Privacy Policy
Introduction
This Privacy Notice for Ark Innovations, LLC ("we," "us," or "our") describes how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
- download and use our mobile application, Ray, or any other application of ours that links to this Privacy Notice;
- engage with us in other related ways, including support, service communications, or subscription and entitlement questions; or
- otherwise interact with us in connection with the Services.
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at mail@arkinnovations.co.
Summary of Key Points
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using the table of contents below.
- What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the features you use.
- Do we process any sensitive personal information? We do not process sensitive personal information.
- Do we collect any information from third parties? We do not buy personal information from data brokers or similar third-party data sellers.
- How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, provide reminders and UV-related guidance, support subscriptions, prevent fraud, and comply with law.
- In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
- How do we keep your information safe? We use reasonable technical and organizational measures, but no electronic transmission or storage can be guaranteed to be 100% secure.
- What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
- How do you exercise your rights? The easiest way to exercise your rights is by visiting https://www.arkinnovations.co/support, or by contacting us at mail@arkinnovations.co.
Table of Contents
- What Information Do We Collect?
- How Do We Process Your Information?
- What Legal Bases Do We Rely On to Process Your Personal Information?
- When and With Whom Do We Share Your Personal Information?
- Do We Offer Artificial Intelligence-Based Products?
- How Long Do We Keep Your Information?
- How Do We Keep Your Information Safe?
- Do We Collect Information From Minors?
- What Are Your Privacy Rights?
- Controls for Do-Not-Track Features
- Do United States Residents Have Specific Privacy Rights?
- Do Other Regions Have Specific Privacy Rights?
- AI Processing Transparency
- Do We Make Updates to This Notice?
- How Can You Contact Us About This Notice?
- How Can You Review, Update, or Delete the Data We Collect From You?
1. What Information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you use Ray, when you contact us for support, or otherwise when you interact with us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the features you use. The personal information we collect may include the following:
- onboarding information and profile preferences, such as reminder timing, sunscreen routine preferences, and related setup choices;
- sunscreen logs, coverage records, snooze selections, and similar in-app tracking information you choose to record;
- support communications, contact information, and any information you include in emails or support requests;
- subscription, entitlement, and purchase-restoration status; and
- other information you choose to submit to us in connection with the Services.
Sensitive Information. We do not process sensitive personal information.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases, but payment processing for in-app purchases is handled and stored by Apple. You may find Apple's privacy notice here: https://www.apple.com/legal/privacy/.
Application Data. If you use our application, we also may collect the following information if you choose to provide us with access or permission:
- Location Data. We may request access to your location in order to fetch current UV conditions, personalize live UV guidance, and improve reminder timing throughout the day.
- Notification and Reminder Data. We may store your reminder settings, notification preferences, and related scheduling information so the app can send sunscreen reminders.
- Mobile Device Data. We may automatically collect device information such as device type, model, operating system, version information, app version, system configuration information, identifiers needed for app operation, crash diagnostics, and information about the features of the application you access.
- Cloud and App Storage Data. If you use cloud-backed app features, we may store app records, logs, settings, and subscription state in Apple-hosted services such as CloudKit and related platform infrastructure we use to operate the Services.
This information is primarily needed to maintain the security and operation of our application, for troubleshooting, and for internal diagnostics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information, such as your Internet Protocol (IP) address and device characteristics, is collected automatically when you use our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity, but may include device and usage information, such as your IP address, browser or device characteristics, operating system, language preferences, device name, country, approximate location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services and for internal diagnostics and reporting purposes.
The information we collect may include:
- Log and Usage Data. Service-related, diagnostic, usage, and performance information, such as date and time stamps, app events, searched or viewed screens, feature usage, system activity, error reports, and hardware settings.
- Device Data. Information about the phone, tablet, or other device you use to access the Services, including device and application identifiers, operating system, network information, hardware model, and similar configuration data.
- Geolocation Data. If you grant location access, we may collect and process device location in order to provide UV-related features.
2. How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, support reminders and UV guidance, prevent fraud, and comply with law.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- to deliver and facilitate delivery of services to the user;
- to personalize UV guidance, reminder timing, and sunscreen routine guidance within the app;
- to respond to user inquiries and offer support;
- to send administrative information to you, such as service updates and policy or terms changes;
- to process and restore premium purchases, subscriptions, and entitlements;
- to save or protect an individual's vital interest when necessary to prevent harm; and
- to maintain security, prevent misuse, and improve the Services.
3. What Legal Bases Do We Rely On to Process Your Personal Information?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases:
- Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a Contract. We may process your personal information when necessary to fulfill our contractual obligations to you, including providing our Services.
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.
- Legitimate Interests. Where permitted, we may process your information for legitimate interests in operating, securing, maintaining, and improving the Services.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. In some exceptional cases, we may also be legally permitted under applicable law to process your information without your consent.
