Privacy Policy

This Privacy Policy applies to members and users of Relay, the Relay companion app (the “Companion App”), the relaypro.com webpages, and the Relay services (“Services”).

We make the security and confidentiality of the personal information that you provide to us a priority. Please read our Privacy Policy carefully.

We may update this Privacy Policy in the future. We will notify our members about material changes to this Privacy Policy by either sending a notice to the email address you provide to us or by placing a prominent notice on our Web sites.

What Information Do We Collect from You?

Contact Information that allows us to communicate with you. We get this information when you order or register for the Services. This would include information like your name, address, and e-mail address.

Billing Information related to your financial relationship with us, such as the services we provide to you, your payment history, your credit history, your credit card numbers (which is provided to our third party credit card processing vendors), and your service history.

Technical & Usage Information related to the Services we provide to you, including information about how you use our network, Services, and the Relay product. Some examples include:

  • Equipment Information that identifies the equipment on our networks, such as equipment type, device identifiers, device status, serial numbers, settings, configuration and software.
  • Network Performance & Usage Information about the operation of the equipment, services and applications you use on our networks. Examples of this might include the number of messages sent and received and the length of each message, minutes used or spent on various channels, bandwidth used, and whether the devices and services were used on Wi-Fi or a cellular network. We also collect information like transmission rates and delays, data associated with remote monitoring services and security characteristics.

When you contact us, we may monitor or record the communication or keep a record of it to help us train employees and provide customer service.

How Do We Collect Information From You?

You Give It To Us when you make a purchase or set up an account with us; or when you use the Services (for example when you send a voice message using a Relay device);

You Use a Service or Make a Choice in the Companion App to provide it: As examples: (1) You decide to send a voice message using a Relay device or the Companion App. In this situation, we convert your voice message into data packets that travel over a WiFI or cellular connection (or a combination of both), to our servers, which then sends the voice data packets back out to the other Relay devices the communication was intended for. We retain a recording of your message for a limited time. You can listen to the recording of your message on the Relay device(s) or in your account in the Companion App. Once we delete your message from our systems, you will no longer able to replay the message. (2) You chose to enable location tracking, through the Companion App, for a particular Relay device. (3) You decide to use a voice command, for example, to change a Channel or listen to a recorded message on a Relay. Your voice command is sent to the Google Cloud Platform, which recognizes speech, converts it to text, and provides that information back to our servers so we can execute your command. We have no control over what Google does with any information that you pass to Google using the voice command feature. The Google Cloud Platform terms can be found here: https://cloud.google.com/terms/. Google may update this information from time to time and may also change the link(s) associated with this information. (4) You chose to enable other features as they become available. We will describe to you the information we collect and you can decide whether to enable the feature. When the feature is provided by a third-party, we will provide you with the information made available by the third-party so that you can decide whether to enable the feature.

We Automatically Collect Information when you use our networks, products and services. For example, we use network tools to collect network statistics; we use web server logs and other technologies. We may automatically measure and monitor network performance and the performance of users’ Internet connections to improve our overall service levels. We may anonymize and then use this anonymized usage information and other anonymized information for certain internal business, product, and sales purposes. We may use this information and other demographic and interest information obtained by us from other sources to prepare aggregated business and marketing reports that we may use ourselves or share with others for their use, but which do not personally identify you. We also may access information about your Relay device, Companion App or device settings to provide customized support or to install or suggest specific features or services that you use or are necessary for your use of certain services we provide to you.

We Obtain Information from Outside Sources like mailing lists, reports that help us detect fraudulent purchases, and commercially available geographic and demographic information along with other publicly available information, such as public posts to social networking sites in order to understand our Relay customer base better and improve the services and support that we offer our Relay customers. We also will not share this information with any third parties for any marketing purposes

How Do We Use Your Information?

We may use the information we collect about you for a variety of purposes, including:

  • The registration and management of your account, including for billing purposes, the delivery and maintenance of products or services, assistance with service-related issues or questions, and the facilitation of your access to and use of our Web sites;
  • Communication with you, including to provide information about Relay and invitations from Relay;
  • Responses to your questions and comments, or other customer service;
  • Business and usage analytics, such as measurement of your interest in our products, services, and Web sites, as well as the improvement, management and protection of our network, products, services, and Web sites;
  • Improving our services;
  • Notifications and provision of information about special offers and products or services available from us that may interest you;
  • Customization of your experience with Relay and the Services;
  • Solicitation of information from you, including through surveys, or administering contests or promotions;
  • Resolution of disputes and troubleshooting of other problems;
  • Prevention of potentially prohibited or illegal activities, or harm to any person or property;
  • Assisting law enforcement, pursuing or defending legal claims, and engaging in other compliance or legal activities;
  • Enforcement of our agreements with you, including our Terms of Service and our Relay Acceptable Use Policy; and
  • As otherwise described to you at the point of collection.

How Do We Use Any Feedback You May Provide?

