Rayz | Privacy Policy
Effective date: 16/06/2026 Version: Rayz Privacy Policy 1.0 (MVP)
1. Who we are
1.1 This Privacy Policy explains how Rayz App Ltd ("Rayz", "we", "us", "our"), a company registered in England and Wales (company number 16847921), registered office: Rayz, Working From Southwark, 32 Blackfriars Road, SE1 8PB, collects and uses personal data.
1.2 For the personal data we process in operating the Platform, Rayz is the data controller.
1.3 The Rayz Foundation is a separate legal entity that delivers the Rayz Development Programme. Where data is processed as part of that programme (for example, parts of verification and onboarding), the Foundation may act as a controller or as our processor, depending on the activity. Where the two entities share data, this is governed by a data sharing arrangement between them.
1.4 We process personal data in accordance with the UK GDPR and the Data Protection Act 2018.
2. Who this policy applies to
2.1 This policy covers Changemakers, Charity Partners, and Supporters using the Platform, and visitors to our website.
2.2 It also explains how we handle personal data of people who appear in content published on the Platform - in particular Captured Lives™ updates (see Section 6).
3. What data we collect
We collect the following categories of personal data:
- Account and identity data - name, email, password, organisation details, country.
- Verification data - identity documents and checks (KYC), interview records, profile-builder responses, supporting documents you upload, your safeguarding and development-module completion, and your one-minute intro video, provided through the Development Programme.
- Profile and content data - your public profile, Trust Profile status (e.g. Rayz Verified), and the Content you publish, including Captured Lives™ updates (text, images, audio, video).
- Donation and payment data - records of donations made and received. Card and bank details are handled by our payment provider(s), not stored by us.
- Communications - messages, voice notes (including thank-you messages to Supporters), and support correspondence on or about the Platform.
- Referred supporter data - where you invite or refer Supporters (for example through a referral link), the contact details you provide so we can invite them.
- Expressed-interest data - where someone uses a public share link to register interest in following a Changemaker, the contact details they provide.
- Supporter activity data - for Supporters: your giving history (one-off and recurring), the interests and values you share during onboarding, the causes and Changemakers you save or follow, your notification preferences, what you view in your feed (Hope Scroll), and referrals you make.
- Usage and technical data - how you interact with the Platform, device and log information, and analytics needed to operate and secure the service.
4. How we use personal data and our legal bases
We use personal data to:
- create and manage accounts, and verify identity and eligibility (contract; legal obligation; and, for safeguarding and anti-fraud checks, legitimate interests);
- operate the Platform, display profiles and Captured Lives™ updates to Supporters, and process donations (contract);
- match Supporters to relevant Changemakers and personalise the feed and discovery based on the interests and giving activity they share (legitimate interests; consent where required);
- maintain trust and safety, including safeguarding and fraud prevention (legitimate interests, and legal obligation where applicable);
- communicate with you about the service (contract; legitimate interests);
- meet legal, regulatory, and tax obligations (legal obligation);
- improve and secure the Platform (legitimate interests).
Where we rely on consent (for example, optional communications, or certain content involving identifiable people), you may withdraw it at any time.
4A. Automated and AI-assisted processing
4A.1 As part of the Development Programme, we use software tools - including AI services to help assess profile and document information and to suggest a personalised learning pathway for each Changemaker.
4A.2 These tools support our team; they do not make solely automated decisions that produce legal or similarly significant effects about you. A member of the team reviews verification and readiness outcomes. Where AI services are used, they are engaged as processors under appropriate data protection terms.
5. Children's and vulnerable people's data
5.1 The Platform is intended for users aged 18 and over.
5.2 Children and vulnerable adults may appear in Captured Lives™ content and other updates published by Changemakers operating in community, humanitarian, and educational settings. We treat this data with particular care, and Changemakers are subject to strict consent and safeguarding obligations before any such content is published - see Section 6 and the Captured Lives™ Consent & Filming Policy.
5.3 We may remove content involving children or vulnerable people at any time where consent cannot be evidenced or where there is a safeguarding concern.
