Welcome to the Privacy Policy of Raya Culture ("Policy").
This privacy policy explains how we collect, store, protect, and share your information.
We recommend that you read our privacy policy in conjunction with our Terms and Conditions of Use.
While using our App or website on any device, we collect some information about you.
In addition, you may choose to use our App or website to share information with other members, including your friends and contacts (hereinafter referred to as "Members").
In certain circumstances, in order to provide you with better service, we may need to share some of the information you have registered in your profile.
The Site and the App are globally accessible, and your information will be accessible in all countries where the App or Site can be accessed, regardless of the country in which you may reside.
This Policy also explains how we protect your personal data when we transfer it to a country that is not your own, so please read it carefully and with due attention.
About Us
The App and the Sites are operated by "Raya Culture" (also referred to as "we" in this document), owned by the company "OFIR LABS, LDA." which is the controller of personal information collected and processed via the Raya Culture App and Site.
Raya Culture has appointed a Data Protection Officer who can be contacted by email at weare@rayaculture.com or by mail at the following address: Avenida General Roçadas, No. 66, 4th Left, 1170-164 Lisbon, Portugal.
1. COLLECTION OF INFORMATION
Registration Information
At “Raya Culture,” we comply with the GDPR, adhering closely to its binding nature as a European Union Regulation, ensuring strict compliance with its provisions to protect your privacy.
When you download our App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:
Name;
Username;
Email address;
Mobile number;
Gender identity;
Date, time, and place of birth;
Photographs;
Location; and
Login details, friend lists from social media accounts that you link to your Raya Culture account (e.g., your Facebook and Instagram accounts ("Social Media Accounts")). For more details on this, see "Linking Other Accounts to Raya Culture" in Section 7 below.
After registering your account, you can review and change this information at any time by simply logging in (except for your date of birth and location, as once you grant the App access to your location in your device's settings, it is automatically updated based on your device's location). It is your responsibility to ensure that your account details are kept up to date. If your mobile number changes, make sure to update it in your account.
The information we collect helps us improve the App and verify our users (to exclude bots).
Registration information such as your name and username may be visible to anyone who visits your profile page.
Profile Information
We recommend that all users carefully consider the information they disclose.
We do not recommend that you disclose email addresses, URLs, instant messaging details, mobile numbers, full names, addresses, credit card information, national identity numbers, driving license details, and other sensitive information on your profile, as it is open and could lead others to misuse the information contained within.
When you, as a user, share information about yourself or use the chat function to communicate with other users, the personal information you share with others is your sole responsibility and risk.
Please see Section 4 below for more information on who can access the information you share or post on the App.
Profile Verification Information
For security, protection, and to ensure that each user has the best possible experience, we ask users to verify their accounts using their mobile number.
Our goal is to ensure that you are not a bot and to prevent the creation of fake accounts on our App, which could be used for malicious, illegal activities and cybercrimes, threatening other users and compromising the App's functionalities.
Purchase Information
If you decide to purchase any of our premium services, we will process your payment information and keep it secure to prevent fraud and for potential audits and/or tax purposes.
Raya Culture uses automated decisions to prevent fraudulent payment transactions from being processed as part of our anti-fraud procedures. To do this, our systems review payment transactions for behaviors that indicate violations of our Terms and Conditions of Use. If a particular transaction meets certain criteria that suggest the Terms and Conditions of Use have likely been violated and the transaction is likely fraudulent, the transaction may be automatically blocked. When a transaction is blocked, the user will be notified that their transaction cannot be processed, and affected users can contact Raya Culture to dispute the decision.
Please note that if your account is blocked for any reason, any accounts you have in other Apps or sites owned by Raya Culture may also be blocked as part of our anti-spam and anti-fraud procedures.
Geolocation Information
If the user has granted the App permission to access their location, we may collect geolocation data from their device and store the coordinates of the device in order to provide certain services. This information helps us identify the events you have attended, and we may use it to personalize the App and facilitate your interaction with other users, allowing your profile to appear when a user who also attended the same event searches for users who were also present.
If the user has allowed the App to access their location but wishes to disable this option, they can do so through the following methods:
iPhone - Settings, Privacy, Location Services, Raya Culture.