Any data that you send to us such as your questions, suggestions, ideas or other creative material belongs to us and we will not treat it as confidential. We may adapt, disclose, display, distribute, reproduce, use, or create derivative works from any such information without acknowledgment of you or compensation to you.

How Do We Share Your Information?

Relay may share your information with others:

  • Within our family of companies (and their divisions) for operational purposes.
  • We may use third party vendors to provide various services or functions on our behalf, including business analytics, customer service, marketing, distribution of surveys, and fraud prevention. We use a third-party intermediary to manage certain payment card processing. This intermediary is not permitted to store, retain, or use billing information, including your billing name and address and credit card number, except for the sole purpose of credit card processing on our behalf.
  • In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. We reserve the right to raise or waive any legal objection or right available to us in any such cases.
  • When we believe it is necessary to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Relay, our Relay community members, or others; and in connection with our Terms of Service and other agreements, subject to applicable law.
  • In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Except as described above, we will notify you when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information. We also may share aggregate or anonymous information with third parties.

How You Can Update and Revise Your Information?

We take reasonable steps to ensure that your information is relevant, accurate, and complete. Your use of the Services or the Companion App or your account may permit you to update or revise your personal information through the Companion App, our websites or otherwise from time to time. You also may contact us if you believe your information needs to be updated or revised.

What Choices Do You Have Regarding the Collection and Use of Your Information?

  • We want to make it easy for you to have choices regarding the information we do not automatically collect. For example, we have designed our Companion App to give the Account Owner control over many of the features available on each Relay device. Depending on the plan you select, many features will be defaulted to opt-out and you will have to opt-in through the Companion App to enable these features. Examples of this include turning on the SOS feature for each Relay device and enabling third-party services that will become available from time-to-time through the Services on the Relay device. You can choose not to turn these functions “on”.
  • You can enable and disable features through the Companion App.
  • You also can revise or update information as described above.
  • You also may unsubscribe from any promotional messages in any email we send. We reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating to your account, without offering you the opportunity to opt out of receiving them.

How Do We Protect Your Information?

While no company or device can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. For example, we permit only authorized personnel to access personal information, and they only may do so for permitted business functions. We also employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information that we maintain. These measures include administrative safeguards, such as policies, procedures, and training, as well as physical and technical controls, such as encryption of your login credentials for your account and where appropriate, for other transmissions. However, we make no guarantee, representation or warranty that use of our services or Web sites is protected from all security threats, viruses, or other vulnerabilities or that your information always will be secure.

How Do We Protect Children’s Privacy?

The Web sites operated by Relay are general audience sites and do not offer services directed to children. The Relay device is also a general use product, but we believe it is likely that parents may buy Relay devices both for themselves and for their children. If you have purchased a Relay device for a child, please read our Children’s Privacy Policy, which sets forth what personal information we collect, what we use that information for and what choices you as a parent have. You can find our Children’s Privacy Policy here: relaypro.com/legal/relay-childrens-privacy-policy/

Does Our Privacy Policy Apply to External Links or Other Parties?

If any part of our Web sites links you to other Web sites, those external Web sites do not operate under this Privacy Policy. Similarly, if you choose to use services of another company about which we provided information, or due to your interaction with other content we provided, that party’s use of your information is not governed by this Privacy Policy. We recommend that you examine the privacy statements posted on those other Web sites to understand their procedures for collecting, using, and disclosing personal information.

How Does Our Privacy Policy Apply If You Visit Our Web Sites from

Outside the United States?

Your information will be transferred to, stored, and processed in the United States or other countries where our servers are located and where we operate. The data protection laws of the United States and other countries may vary from those applicable in your country. However, Relay will treat your information in compliance with law and as described in this policy regardless of the location from which it was collected. By using our Web site or services, you understand that your information may be transferred to us and to third parties with whom we share it as described in this Privacy Policy.

Do You Have Additional Rights Under California Law?

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email legal@relaypro.com.

Additional Privacy Policy Terms that Apply To The Relay Web sites

We collect information about your computer when you visit our Web sites. For example, we collect session data, including your IP address, Web browser software, and referring Web site. We also may collect information about your online activity, such as content viewed and pages visited. This information also may permit us to identify users associated with multiple devices used to access our sites or services.

Cookies are small data text files that, if you accept and your Web browser permits, can be stored on your computer’s hard drive. Relay and its Web sites use cookies:

  • To help us recognize your Web browser as a previous visitor and save and remember any preferences set while your Web browser visited our Web sites. For example, if you register on our Web sites, we may use cookies to remember your registration information so you do not need to log into our Web sites each time you visit. We also may save your password in a cookie, if you checked the box entitled “Save this password for automatic sign-in” (or other similar words).
  • To help us customize the content, Web site experience, and advertisements provided to you on our Web sites and on other Web sites across the Internet. For example, when you access a web page, a cookie automatically recognizes your Web browser as you navigate on the Internet and presents you with information and advertising based on your apparent interests.
  • To help measure and research the effectiveness of the features, offerings, advertisements, and email communications (by determining which emails you open and act upon) of our Web sites.

