Privacy Policy

This Privacy Policy explains how L’Atelier Gege LLC, a limited liability company registered in Mongolia (“Ray”, “we”, “us”), handles information in connection with the Ray notification and messaging service (the “Service”). We distinguish between account data (about our customers and their team members) and message data (recipient data our customers send through the Service).

1. Who we are

L’Atelier Gege LLC is the controller of account data. You can reach us about anything in this Policy at [email protected].

2. Account data we collect

• your name, email address, and avatar from your GitHub account when you sign in;
• workspace, membership, role, invitation, and API-key metadata;
• sign-in session records, including IP address and browser user agent;
• an audit log of actions taken in a workspace, including who took the action, their IP address, and user agent;
• billing details handled by our payment providers, Polar and QPay (we do not receive or store card numbers);
• messages you send us, such as support emails;
• logs, usage metrics, and error reports needed to operate, secure, and troubleshoot the Service.

3. Message data (customer content)

When you send through Ray, we process the recipients, content, and delivery metadata you provide, solely to deliver your messages and provide the Service. For this data you are the controller and Ray is the processor; you are responsible for having a lawful basis and any required consent.

We do not use message data for any purpose beyond delivering it and showing you what happened to it. Specifically, we do not sell it, share it for advertising, mine it for analytics or product research, or use it to train machine-learning models — not in identifiable form and not in aggregate. Access is limited to what is needed to operate the Service and to investigate a problem you report to us.

If you use in-app notifications, we store feed items — a title and description linked to the identifier you use for your end user — so they can be shown in that user’s in-app feed. If you turn on link-click tracking for email, we record when a tracked link was clicked, the destination URL, and the clicking browser’s user agent; we do not record the recipient’s email address with the click.

4. How we use account data, and why

We use account data (section 2):

• to provide, maintain, secure, and improve the Service;
• to process payments and prevent fraud and abuse;
• to communicate with you about your account and service changes;
• to meet our legal, accounting, and tax obligations.

“Improve the Service” covers account and usage data only. It does not extend to message data, whose permitted uses are limited to those stated in section 3.

We process account data to perform our contract with you, for our legitimate interests in running a secure and reliable service, to comply with the law, and — where the law requires it — with your consent, which you give when you sign up and accept our Terms and this Policy. You can withdraw consent at any time by closing your account (section 11); this does not affect processing that already took place, or data we must keep by law.

5. Cookies and local storage

We use only essential cookies and browser storage. We do not use analytics or advertising trackers.

• sign-in cookies that keep you signed in and secure the GitHub sign-in flow;
• sidebar_state, which remembers whether the dashboard sidebar is open;
• ray_last_workspace, which remembers the workspace you last opened (kept for one year);
• your light/dark theme preference, kept in your browser’s local storage.

6. Service providers and sharing

We use these providers to run the Service and share data with each only as needed for its role:

• Amazon Web Services — hosting and database;
• GitHub — sign-in;
• Cloudflare — DNS and network proxy in front of our website;
• an error-monitoring provider — diagnosing crashes and errors;
• Polar — merchant of record for card payments. Polar handles your payment details as an independent controller under its own privacy policy;
• QPay — payments in MNT.

The delivery providers you connect to a workspace — for example Amazon SES, Firebase Cloud Messaging, Twilio, sendsms.mn, Slack, Discord, Telegram, or your own webhook endpoints — are engaged by you under your own accounts. They are not our subprocessors: we pass them your messages on your instruction, and their handling of that data is governed by your agreement with them.

We may also disclose data where required by law or to protect the rights and safety of Ray, our users, or others. We do not sell personal data. A current list of our service providers is available on request.

7. Where data is stored (international transfers)

The Service is hosted on Amazon Web Services in the Tokyo, Japan region. This means your data is stored and processed outside Mongolia, and likely outside your own country. Some of our providers, such as GitHub, Cloudflare, and Polar, may also process data in other countries, including the United States. We transfer data abroad to provide the Service under our contract with you and on the basis of the consent you give when you sign up, and we use providers that apply appropriate safeguards to the data they handle.

8. Retention and deletion

Account data is retained for as long as your account is active and as needed for legal and operational purposes. The workspace audit log is deleted on the same plan retention window as delivery records (below).

Message data is retained in two stages. Message content and recipient details — the recipient address or token, the rendered message body, and its title — are erased 30 days after a message reaches its final state, on every plan, including paid ones. This is not a feature you can extend by upgrading.

What remains after that is the delivery record: which template and channel were used, when it was sent, and whether it succeeded or failed. That record is kept for your plan’s retention window and then deleted. Retention windows by plan are listed on our pricing page; custom windows are available on enterprise terms. Erasure is permanent — we cannot restore data once a retention window has passed.

In-app feed items and link-click records (section 3) are not part of the 30-day erasure: they are kept until the workspace is deleted, because your end users’ in-app feeds and your click reports depend on them.

When a workspace owner permanently deletes a workspace, we delete its data from the Service, including its templates, channels and stored provider credentials, API keys, delivery logs and sends, in-app feed items, suppressions, webhooks, members, invitations, usage counters, audit log, and subscription record. We cannot restore a deleted workspace. Records of billing and payment events — such as amounts, plan, and payment-provider references — are kept after deletion for accounting, tax, fraud-prevention, and dispute purposes. Deleted data may also remain in our backups for a limited period until those backups are overwritten in the normal course.

9. Security

We use encryption in transit, per-tenant encryption of sensitive credentials, scoped API keys, and access controls. No system is perfectly secure, but we work to protect your data.

If a security breach affects personal data we hold, we will notify the competent authorities as required by law, and notify affected users and customers without undue delay — immediately where the breach is likely to cause harm — so that they can take steps to protect themselves and their recipients.

10. Children

The Service is for businesses and developers. It is not directed at anyone under 18, and you must be able to form a binding contract to create an account.

11. Your rights

Depending on your jurisdiction, you may have rights to access, correct, export, or delete your personal data, to object to or restrict certain processing, and to withdraw consent. Email us at [email protected] to exercise them. There is no self-serve way to delete a user account yet, so to close your account, email us from the address on your GitHub account; workspace owners can delete a workspace themselves from its Settings page. For recipient data you send through Ray, direct requests to the customer who controls that data.

If you believe we have not handled your data properly, you may complain to a data protection authority — in Mongolia, the National Human Rights Commission of Mongolia, or the authority where you live.

12. Changes

We may update this Policy; material changes will be communicated through the Service or by email, and the date at the top of this page will change.