordings, chat transcripts, screenshots, or session replay data where used;
• professional or employment-related information, such as job title, employer, role, business contact information, and information we maintain in connection with employee and contractor administration; and
• inferences drawn from the information above, such as information used to evaluate engagement, attribute conversions, classify leads, support reporting, or generate merchant insights.

We collect these categories from the sources and for the purposes described above, and we disclose them to the categories of recipients described above. We do not sell personal information for money. Depending on how our marketing site is configured, certain cookie-, pixel-, or plug-in-based disclosures for analytics, advertising, or conversion measurement may be considered “sharing” under California law. California residents may request access, correction, or deletion, and may opt out of sale or sharing where applicable, by contacting us or using any available cookie choices on our site. We do not knowingly use or disclose sensitive personal information to infer characteristics about California residents, and we do not offer financial incentives tied to personal information.

9. Cookies, Tracking Technologies, and Third-Party Links

We use cookies, pixels, software development kits, local storage, plug-ins, and similar technologies on our website and, in some cases, within our merchant dashboard to remember preferences, keep users signed in, understand usage, support analytics, troubleshoot issues, and measure advertising or conversion performance. Some of these technologies are operated by us and others are operated by our service providers or partners. For more detail, see our Cookie Policy.

Where required by law, we or the applicable merchant will seek consent before placing non-essential cookies or similar technologies. On merchant-controlled storefronts, the merchant is generally responsible for providing notices and configuring consent choices, and Adray technologies may rely on merchant-provided consent signals or browser-based controls where available. You can manage cookies through browser settings and, where available, consent or preference tools. Disabling certain technologies may affect site or service functionality.

Our Services may link to third-party websites, applications, or services, or allow merchants to connect third-party integrations. This Privacy Policy does not apply to third-party properties or services, and we are not responsible for their privacy practices.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other business or operational reasons.

When we make changes, we will post the updated policy and revise the “Updated” date below. If changes are material, we will provide additional notice where required by law.

11. Notice to Individuals in Mexico

If Mexican data protection law applies, this section supplements the rest of this Privacy Policy. Adray is responsible for the processing of personal data it handles as a controller for its own purposes, such as operating its website, managing merchant accounts, marketing, administering business relationships, and administering employee and contractor relationships.

If we process personal data on behalf of a merchant, the merchant is responsible for the applicable privacy notice and for responding to rights requests relating to that data. In those cases, Adray acts on the merchant's instructions, subject to our contract and applicable law.

Individuals in Mexico may request access, rectification, cancellation, or opposition (ARCO rights), request limitation on the use or disclosure of personal data, or revoke consent where processing is based on consent, by contacting us using the information below. We may request information needed to verify identity and respond to the request, and we may deny or limit a request where permitted by law.

We may transfer personal data to service providers and other recipients described in this Privacy Policy, including recipients located outside Mexico, for the purposes described above. By providing your personal data where consent is required, you acknowledge these transfers as described in this Privacy Policy.

12. Notice Regarding GDPR

If the General Data Protection Regulation (“GDPR”) applies to our processing of personal data, this section supplements the rest of this Privacy Policy. Adray generally acts as a controller for personal data it processes for its own purposes, such as operating its website, managing merchant accounts, marketing, administering business relationships, and administering employee and contractor relationships. When we process shopper or end-customer personal data on behalf of a merchant through the Services, we generally act as a processor acting on the merchant’s instructions.

When we act as a controller, we generally rely on one or more of the following legal bases, depending on the context: performance of a contract, compliance with legal obligations, our legitimate interests, and your consent where required by law. If you are in the European Economic Area, you may have the right to request access to, correction of, deletion of, restriction of, or portability of your personal data, to object to certain processing, and to withdraw consent where we rely on consent.

If we process your personal data on behalf of a merchant, the merchant is generally responsible for responding to your request, although we may assist the merchant as required by applicable law or contract. You may also have the right to lodge a complaint with the supervisory authority in the country where you live, work, or believe a violation occurred.

13. How to Contact Us

If you have questions about this Privacy Policy or would like to submit a privacy request, please contact us at privacy@adray.ai or at:

Adray, Inc.
1111B S Governors Ave # 53849
Dover, DE 19904
United States