Our Web sites also may use Web beacons (also known as clear gifs, pixel tags or Web bugs). These Web beacons are tiny graphics with a unique identifier, similar in function to cookies, that we place in the code of a Web page. Web beacons allow us to monitor the traffic patterns of users from one page within our Web sites to another, deliver or communicate with cookies, understand whether you have come to our Web sites from an online advertisement displayed on a third-party Web site, and improve the performance of our Web sites. We also may allow our service providers to use Web beacons to help us understand which emails recipients have opened and track the visitor traffic on our Web sites.

We may use these technologies to serve interest-based ads. If you accept cookies, we also allow third parties to collect information about your online activities through cookies and other technologies, and they may do so over time and across different websites. These third parties include advertising networks and our business partners, who collect information when you view or interact our site or services, our ads, or ads you see on our sites or services. We do not have access to or control cookies or other technologies these third parties may use to collect information about your interests; our Privacy Policy does not cover either these third parties or their information practices.

We may use your information to help identify you as a user when you access our Web sites using different devices. If you use different devices (such as your home computer, laptop, and/or mobile device) to access our Web sites and/or engage in a transaction, we may be able to associate you with each of your devices. For example, if you choose to click the email link on a new device, we may be able to associate your current device with your account information. We may combine information we have collected from your use of different devices and use that information consistent with this Policy, such as to help provide a more personalized and consistent experience across your devices, and to deliver more relevant advertisements to you.

We may also authorize third-party vendors to collect information on our behalf to operate features of our Web sites or facilitate the delivery of online advertising tailored to your interests, among other reasons. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.

What Choices Do You Have About Cookies

  • The Help portion of the toolbar on most browsers will tell you how to prevent your Web browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. At this time our Web sites do not respond to “do not track” signals.
  • Certain ad networks have agreed to adhere to industry-supported consumer choice mechanisms, such as the Network Advertising Initiative’s opt-out for interest-based advertising, which can be found here: optout.networkadvertising.org.
  • The Digital Advertising Alliance also maintains a similar opt-out that may permit you to opt out of the use of your information to identify your devices across multiple websites. It can be found here: optout.aboutads.info.

How Can You Contact Us?

If you have questions about this Privacy Policy, please contact us at:

Mail:

Relay, Inc. Attention: Customer Care 4200 Six Forks Road, Suite 1800, Raleigh, NC 27609

Tel: 919-230-4307

Email:

legal@relaypro.com

© 2024 Relay, Inc.

Effective: January 1, 2022

Last Reviewed: January 23, 2024

 

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the Relay Privacy Policy and applies to members and users of Relay, the Relay companion app (the “Companion App”), the relaypro.com webpages, and the Relay services (“Services”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being Associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months.”YES” means we have collected information within the Category but does not mean we have collected all types of examples for each category.