Android - Settings, Location, Raya Culture, Permissions, Location.
Device Information
We may collect information about your device when you use the App, including the unique device ID, device model, and operating system, for various purposes as outlined in this policy.
Additionally, if the user grants permission, the App may access the contact list on their device, but only to add someone to their friends/contacts list on the App.
Links
We may collect information on how the user interacts with the links available in the App, including third-party services, redirected clicks, or through other means.
Raya Culture Stories, Surveys, and Other Contributions
Occasionally, we may conduct surveys for research purposes and contact you to see if you wish to participate. We may also contact you to see if you would like to participate in marketing campaigns, share positive experiences or testimonials (for example, if you inform us that you found a match on the App or formed a friend group through connections provided by the App, we may contact you to ask if you would like to appear in Raya Culture’s advertisements). These surveys and marketing campaigns are optional, and more information will be provided at the time of contact.
If you do not wish to be contacted to participate in a survey or marketing campaign, please contact our Customer Support Team at the following email address: weare@rayaculture.com.
When You Contact Customer Support
If the user contacts our Customer Support Team via email, we will receive your email address and may log your IP address as well as the information you send to help resolve your issue. We will keep records of our communications with you, including any complaints we receive about other users (as well as complaints from other users about you) for six years after deleting your account.
Cookies and Similar Technologies
When you access our websites or use the App, we may automatically collect your personal data using cookies or similar technologies. A cookie is a small file that may be placed on your device or browser, which allows us to recognize and remember you.
2. USE OF INFORMATION
Our main goal is to ensure that your experience with Raya Culture is extremely positive, enabling you to have great moments without being bothered by anyone. To achieve this, we may use your registration and other information to:
Provide you with our services and features;
Contact you with information about the App (e.g., updates and new offers);
Personalize the App and the content we offer you;
Conduct surveys and analyses on how you use and interact with the App/Site;
Test new technologies and processes designed to enhance and improve the App/Site;
Resolve conflicts, address issues, and enforce our Terms and Conditions;
Investigate fraud, protect our legal rights, and enforce our Terms and Conditions;
Send you information about promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) via direct marketing or other communication methods—if you have subscribed to receive our communications or otherwise indicated your consent. We will not use your information in direct email marketing unless you give us your consent during the account creation process or within the App settings (you may opt-out of marketing at any time in the App settings or by using the unsubscribe mechanisms and links provided in each message);
Protect our users and third parties from harm.
Connection Algorithms
To predict your compatibility with other users, we have developed certain connection algorithms, and for this reason, we may show you people who attended the same events as you and whom we believe match you.
Our connection algorithms use the following data about you to predict which users will appear on your Raya Match screen during a given event: the information in your profile, information about your activity on the App, and your device’s coordinates while attending the event, which are needed to understand your proximity to other users during the event. The legal basis for processing profile and proximity data is that it is necessary for the provision of our contractual services, according to Article 6(1)(b) of the GDPR. Whenever we process information about your activity on the App, this is based on our legitimate interests in accordance with Article 6(1)(f) of the GDPR, specifically, our legitimate interest in generating more personalized and relevant recommendations about users who attended the same event. If you have chosen to include sensitive information in your profile, such as details about your beliefs, the processing of this information is based on your voluntary and explicit consent.
Moderation Practices
We use a combination of automated systems and a team of moderators to monitor and review accounts (including photos and any other information uploaded to user profiles) and messages with content that suggests violations of our Terms and Conditions of Use. If an account or message meets certain criteria indicating that the Terms and Conditions of Use have likely been violated, the account will be subject to a warning, and the user’s access may be restricted and/or blocked. Affected members may contact Raya Culture to challenge the decision.
If the user shares any content that does not comply with our Terms and Conditions of Use, we reserve the right to delete or restrict access to their account.
Legal Basis
Under EU data protection laws, we are required to inform you about our legal basis for using your data, and we define this in the table below. Where the legal basis is consent, the user may withdraw it at any time. When the legal basis is legitimate interests, the user has the right to object to the use of their data. We explain in the relevant sections of this Policy how you can withdraw consent or cancel the use of certain data (where applicable).