4. When and With Whom Do We Share Your Personal Information?
In Short: We may share information in specific situations described in this section and with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts or platform arrangements in place designed to help safeguard your personal information.
The categories of third parties we may share personal information with include:
- Apple platform and infrastructure providers, including App Store, StoreKit, CloudKit, and WeatherKit-related services; and
- subscription, paywall, or purchase-restoration providers used to operate the Services if enabled in production.
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with a merger, sale of company assets, financing, or acquisition of all or a portion of our business.
- Legal Compliance and Safety. We may disclose information where reasonably necessary to comply with law, enforce our policies, or protect rights, property, and safety.
5. Do We Offer Artificial Intelligence-Based Products?
In Short: Ray does not currently offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies as part of the shipped sunscreen guidance experience.
If Ray later includes AI-powered products, features, or tools, we may update this Privacy Notice to explain how those features work and how personal information is processed in connection with them.
6. How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will keep your personal information for only as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law, such as for tax, accounting, legal compliance, or dispute-resolution requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if that is not possible, we will securely store it and isolate it from further processing until deletion is possible.
7. How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security.
8. Do We Collect Information From Minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at mail@arkinnovations.co.
9. What Are Your Privacy Rights?
In Short: Depending on your state of residence in the US or in some regions, such as the EEA, UK, Switzerland, and Canada, you may have rights that allow you greater access to and control over your personal information.
In some regions, you may have certain rights under applicable data protection laws. These may include the right to request access to and obtain a copy of your personal information, request rectification or erasure, restrict the processing of your personal information, request data portability, and, in certain circumstances, object to the processing of your personal information.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of the processing before its withdrawal.
If you have questions or comments about your privacy rights, you may email us at mail@arkinnovations.co.
10. Controls for Do-Not-Track Features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
11. Do United States Residents Have Specific Privacy Rights?
In Short: If you are a resident of certain US states, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information where applicable.
Categories of personal information we may collect
Depending on how you use Ray, we may collect categories of personal information such as:
- identifiers, such as email address or support contact information you provide;
- commercial information, such as subscription or purchase status;
- geolocation data, if you grant location permission;
- internet or network activity and device diagnostics related to app operation;
- user-provided content such as sunscreen logs, routine preferences, support messages, and similar in-app records; and
- inferences or preferences derived from your use of the Services to support reminder timing and product functionality.
We may also collect other personal information through customer support channels, service troubleshooting, and the delivery of our Services.
How we use and share personal information
We may disclose your personal information with service providers pursuant to written contracts or platform terms. Learn more in "When and With Whom Do We Share Your Personal Information?"
We do not sell personal information for money. We also do not knowingly share personal information for cross-context behavioral advertising in a manner that would be inconsistent with this notice.
Your rights
You may have rights under certain US state data protection laws, including:
- the right to know whether or not we are processing your personal data;
- the right to access your personal data;
- the right to correct inaccuracies in your personal data;
- the right to request deletion of your personal data;
- the right to obtain a copy of the personal data you previously shared with us;
- the right to non-discrimination for exercising your rights; and
- where applicable, the right to opt out of certain targeted advertising, sales, or profiling activities.
How to exercise your rights
To exercise these rights, you can contact us by visiting https://www.arkinnovations.co/support, by emailing us at mail@arkinnovations.co, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Request verification
Upon receiving your request, we may need to verify your identity to determine you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at mail@arkinnovations.co. We will inform you in writing of any action taken or not taken in response to the appeal. If your appeal is denied, you may submit a complaint to your state attorney general.
California "Shine The Light" law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information, if any, disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing by using the contact details provided in the section "How Can You Contact Us About This Notice?"
12. Do Other Regions Have Specific Privacy Rights?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020.
This Privacy Notice satisfies the notice requirements defined in those laws, including what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill an applicable purpose, it may affect our ability to provide our Services, including the ability to offer features you request or respond to your support requests.
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us through the details provided in the section "How Can You Review, Update, or Delete the Data We Collect From You?"
If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of the Privacy Commissioner of New Zealand.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint regarding our processing of personal information, you can contact the office of the regulator:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za
13. AI Processing Transparency
Ray does not currently process uploaded images, text prompts, or other user content through a third-party AI provider as part of the shipped sunscreen guidance experience.
If Ray later introduces AI-powered features, we may update this notice to describe what data is processed, which providers are involved, and what safeguards apply.
14. Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you by prominently posting a notice of such changes or by directly sending you a notification.
15. How Can You Contact Us About This Notice?
If you have questions or comments about this notice, you may email us at mail@arkinnovations.co or contact us by post at:
Ark Innovations, LLC
131 Continental Dr
Suite 305
Newark, DE 19713
United States
16. How Can You Review, Update, or Delete the Data We Collect From You?
Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw consent to our processing of your personal information in some circumstances. To request to review, update, or delete your personal information, please visit https://www.arkinnovations.co/support or contact mail@arkinnovations.co.