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Information You Provide. We collect information that you provide to us when you apply for, purchase, or use our products or services, or otherwise communicate with us. For example:
    • Contact Information that allows us to communicate with you. We get this information when you order or register for the Services. This would include information like your name, address, and e-mail address.
    • Billing Information related to your financial relationship with us, such as the services we provide to you, your payment history, your credit history, your credit card numbers (which is provided to our third party credit card processing vendors), and your service history.
    • When you contact us, we may monitor or record the communication or keep a record of it to help us train employees and provide customer service.
    • When you name your Relay device, we retain the custom names you provide to identify relay devices from the companion app
    • When you activate your Relay device, we keep a record of how your Relay device will be used (parent, child, business, other).
    • When geofencing is enabled, we retain location, name and radius data in order to provide notifications to companion app users.
  • Information We Collect Indirectly. We collect information about your computer when you visit our Web sites. For example, we collect session data, including your IP address, Web browser software, and referring Web site. We also may collect information about your online activity, such as content viewed and pages visited. This information also may permit us to identify users associated with multiple devices used to access our sites or services.
    • Cookies are small data text files that, if you accept and your Web browser permits, can be stored on your computer’s hard drive. Relay and its Web sites use cookies:
      • To help us recognize your Web browser as a previous visitor and save and remember any preferences set while your Web browser visited our Web sites. For example, if you register on our Web sites, we may use cookies to remember your registration information so you do not need to log into our Web sites each time you visit. We also may save your password in a cookie, if you checked the box entitled “Save this password for automatic sign-in” (or other similar words).
      • To help us customize the content, Web site experience, and advertisements provided to you on our Web sites and on other Web sites across the Internet. For example, when you access a web page, a cookie automatically recognizes your Web browser as you navigate on the Internet and presents you with information and advertising based on your apparent interests.
      • To help measure and research the effectiveness of the features, offerings, advertisements, and email communications (by determining which emails you open and act upon) of our Web sites.
    • Our Web sites also may use Web beacons (also known as clear gifs, pixel tags or Web bugs). These Web beacons are tiny graphics with a unique identifier, similar in function to cookies, that we place in the code of a Web page. Web beacons allow us to monitor the traffic patterns of users from one page within our Web sites to another, deliver or communicate with cookies, understand whether you have come to our Web sites from an online advertisement displayed on a third-party Web site, and improve the performance of our Web sites. We also may allow our service providers to use Web beacons to help us understand which emails recipients have opened and track the visitor traffic on our Web sites.
    • We may use these technologies to serve interest-based ads. If you accept cookies, we also allow third parties to collect information about your online activities through cookies and other technologies, and they may do so over time and across different websites. These third parties include advertising networks and our business partners, who collect information when you view or interact our site or services, our ads, or ads you see on our sites or services. We do not have access to or control cookies or other technologies these third parties may use to collect information about your interests; our Privacy Policy does not cover either these third parties or their information practices.
    • We may use your information to help identify you as a user when you access our Web sites using different devices. If you use different devices (such as your home computer, laptop, and/or mobile device) to access our Web sites and/or engage in a transaction, we may be able to associate you with each of your devices. For example, if you choose to click on the email link on a new device, we may be able to associate your current device with your account information. We may combine information we have collected from your use of different devices and use that information consistent with this Policy, such as to help provide a more personalized and consistent experience across your devices, and to deliver more relevant advertisements to you.
    • We may also authorize third-party vendors to collect information on our behalf to operate features of our Web sites or facilitate the delivery of online advertising tailored to your interests, among other reasons. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
  • Information We Collect Automatically.
    • Technical & Usage Information related to the Services we provide to you, including information about how you use our network, Services, and the Relay product. Some examples include:
      • Equipment Information that identifies the equipment on our networks, such as equipment type, device identifiers, device status, serial numbers, settings, configuration and software.
      • Network Performance & Usage Information about the operation of the equipment, services and applications you use on our networks. Examples of this might include the number of messages sent and received and the length of each message, minutes used or spent on various channels, bandwidth used, and whether the devices and services were used on Wi-Fi or a cellular network. We also collect information like transmission rates and delays, data associated with remote monitoring services and security characteristics.
    • Using a Service or Make a Choice in the Companion App to provide it: As examples: (1) You decide to send a voice message using a Relay device or the Companion App. In this situation, we convert your voice message into data packets that travel over a WiFI or cellular connection (or a combination of both), to our servers, which then sends the voice data packets back out to the other Relay devices the communication was intended for. We retain a recording of your message and you can listen to the recording of your message on the Relay device(s) or in your account in the Companion App. Once we delete your message from our systems, you will no longer able to replay the message. (2) You chose to enable location tracking, through the Companion App, for a particular Relay device (3) You decide to use a voice command, for example, to change a Channel or listen to a recorded message on a Relay. Your voice command is sent to the Google Cloud Platform, which recognizes speech, converts it to text, and provides that information back to our servers so we can execute your command. We have no control over what Google does with any information that you pass to Google using the voice command feature. The Google Cloud Platform terms can be found here: https://cloud.google.com/terms/. Google may update this information from time to time and may also change the link(s) associated with this information. (4) You chose to enable other features as they become available.. When the feature is provided by a third-party, we will provide you with the information made available by the third-party so that you can decide whether to enable the feature.
    • When you use our networks, products and services. For example, we use network tools to collect network statistics; we use web server logs and other technologies. We may automatically measure and monitor network performance and the performance of users’ Internet connections to improve our overall service levels. We may anonymize and then use this anonymized usage information and other anonymized information for certain internal business, product, and sales purposes. We may use this information and other demographic and interest information obtained by us from other sources to prepare aggregated business and marketing reports that we may use ourselves or share with others for their use, but which do not personally identify you. We also may access information about your Relay device, Companion App or device settings to provide customized support or to install or suggest specific features or services that you use or are necessary for your use of certain services we provide to you.
  • Information From Other Sources. We may also obtain information about you from third parties, affiliated entities and business partners. For example, social media services and information obtained from consumer reporting agencies

Use of Personal Information

We may use the information we collect about you for a variety of purposes, including:

  • The registration and management of your account, including for billing purposes, the delivery and maintenance of products or services, assistance with service-related issues or questions, and the facilitation of your access to and use of our Web sites;
  • Communication with you, including to provide information about Relay, and invitations from Relay;
  • Responses to your questions and comments, or other customer service;
  • Business and usage analytics, such as measurement of your interest in our products, services, and Web sites, as well as the improvement, management and protection of our network, products, services, and Web sites;
  • Improving our services;
  • Notifications and provision of information about special offers and products or services available from us that may interest you;
  • Customization of your experience with Relay and the Services;
  • Solicitation of information from you, including through surveys, or administering contests or promotions;
  • Resolution of disputes and troubleshooting of other problems;
  • Prevention of potentially prohibited or illegal activities, or harm to any person or property;
  • In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  • Assisting law enforcement, pursuing or defending legal claims, and engaging in other compliance or legal activities;
  • Enforcement of our agreements with you, including our Terms of Service and our Relay Acceptable Use Policy; and as otherwise described to you at the point of collection.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sensitive Information

Subject to the features enabled and your contractual agreement we may collect, process, or disclose certain personal information that qualifies as “sensitive data” under applicable U.S. state data privacy laws. Sensitive data is a subset of personal information. In the list below, we outline the categories of sensitive data we collect, the sources of the sensitive data and our purposes of processing. 