Purpose for which data is used:
DataSourceLegal BasisTo provide the social networking service on Raya CultureName, email address, date of birth, location.The user provides us with their name, email address, and date of birth. We obtain location data from the device the user uses to access the service.To facilitate networking opportunities within the AppOptional information the user chooses to provide on their profile, including information about their sexual preferences, religion, ethnic background, photos, interests, etc.The user provides us with this informationTo verify identity and prevent fraud, ensuring the safety and protection of membersPhone number and, for members located in countries where age verification is required by law: government ID photo + geolocation and device information.The user provides us with this information, except for geolocation and device information, which we obtain from the device they use to access the serviceTo process payments for premium services (not applicable for users who make payments through Apple’s App Store)Payment card details.The user provides us with this informationTo send marketing information about our events, offers, and servicesName, email address, postal address, Instagram identifier, and phone number.The user provides us with this informationTo conduct surveys and research to help improve the App and test new technologies and processes designed to enhance and improve the App/SiteRegistration and usage data, including IP address, browser type, referring domain, pages accessed, telecom carrier, search terms, images and videos, registration information, profile information.The user provides us with photos and videos. We obtain the registration and usage information from the device used to access the service.To respond to correspondence and queries the user sends us, including social media inquiriesEmail address, IP address, social media name, phone number.The user provides us with their email address, social media name, and phone number when contacting us, and we obtain their IP address from the device they use to contact us.To investigate and block users for reported violations of our Terms and Conditions of UseUser's registration details, profile information, message content, and photos + usage and device data, such as IP address and session IP information.The user provides us with their registration details, profile information, messages, and photos. We obtain the other device information from the device used to access the service.To improve the user experience in the AppData on profile photos, such as whether the first profile photo was swiped or not, and whether the user liked or disliked: data on profile photos and other information shared in the profileWe obtain this information based on how users interact with the App and the profile photos of other usersTo allow users to create and enhance their profiles and log in to the App through third-party accountsFacebook and other third-party account data (see Section 7 of this Privacy Policy for more details).We obtain this information from Facebook or any other accounts the user uses to log in or connect to their Raya Culture accountTo block payment transactions as part of our anti-fraud proceduresName, IP address, email address, phone number, cardholder name, received payments, payment type, user ID, country.The user provides us with their name, email address, phone number, and card details. We obtain their IP address from the device they use to contact us. We obtain payment details from their interactions with our service.To display promotional cards and ads in the AppLocation, gender, age, and information the user optionally provides via their profile.We obtain the user’s age, gender, and profile information, and location data from the device they use to access our serviceTo display ads on third-party networks and measure the effectiveness of such adsData on user visits to our website or App and actions taken on them (e.g., if the user downloaded our App or created an account), IP address (and estimated location based on IP address), age and gender, device ID.We obtain the user’s age and gender and other information from the device or browser they use to access our serviceTo contact you to conduct surveys and gather feedback, and to ask if you want to participate in marketing campaignsEmail address and phone number.The user provides us with this informationTo enable video and audio calling features and the sending of images and videosData on video and audio call usage, images, and videos.We obtain this information from the device the user uses to access the serviceTo defend legal actions, protect legal rights, and protect people from harmThis may include any information relevant to the issue.This information may be obtained directly from you, from your device, or from third parties, depending on the information involved
3. INFORMATION DISSEMINATION
Circumstances in which your data may be disclosedData disclosed
Service Providers - We hire certain trusted third parties to perform functions and provide us with services. In order to better perform the services provided by third parties, who are also trustworthy in terms of data protection, we may need to share your registration information or personal data with those third parties, but only to the extent necessary for the purpose.This may include all categories of data.
Moderators - To monitor activity in the App and approve content.User registration name and details, profile information, message content, and photos.
Payment Processing and Telecommunications Companies - To facilitate payments made by you for the purchase of our premium services and other items.Cardholder’s name, cardholder’s address, card number, payment amount, transaction date/time.
Law and Damages - As mentioned in the Terms and Conditions of Use, we believe it is of utmost importance that all users behave appropriately while using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will cooperate with legal information requests made within or outside of your country of residence when required by law. This may include situations where there is an investigation into alleged criminal behavior or to protect the fundamental interests of a person. We may preserve or disclose any of your information, including your registration information, if we believe in good faith that it is necessary to comply with a specific law or regulation, or if we believe in good faith that disclosure is necessary:This may include any personal data that Raya Culture holds about you, depending on the nature of the request or issue we are dealing with, including all categories of data.
