- Last updated: August 6, 2022
The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.
This policy applies to all products built and maintained by NRAY LLC including nray.dev.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for a NRAY LLC product, we ask for identifying information such as your name, email address. That’s so we can send you product updates and other essential information. We may send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.
We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us.
When you email nray.dev with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.
To provide products or services you’ve requested. We use some third-party subprocessors to manage newsletter subscriptions and sending customer surveys.
No NRAY LLC human looks at your content except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see “When required under applicable law” below).
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
When required under applicable law.
NRAY LLC is a U.S. company and all data infrastructure are located in the U.S.
- Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. However, if U.S. law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring us to share data, we must comply. Likewise, we will only respond to requests from government authorities outside the U.S. if compelled by the U.S. government through procedures outlined in a mutual legal assistance treaty or agreement. It is NRAY LLC's policy to notify affected users before we share data unless we are legally prohibited from doing so, and except in some emergency cases.
- Preservation requests. Similarly, NRAY LLC's policy is to comply with requests to preserve data only if compelled by the U.S. Federal Stored Communications Act, 18 U.S.C. Section 2703(f), or by a properly served U.S. subpoena for civil matters. We do not share preserved data unless required by law or compelled by a court order that we choose not to appeal. Furthermore, unless we receive a proper warrant, court order, or subpoena before the required preservation period expires, we will destroy any preserved copies of customer data at the end of the preservation period.
- If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we will share only the minimum needed, such as billing addresses and tax exemption information.
At NRAY LLC, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To Be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using NRAY LLC services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not Be Subject to Automated Decision-Making. You have the right to object to and prevent any decision that could have a legal or similarly significant effect on you from being made solely based on automated processes. This right is limited if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at email@example.com.
If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser.
Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to and stored in the United States. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
There are a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with NRAY LLC operations, for instance, if an EU user signs up for our newsletter or participates in one of our surveys. Such transfers are only occasional and data is transferred under the Article 49(1)(b) derogation under GDPR and the UK version of GDPR.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. You can view a history of the changes to our policies since 2022 [on GitHub](https://github.com/basecamp/policies/commits/master https://github.com/nicholasray/nray.dev/commits/main/pages/privacy.mdx). Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.