Retention of Personal Information

Relay, Inc. will retain your personal information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

Sharing Personal Information

Relay Inc may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales and Opt-In Rights]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase personal information we hold from reselling it unless you have explicit notice and an opportunity to opt-out of further sales.]

We share your personal information with the following categories of third parties:

  • Service providers
  • Data aggregators
  • Social media services

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Data aggregators
  • Social media services

Sales of Personal Information

In the preceding twelve (12) months, we have not sold any personal information for financial consideration.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal

information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and

use of your personal information over the past 12 months. Once we receive and confirm your

Verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Relay delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request through our online form available here. You can also call our dedicated privacy toll-free number at (833) 785-4411.

In the request, please specify which right you are seeking to exercise. We may require specific information from you to help us verify your identity and process your request. We will not use this additional information for anything other than handling your request.

Under the California Consumer Privacy Act (CCPA), a California customer may use an authorized agent to make a CCPA privacy request on the customer’s behalf. To make a request on behalf of a Relay customer, the authorized agent must first provide a copy of either:

(a) a letter signed by the customer authorizing the agent to submit a CCPA request on his or her behalf, or

(b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465.

An authorized agent must email one of these documents to legal@relaypro.com and include a phone number where the agent may be reached during regular business hours.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to {45/90} days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Correct Inaccurate Personal Information

You have a right to request correction of inaccurate personal information.

Personal Information Sales Opt Out and Opt-In Rights

California residents have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Business customers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out on Relaypro.com, you (or your authorized representative) may submit a request to us by following instructions detailed below::

  1. Go to our homepage www.Relaypro.com
  2. Scroll to the bottom of the page (under the Legal section) select the “DO NOT SELL MY PERSONAL INFORMATION” link
  3. The Privacy Manager Consent Management System is launched, click the teal toggle to turn off (opt out) of your information shared with advertising entities
  4. Click “Save and Exit”

To exercise the right to opt-out Relay Companion App, you (or your authorized representative) may submit a request to us by:

  1. In the Relay app tap on the “Settings” tab near the bottom of the screen.
  2. On the page, scroll to the bottom and select “About”.
  3. On the “About” page, toggle the switch labeled “DO NOT SELL MY PERSONAL INFORMATION”
  4. Select “Opt-out” submit your request to restrict information shared with advertising entities

Please keep in mind, If you delete the Relay Companion app, you will need to adjust your settings to opt out in the event you decide to reinstall the app. Your selection won’t cross from the mobile application to the web site (or the other way round): If you click the “Do Not Sell My Personal Information” on this website, your selection will not transfer to our mobile app. Similarly, your activation of the feature on the mobile app won’t apply to RelayPro.com.

We will only use personal information provided in an opt-out request to review and comply with the request.

Global Privacy Control

Relay, Inc. participates in a service called Global Privacy Control (GPC) that lets you set a “Do Not Sell or Share” preference at the browser level.  

  First, you’ll need a GPC-enabled browser or browser extension. Next, you’ll activate or turn on the GPC setting in the browser. When you visit a website, your browser will automatically send the site a “Do Not Sell or Share” signal and participating websites, like ours, will honor your preference.

Note: Not all browsers and extensions offer a GPC setting. To download a GPC-enabled browser, go to the Global Privacy Control website.  

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message to legal@relaypro.com through our website or write us at our address listed on our webpage.

Colorado, Connecticut, Utah, and Virginia:

If you are a resident of Colorado, Connecticut, Utah, or Virginia, we have certain obligations, and you have certain rights with respect to your personal information, including:

  • Right to correct inaccuracies in personal information
  • Right to delete personal information
  • Right to opt out from targeted advertising
  • Right to opt out from the sale of personal information

In certain states, you also have the right to opt out from profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer (such as Virginia, Colorado, and Connecticut) and appeal a decision regarding a request to exercise your rights.

Changes to our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which Relay collects and uses your personal information described above [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law,please do not hesitate to contact us:

Via our website: https://relaypro.com/legal/relay-privacy-policy

Write us: RELAY INC. Attn: PRIVACY & REGULATORY AFFAIRS 4200 Six Forks Road, Suite 1800, Raleigh, NC 27609

 

B2B Privacy Notice for California Residents

EFFECTIVE DATE: January 1, 2022

LAST REVIEWED: January 23, 2024

This Privacy Notice for California Residents supplements the information contained in the Relay Privacy Policy. The Relay, Inc B2B Privacy Policy “B2B Privacy Policy” applies to the users of Relay+ devices, the Relay Companion app (the “Companion App”), the online activity on relaypro.com webpages, the Relay+ services (“Services”), Relay platforms and our offline data processing activities including information collected during our in-person business interactions and conference events.