Business Transfer - In the event that Raya Culture undergoes a business transition or change in ownership, such as a merger, acquisition by another company, reorganization, or sale of all or part of its assets, or in the case of insolvency or administration, we may be required to disclose your personal data.This may include all personal data that Raya Culture holds about you, including all categories of data.
Advertising Partners - To serve targeted ads to users.Advertising identifier associated with your device (device ID), estimated location (based on your IP address), age, gender, and data regarding your visit to our site or App and actions taken on them (for example, if the user downloaded our App or created an account on it), hashed email address (only for “custom audiences”).
Anti-Spam and Anti-Fraud - Your data may be shared with other companies within Raya Culture, for example, to block accounts and suspicious payment transactions as part of our anti-spam and anti-fraud programs.Email address, mobile number, IP address and session IP information, social network ID, username, user-agent string, and transaction and payment data.
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but does not directly identify you) along with other information, including registration data for industry analysis and demographic profiling.
MORE INFORMATION ABOUT DISCLOSURES
Service Providers
We engage certain trusted and reputable third parties to perform functions and provide services to us ("Service Providers"). The service providers with whom Raya Culture shares your personal data vary depending on a variety of factors, such as which of our services you engage with. In order to provide our services to users, we typically use the following service providers:
Purchasing Services – to allow users to purchase paid services from our App;
Social Media Providers – to allow users to create/connect their Raya Culture account with their account(s) on such platforms (e.g., Facebook or Instagram);
Product Improvement and Market Research – we may use third-party platforms and agencies to conduct customer surveys and market research to improve our products and services.
IT Services – some of the third-party software providers used in the operation of our business may process users’ personal data (for example, if a user contacts us via social media with a support query, their query will be processed by our community management software).
We conduct due diligence on all the Service Providers we engage to ensure they have appropriate data protection and information security measures in place, and we only provide them with the personal data necessary for the service they provide. Measures are taken to ensure that the data shared is anonymized as much as possible, and our providers are also subject to extensive obligations arising from our contractual terms, including strict data retention limits.
Marketing Service Providers
We may partner with marketing service providers (such as Facebook, for example) (“Marketing Service Providers”) to help us market and advertise our App and services on third-party websites and apps and measure the effectiveness of our advertising campaigns. For example:
Exclude you from advertising campaigns aimed at finding new users if you already have an account in our App;
Show Raya Culture ads to existing users to encourage them to use the service (for example, when we launch new services for the App, we may advertise those services to existing users);
Create an audience for our ads from other potential users who have similar characteristics to yours, based on the information that Marketing Service Providers maintain about you (also known as Lookalike Audience); or
Include you in a “Custom Audience” that will receive Raya Culture advertising content (a Custom Audience is essentially a list of people we believe are most likely to be interested in a specific type of ad).
We share a limited amount of your personal data with these Marketing Service Providers, such as:
The advertising identifier associated with your device (this is a random number assigned by the manufacturer of your mobile device (e.g., Apple or Google) to your device to help advertisers (including the manufacturer) know when an ad has been viewed or clicked on in an app and when an ad leads to a ‘conversion’ (e.g., download of the advertised app for you));
Your estimated location (based on your IP address);
Age and gender;
Data about your visit to our App or website and actions taken on it (e.g., whether you downloaded our App, created an account on our App, or made any purchases in the App);
A hashed* version of your email address (to create “Custom Audiences”).
*Hashing is a form of encrypting information by turning it into a combination of random numbers and letters – this code cannot be traced back to the email address. When hashed email addresses are sent to a marketing service provider, they are compared with the provider’s existing list of hashed user data, and our ads are shown to our users who successfully match those of the provider. Matching and non-matching hashes are excluded by the provider.
In some cases, these third parties may also use the data they collect for their own purposes, such as aggregating your data with other data they have and using it to inform advertising-related services provided to other clients.