6. Captured Lives™ - content featuring identifiable people
6.1 What Captured Lives™ is. Captured Lives™ is the short-form update format Changemakers use to show their work in real time - text, images, audio, and video. These updates often feature identifiable people, including beneficiaries, community members, children, and vulnerable adults.
6.2 The Changemaker's responsibility to obtain consent. Before recording or publishing any Captured Lives™ content featuring an identifiable person, the Changemaker must obtain that person's informed consent to being filmed or photographed and to that content being shared publicly on the Platform. Consent must be freely given, specific, and informed - the person should understand who Rayz is, that Supporters and (where applicable) the public may view the content, and that it may remain visible over time.
6.3 Children and vulnerable adults. Where a Captured Lives™ update features a child or a vulnerable adult, the Changemaker must obtain consent from a parent, legal guardian, or appropriate responsible adult, and must complete any safeguarding approval Rayz requires. Changemakers must not publish content that could identify, locate, or put a child or vulnerable person at risk. Where appropriate, identifying details should be minimised or withheld.
6.4 What Rayz does with this content. When a Changemaker publishes a Captured Lives™ update, Rayz hosts, stores, and displays it to Supporters and, where the update is shared via a public link, to others who access that link. We process it to operate the relationship loop between Changemakers and Supporters, and to maintain trust and safety on the Platform.
6.5 Withdrawal and removal. Any person featured in a Captured Lives™ update (or their parent, guardian, or responsible adult) can ask for that content to be removed. Requests can be made to the Changemaker directly or to Rayz at contact@rayz.space. On a valid request, or where consent cannot be evidenced, we will remove or restrict the content. Withdrawing consent does not affect lawful processing that took place before withdrawal.
6.6 Our role and limits. Rayz provides the publishing tools, sets consent and safeguarding requirements, and acts on removal requests and safeguarding concerns. We are not present at the point of recording and rely on Changemakers to obtain valid consent before they publish. Full practical requirements for Changemakers are set out in the Captured Lives™ Consent & Filming Policy available on our website or via contact@rayz.space.
7. Who we share data with
We share personal data with:
- Payment provider(s) who process donations and payouts;
- Identity verification provider(s) used for KYC during onboarding;
- learning-management and content-storage providers used to deliver the Development Programme and handle documents and intro videos;
- AI service provider(s) used to support learning-pathway assignment, under processor terms and with human oversight;
- the Rayz Foundation, in connection with the Development Programme, under a data sharing arrangement;
- Supporters, who see your public profile and the Captured Lives™ updates you choose to publish;
- service providers (e.g. hosting, analytics, communications) acting on our instructions as processors;
- authorities or regulators where required by law or to address a safeguarding or fraud concern.
We do not sell personal data.
8. International transfers
8.1 Changemakers and content may originate from multiple countries, and some of our providers are based outside the UK. Where we transfer personal data internationally, we use appropriate safeguards (such as UK adequacy regulations or standard contractual clauses / the UK International Data Transfer Agreement) to protect it.
9. How long we keep data
9.1 We keep personal data only as long as needed for the purposes above, including to meet legal, regulatory, safeguarding, and tax obligations. Verification, safeguarding, and donation records may be kept longer where required for audit or legal reasons. Published content remains available until removed by the Changemaker, by us, or following a valid removal request.
10. Your rights
10.1 Subject to applicable law, you have the right to access, correct, erase, restrict, or object to processing of your personal data, to data portability, and to withdraw consent where we rely on it.
10.2 To exercise these rights, contact us at contact@rayz.space. You also have the right to complain to the Information Commissioner's Office (ICO).
11. Security
11.1 We use appropriate technical and organisational measures to protect personal data. No system is completely secure; please keep your credentials safe and report any concern to us promptly.
12. Cookies
12.1 We use cookies and similar technologies to operate, secure, and improve the Platform. Our Cookie Policy is available on our website.
13. Changes to this policy
13.1 We may update this policy from time to time and will post the current version with its effective date. Where changes are material, we will give reasonable notice.
14. Contact
Questions or requests about this policy: contact@rayz.space and/or Rayz App Ltd, Working From Southwark, 32 Blackfriars Road, SE1 8PB