We make the security and confidentiality of the personal information that you provide to us a priority. Please read our Privacy Policy carefully.

We may update this Privacy Policy in the future. We will notify our business customers about material changes to this Privacy Policy by either sending a notice to the email address you provide to us or by placing a prominent notice on our websites

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

Commitment to Privacy

This B2B Privacy Policy applies to the collection, use, storage, sharing and retention of personal data associated with your B2B Enterprise account with us, if you work for an organization we do business with, how you can access, update your information and your rights to make decisions about how your information is utilized. This Privacy Policy governs our business-to-business (“B2B”) relationships and associated processing of information.

Information We Collect

We have collected the following categories of personal information from our business customers within the last twelve (12) months. ”YES” means we have collected information within the Category but does not mean we have collected all types of examples for each category.

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Information You Provide. We collect information that you provide to us when you apply for, purchase, or use our products or services, or otherwise communicate with us. For example:
    • Contact Information that allows us to communicate with you. We receive this information when you register on our website, and/or when you choose to request a demo through our website, order Relay+products or register for our Services. This would include information like your name, email address, business contact information, organization you are employed by and your role within said organization.
    • Billing Information related to your business relationship and information required for invoicing, such as whom and where to direct such matters to, the business services we provide to you, payment remittance, ACH information, your credit card numbers (which is provided to our third party credit card processing vendors), and service history.
    • When you contact us or request a demo we may monitor, record the communication and keep record of interactions to help us train employees and provide customer service.
    • When you name your Relay device, we retain the custom names you provide to identify relay devices from the companion app.
    • When you activate your Relay device, we keep a record of how your Relay device will be used.
    • When certain features are enabled by a business customer, we retain location, name and radius data in order to provide notifications to companion app and administrative users.
  • Information We Collect Indirectly. We collect information about your computer when you visit our Web sites and web interfacing platforms. For example, we collect session data, including your IP address, Web browser software, and referring website. We also may collect information about your online activity, such as content viewed and pages visited. This information also may permit us to identify users associated with multiple devices used to access our sites or services.
    • Cookies are small data text files that, if you accept and your web browser permits, can be stored on your computer’s hard drive. Relay and its web sites use cookies:
      • To help us recognize your web browser as a previous visitor and save and remember any preferences set while your Web browser visited our Web sites. For example, if you register on our websites, we may use cookies to remember your registration information so you do not need to log into our websites each time you visit. We also may save your password in a cookie, if you checked the box entitled “Save this password for automatic sign-in” (or other similar words).
      • To help us customize the content, website experience, and advertisements provided to you on our websites and on other websites across the Internet. For example, when you access a web page, a cookie automatically recognizes your web browser as you navigate on the Internet and presents you with information and advertising based on your apparent interests.
      • To help measure and research the effectiveness of the features, offerings, advertisements, and email communications (by determining which emails you open and act upon) of our websites.
    • Our websites also may use Web beacons (also known as clear gifs, pixel tags or web bugs). These web beacons are tiny graphics with a unique identifier, similar in function to cookies, that we place in the code of a web page. Web beacons allow us to monitor the traffic patterns of users from one page within our Web sites to another, deliver or communicate with cookies, understand whether you have come to our websites from an online advertisement displayed on a third-party website, and improve the performance of our websites. We also may allow our service providers to use web beacons to help us understand which emails recipients have opened and track the visitor traffic on our websites.
    • We may use these technologies to serve interest-based ads. If you accept cookies, we also allow third parties to collect information about your online activities through cookies and other technologies, and they may do so over time and across different websites. These third parties include advertising networks and our business partners, who collect information when you view or interact with our site or services, our ads, or ads you see on our sites or services. We do not have access to or control cookies or other technologies these third parties may use to collect information about your interests; our Privacy Policy does not cover either these third parties or their information practices.
    • We may use your information to help identify you as a user when you access our websites using different devices. If you use different devices (such as your home computer, laptop, and/or mobile device) to access our websites and/or engage in a transaction, we may be able to associate you with each of your devices. For example, if you choose to click on the email link on a new device, we may be able to associate your current device with your account information. We may combine information we have collected from your use of different devices and use that information consistent with this Policy, such as to help provide a more personalized and consistent experience across your devices, and to deliver more relevant advertisements to you.
    • We may also authorize third-party vendors to collect information on our behalf to operate features of our Web sites or facilitate the delivery of online advertising tailored to your interests, among other reasons. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
  • Information We Collect Automatically.
    • Technical & Usage Information related to the Services we provide to your organization, including information about how you use our network, Services, Relay+ products and applications. Some examples include:
      • Equipment Information that identifies the Relay equipment on our networks, such as equipment type, device identifiers, device status, serial numbers, settings, IP address, configuration and software.
      • Network Performance & Usage Information about the operation of the equipment, services and applications you use on our networks. Examples of this include but are not limited to the Relay+ and virtual devices (applications and profiles) managed within the Relay Dashboard, number of users, channel members, direct chats sent and received, management of channels, bluetooth connectivity and whether the Relay+ devices and application services were used on Wi-Fi or a cellular network. We also collect information like transmission rates and delays, data associated with remote monitoring services and security characteristics.
    • Using a Service or Make a Choice in the Companion App to provide it: As examples: (1) You decide to send a voice message using a Relay device or the Companion App. In this situation, we convert your voice message into data packets that travel over a WiFI or cellular connection (or a combination of both), to our servers, which then sends the voice data packets back out to the other Relay devices the communication was intended for. We retain a recording of your message for a limited time. You can listen to the recording of your message on the Relay device(s) or in your account in the Companion App. Once we delete your message from our systems, you will no longer be able to re-play the message. (2) You chose to enable location tracking, through the Companion App, for a particular Relay device. (3) You decide to use a voice command, for example, to change a Channel or listen to a recorded message on a Relay. Your voice command is sent to the Google Cloud Platform, which recognizes speech, converts it to text, and provides that information back to our servers so we can execute your command. We have no control over what Google does with any information that you pass to Google using the voice command feature. The Google Cloud Platform terms can be found here: https://cloud.google.com/terms/. Google may update this information from time to time and may also change the link(s) associated with this information. (4) You chose to enable other features as they become available. We will describe to you the information we collect and you can decide whether to enable the feature. When the feature is provided by a third-party, we will provide you with the information made available by the third-party so that you can decide whether to enable the feature.
    • When you use our networks, products and services. For example, we use network tools to collect network statistics; we use web server logs and other technologies. We automatically measure and monitor network performance and the performance of users’ Internet connections to improve our overall service levels.
    • Services,Companion App, Platforms, or device settings to provide customized support or to install or suggest specific features or services that you use or are necessary for your use of certain services we provide to you.
  • Information From Other Sources. like mailing lists, attendee lists from conference sponsorships, reports that help us detect fraudulent purchases, lead generation services, commercially available geographic and demographic information along with other publicly available information, such as public posts to social networking sites in order to better understand our Relay+ customer base better and improve the services and support that we offer our Relay business customers.
  • We may also obtain information about you from third parties. For example, our affiliates, service providers,data aggregators, lead generation services and social media services