Facebook
When we share data with Facebook as our marketing service provider (including through the “Like” feature) on Facebook, we are Joint Data Controllers with Facebook Ireland for that processing. This arrangement means that Raya Culture must provide this notice, but you should contact Facebook if you wish to exercise your data protection rights. More information, including how Facebook allows you to exercise your data protection rights and subsequently processes your information as an independent data controller, can be found in Facebook Ireland’s Data Policy.
The data mentioned above may include actions you take on our website, such as your interactions with our site or other information collected from cookies or similar technologies, including the Facebook pixel. This allows us to measure the effectiveness of our advertising, improve our marketing practices, and help us provide more relevant advertising to you and similar people (including on social networks such as Facebook).
4. WHAT OTHERS CAN KNOW ABOUT YOU
Our App is designed to make it easier to connect and interact with other users who have attended the same events as you.
By using the Raya Culture App, you acknowledge that anything you post or send on the App is visible and accessible publicly, both by App users and non-users. We want users to be careful and cautious when sharing and posting information that may become public.
Be cautious when sharing sensitive details about yourself in your profile, such as your religious orientation or health details.
Although you may voluntarily provide this information to help create your profile, including your sexual preferences, there is no requirement to do so. Remember that the photos you share on the Raya Culture App may reveal information about you. When you share a photo and choose to provide us with sensitive information, you explicitly consent to our processing of that information and its public display to other users.
Your profile, as well as other information you provide through the App, including certain information added to your profile through third-party accounts (such as Facebook or Instagram – see section 7 of this Privacy Policy for more information on this matter), may be viewed and shared by users with individuals who may or may not be users of the App. For example, a user might recommend you to connect with their Facebook friend(s) by taking a screenshot of your profile picture and sharing it, regardless of whether that/those friend(s) are users of the App.
Please also note that in certain countries (currently, only South Korea), users are provided with a feature that allows them to download a copy of their chat history (as required by local laws), and Raya Culture has no control over how users may then publish or use that information.
If you log in or access the App through your Facebook account or a third-party device that you share with others, you should log out of the App and your account when you leave the device, to prevent other users from accessing your Raya Culture account.
5. OUR POLICY ON AGE
You must be at least 18 years old to use the Raya Culture App.
Raya Culture does not intentionally collect any information about children, minors, or anyone under the age of 18. If we become aware that a child, minor, or anyone under the age of 18 has registered on our App and provided us with personal information, we will take steps to terminate that person’s registration.
6. SECURITY
At Raya Culture, we take certain and specific security measures to help protect information from loss, misuse, and unauthorized access or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information, such as secure servers protected by firewalls.
Unfortunately, no website or transmission over the Internet is 100% secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. However, here are some useful tips to help keep your data secure:
Please ensure you log out of your account after use, as you never know who might end up accessing your account.
Do not share the password you use to access your account with anyone.
Change your password periodically.
We cannot guarantee the security of your personal data while it is transmitted to our App, and any data transmission is done at your own risk.
7. LINKING OTHER ACCOUNTS TO RAYA CULTURE
Using your data from other social networks to log into Raya Culture
By logging into our App using your Facebook account, you grant Facebook permission to share your name and profile picture with us. Unless you disable this, you also give permission for Facebook to share your email address (if any is associated with your Facebook account), date of birth, profile photos, gender, page likes, and current city.
By logging into our App using your Instagram account, you grant Instagram permission to share your name and profile picture with us. Unless you disable this, you also give permission for Instagram to share your email address (if any is associated with your Instagram account), date of birth, profile photos, gender, page likes, and current city.
We will then use this personal data to register your account in the Raya Culture App. To stop having access to this data, you must delete your account from the Raya Culture App.
Linking Social Media Accounts to Your Raya Culture Account
You can link your Raya Culture account to your Instagram or Facebook accounts. This allows you to share some information from those accounts directly on your Raya Culture account (e.g., Instagram photos).
We only receive the limited information that Instagram or Facebook allows to be transferred (as detailed by Instagram/Facebook and agreed upon by you when you first link your account from such platforms to your Raya Culture account).
If you no longer wish to link your Raya Culture account to your Instagram or Facebook account, visit the settings of your Instagram or Facebook account and follow the instructions to remove Raya Culture’s access permissions. Any information already added to your Raya Culture account from these platforms will not be deleted unless you also delete it from your Raya Culture account.