Use of Personal Information

We may use the information we collect about you for a variety of purposes, including:

  • The registration and management of your account, including for invoicing purposes, the delivery and maintenance of products or services, assistance with service-related issues or questions, and the facilitation of your access to and use of our websites and web interface Relay platforms;
  • Communication with you, including to provide information about Relay+ and invitations from Relay;
  • Responses to your questions and comments, or other customer service;
  • Business and usage analytics, such as measurement of your interest in our products, services,platforms and websites, as well as the improvement, management and protection of our network, products, services, and websites;
  • Automated information collection technologies to provide personalized experiences to improve our services.
  • Notifications and provision of information about special offers and products or services available from us that may interest you;
  • Customization of your experience with Relay+ devices, applications and Services;
  • Solicitation of information from you, including through surveys, or administering contests or promotions;
  • Resolution of disputes and troubleshooting of other problems;
  • Prevention of potentially prohibited or illegal activities, or harm to any person or property;
  • Assisting law enforcement, pursuing or defending legal claims, and engaging in other compliance or legal activities;
  • Enforcement of our agreements with you, including our Terms of Service and our Relay Acceptable Use Policy; and
  • As otherwise described to you at the point of collection.

Sensitive Information

Subject to the features enabled and your contractual agreement we may collect, process, or disclose certain personal information that qualifies as “sensitive data” under applicable U.S. state data privacy laws. Sensitive data is a subset of personal information. In the list below, we outline the categories of sensitive data we collect, the sources of the sensitive data and our purposes of processing. 

 

Categories of Sensitive Data

Account log-in, financial account, debit or credit card number, and the means to access the account (security or access code, password, credentials, etc.)

  • Sources of sensitive data: Interactions with users and service providers that represent users
  • Purposes of Processing (Collection and Disclosure to Third Parties): Provide the Relay product/services and fulfill requested financial transactions 

Precise geo-location information

  • Sources of sensitive data: Users’ interactions with the products
  • Purposes of Processing (Collection and Disclosure to Third Parties): Provide the service requested; product improvement; some attributes may be disclosed to third parties to provide the service

Contents of your mail, email, or text messages 

Retention of Personal Information

Relay, Inc. will retain your personal information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.

Sharing Personal Information

Relay Inc. may disclose your personal information to a third party for a business purpose or sell your personal information as a “sale” is defined in the CCPA, subject to your right to opt-out of those sales (see Personal Information Sales and Opt-In Rights]. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase personal information we hold from reselling it unless you have explicit notice and an opportunity to opt-out of further sales.]