8. YOUR RIGHTS
In addition to jurisdictions where the GDPR may apply, the privacy laws in your country may grant you the following rights:
Right to be informed: the right to know what personal data an organization is processing and why (we provide this information to you in this Privacy Policy);
Right of access: you can request a copy of your data;
Right to rectification: if the data we hold is inaccurate, you have the right to correct it;
Right to erasure: you have the right to delete your data in certain circumstances;
Right to restrict processing: in limited circumstances, you have the right to request that processing be halted, while the data is retained;
Right to data portability: you can request a copy of certain data in a machine-readable format that can be transferred to another provider;
Right to object: in certain circumstances (including when data is processed based on legitimate interests or for marketing purposes), you can object to such processing;
Rights related to automated decision-making, including profiling: there are several rights in this area when processing based solely on automation results in a decision that has legal or significant effects for the individual. In these circumstances, your rights include the right to ensure there is human intervention in the decision-making process.
The specific rights applicable to you (which may include other rights not listed above) may vary depending on your country. You should be aware of the rights you have under the applicable privacy laws in your country.
If you wish to exercise any of the rights mentioned above, please email us at weare@rayaculture.com. You may also contact us by post at the following address: Avenida General Roçadas, 66, 4º Esquerdo, 1170-164 Lisboa, Portugal. For your protection and the protection of all our users, we may need to ask for specific information about you to help confirm your identity before we can respond to the requests above.
If you have any questions about how we process your request or your personal data, please contact us first using the contact details provided above.
If you feel we have not addressed your concern, you have the right to file a complaint at any time with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
If you reside in a country or territory located within the European Union (EU) or the European Economic Area (EEA), you can contact the Data Protection Regulator.
If you reside in a country outside the EU, you may have the right to file a complaint with your local privacy or data protection regulatory authority.
9. DATA LOCATIONS
We want you to be able to access Raya Culture anywhere in the world. To allow us to provide this service, we operate a global network of servers, including in the USA, the UK, Hong Kong, Europe, and Russia (for members located in Russia). The hardware is located in third-party data centers but is owned by Raya Culture. Data collected by advertising partners may also be processed outside the European Economic Area. We ensure that the data is properly protected by implementing valid legal mechanisms, such as EU-approved Standard Contractual Clauses, and robust contractual standards.
10. DATA RETENTION AND DELETION
We retain your personal information only for as long as necessary for the legal basis on which it is based (as established in Section 2 above) and as permitted by applicable law. Please refer to "Profile Verification Information" in Section 1 above.
When your account is deleted, we ensure that it can no longer be viewed in the App. Up to 28 days after deleting your account, it is still possible to restore it if it was deleted by mistake. After 28 days, we begin the process of deleting your personal information from our systems, unless:
We continue to retain it in accordance with applicable law (e.g., if you make purchases within the App, some personal data may be retained for tax purposes);
We continue to retain it to demonstrate our compliance with applicable law (e.g., if an account is blocked, we retain some account information and a record of the behavior that led to the blocking—this information is retained for proof in case of any doubts or legal actions related to the blocking);
There is an outstanding issue, claim, or dispute requiring us to retain relevant information until it is resolved; or
The information needs to be kept for our legitimate security interests, such as fraud prevention and improving security and user protection (e.g., it may be necessary to retain information to prevent a user who was banned due to unsafe behavior or security incidents from creating a new account).
Notice: Even after removing information from your profile or deleting your account, copies of information may still be visible and/or accessible to the extent that they have been previously shared with others, copied, or stored by other users, or to the extent that such information has been shared with search engines. We cannot control these occurrences, nor do we accept any responsibility for them. If you have given access to third-party applications or websites, they may retain your personal information to the extent allowed, according to the terms of their service or privacy policies.
Thank you for reading this Privacy Policy.
11. CHANGES TO THIS PRIVACY POLICY
As Raya Culture evolves, it may become necessary to review this Privacy Policy. The most current version of the policy governs the use of your information and can always be accessed via this link. If we make a change to this policy that, in our sole discretion, is significant, we will notify you, for example, via an email to the address associated with your account or by posting a notice within the App itself.
Effective Date
This Privacy Policy was updated and is effective as of June 21, 2024.