We share your personal information with the following categories of third parties:

  • Our affiliates;
  • Service providers;
  • Data aggregators;
  • Lead generation services;
  • Social media services.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial information.

Category E: Biometric Information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category I: Professional or employment information.

Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates;
  • Service providers;
  • Data aggregators;
  • Lead generation services; and
  • Social media services.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold any personal information for financial consideration.

Your Rights and Choices

What Choices Do You Have Regarding the Collection and Use of Your Information?

  • We want to make it easy for you to have choices regarding the information we do not automatically collect. For example, we have designed our Companion App to give the Account administrator control over many of the features available on each Relay device. Examples of this include turning on the SOS panic button feature for each Relay device enabling third-party services that will become available from time-to-time through the Services on the Relay device, location tracking, voice & audio message history, NFC based identity verification, bluetooth beacons, language translation and Relay Assistant.
  • You can choose not to turn these functions “on.”
  • You can enable and disable features through the Companion App or through web based Relay platforms.
  • You also can revise or update information as described above.
  • You also may unsubscribe from any promotional messages in any email we send. We reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating to your account, without offering you the opportunity to opt out of receiving them.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and

use of your personal information over the past 12 months. Once we receive and confirm your

Verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Relay, Inc delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a request through our online form available here. You can also call our dedicated privacy toll-free number at (833) 785-4411.

In the request, please specify which right you are seeking to exercise. We may require specific information from you to help us verify your identity and process your request. We will not use this additional information for anything other than handling your request.

Under the California Consumer Privacy Act (CCPA), a California customer may use an authorized agent to make a CCPA privacy request on the customer’s behalf. To make a request on behalf of a Relay customer, the authorized agent must first provide a copy of either:

(a) a letter signed by the customer authorizing the agent to submit a CCPA request on his or her behalf, or

(b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465.

An authorized agent must email one of these documents to legal@relaypro.com and include a phone number where the agent may be reached during regular business hours.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to {45/90} days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Correct Inaccurate Personal Information

You have a right to request correction of inaccurate personal information.

Personal Information Sales Opt Out and Opt-In Rights

California residents have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Business customers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out on Relaypro.com, you (or your authorized representative) may submit a request to us by following instructions detailed below::

  1. Go to our homepage www.Relaypro.com
  2. Scroll to the bottom of the page (under the Legal section) select the “DO NOT SELL MY PERSONAL INFORMATION” link
  3. The Privacy Manager Consent Management System is launched, click the teal toggle to turn off (opt out) of your information shared with advertising entities
  4. Click “Save and Exit”

To exercise the right to opt-out Relay Companion App, you (or your authorized representative) may submit a request to us by:

  1. In the Relay app tap on the “Settings” tab near the bottom of the screen.
  2. On the page, scroll to the bottom and select “About”.
  3. On the “About” page, toggle the switch labeled “DO NOT SELL MY PERSONAL INFORMATION”
  4. Select “Opt-out” submit your request to restrict information shared with advertising entities

Please keep in mind, If you delete the Relay Companion app, you will need to adjust your settings to opt out in the event you decide to reinstall the app. Your selection won’t cross from the mobile application to the web site (or the other way round): If you click the “Do Not Sell My Personal Information” on this website, your selection will not transfer to our mobile app. Similarly, your activation of the feature on the mobile app won’t apply to RelayPro.com.

We will only use personal information provided in an opt-out request to review and comply with the request.

Global Privacy Control

-Relay, Inc. participates in a service called Global Privacy Control (GPC) that lets you set a “Do Not Sell or Share” preference at the browser level.  

  First, you’ll need a GPC-enabled browser or browser extension. Next, you’ll activate or turn on the GPC setting in the browser. When you visit a website, your browser will automatically send the site a “Do Not Sell or Share” signal and participating websites, like ours, will honor your preference.

Note: Not all browsers and extensions offer a GPC setting. To download a GPC-enabled browser, go to the Global Privacy Control website.  

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a Relay Affiliate Program program requires your prior opt in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message to legal@relaypro.com through our website or write us at our address listed below.

Colorado, Connecticut, Utah, and Virginia:

If you are a resident of Colorado, Connecticut, Utah, or Virginia, we have certain obligations, and you have certain rights with respect to your personal information, including:

  • Right to correct inaccuracies in personal information
  • Right to delete personal information
  • Right to opt out from targeted advertising
  • Right to opt out from the sale of personal information

In certain states, you also have the right to opt out from profiling in furtherance of decisions that produce legal or similarly significant effects on the consumer (such as Virginia, Colorado, and Connecticut) and appeal a decision regarding a request to exercise your rights.

Changes to our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which Relay collects and uses your personal information described above [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us:

Via our website: https://relaypro.com/legal/relay-privacy-policy

Write us: RELAY INC. Attn: PRIVACY & REGULATORY AFFAIRS 4200 Six Forks Road, Suite 1800, Raleigh, NC 27609

Email us: Legal@relaypro.com

 

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