Consent to Personal Data Processing

Last Updated: 06.08.2024

This Consent to Personal Data Processing applies to the Raily service ("Service") operated by Summatus GmbH, a company registered in Germany with company number HRB 237306, and registered office at Frundsbergstraße 58a, Straßlach-Dingharting, 82064, Germany, operating under the brand name Raily, and its affiliated companies and subsidiaries (collectively referred to as "Company", "we", "us", "our").

The Service includes the Raily mobile applications (iOS and Android), smart glasses application, smartwatch application, website (www.raily.app), and all related services collectively provided by the Company under the Raily brand.

I hereby give my explicit and voluntary consent to the Company to process my personal data in accordance with the following conditions:

1. Scope of Consent

I agree to the collection, use, storage, and processing of the following categories of my personal data:

  • Name and surname (if provided)
  • Email address
  • Phone number
  • Profile picture
  • Geolocation data
  • Information about my interests and preferences
  • App usage data

Use of Artificial Intelligence (AI):

You agree to the use of advanced AI technologies to process your data for the purpose of enhancing your user experience. Our AI system analyzes the information you provide, including photographs, social media data, and preferences, to create personalized recommendations and match you with the most suitable travel companions. All data is transformed into vector representations, ensuring a high level of anonymity and protection of your personal information.

You have full control over your interests and preferences information. While our AI system may automatically determine your interests based on the data provided, you can always manually edit, add, or remove any interests through your profile settings. You also have the option to completely disable automatic interest determination if you prefer to specify them yourself.

Control over AI Decisions:

You have full control over how the AI system interprets your data. If you disagree with any conclusions or recommendations provided by our AI system, you can change the relevant information in your profile at any time. These changes will be immediately taken into account by the system to update recommendations and travel companion matching.

AI Transparency:

In accordance with Article 50 of the EU AI Regulation, we inform you that the Raily service is fundamentally built on AI-driven matchmaking. Our commitment to transparency includes:

  • Continuous AI Interaction: The entire Raily experience is powered by AI. This includes matchmaking, recommendations, and content personalization.
  • Visible AI Influence: We display a matching percentage bar next to people or places, clearly showing how our AI system has determined compatibility based on your profile and preferences.
  • User Control: You have direct control over your interests and preferences. Any changes you make will immediately affect your matching percentages and results, allowing you to see how your input influences the AI's decisions.
  • Transparent Learning: Our AI's understanding of your preferences is always reflected in your Interests section. You can review, modify, or remove these interests at any time, directly controlling how the AI interprets your data.
  • No Hidden Manipulations: We do not create or manipulate user profiles or content using AI. All profiles and content are created by users themselves.
  • Emotion and Biometric Recognition: Our AI system may analyze visual data to enhance matchmaking, but we do not use emotion recognition or biometric categorization for any purpose other than improving your matches and recommendations.

You can always access more detailed information about how our AI system works and influences your experience in the FAQ section at www.raily.app.

2. Purposes of Processing

I agree to the processing of my personal data for the following purposes:

  • Providing the Service, including travel and companion matching
  • Personalizing content and recommendations
  • Improving app functionality and user experience
  • Communicating with me
  • Ensuring security and preventing fraud

3. Data Sharing Within Company Group

I understand and agree that the Company may share my personal data with its affiliated companies, subsidiaries, and other legal entities within its corporate group, located in various countries and jurisdictions. This sharing is done to facilitate the provision of services, improve user experience, and for administrative purposes. The Company may delegate its rights and obligations regarding data processing to these entities without seeking additional confirmation from me.

4. Third-Party DataSharing

I understand that my data may be shared with third parties acting on behalf of the Company, exclusively for the purposes stated above and with appropriate data protection measures in place.

5. International Data Transfers

I agree to the transfer of my data to countries outside my country of residence, including countries outside the European Economic Area, if necessary for service provision. The Company ensures an adequate level of data protection for such transfers.

6. Duration of Consent

This consent is valid from the moment it is provided until I delete my account or withdraw my consent.

7. Right to Withdraw Consent

You understand that you have the right to withdraw this consent at any time by sending a request to privacy@raily.app or through the appropriate section in the app. You acknowledge and agree that withdrawing your consent will result in the termination of your access to Raily services, as your consent forms the legal basis for the processing of your personal data, which is essential for providing these services.

You understand that if you withdraw your consent:

  • Your account will be deactivated
  • You will no longer have access to Raily services
  • The Company will cease processing your personal data for the purposes outlined in this consent, except where there are other legal grounds to continue processing
  • The Company will retain your data only as long as necessary for legal or business purposes, as outlined in the Data Retention Policy

You understand that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8. My Rights

I understand that I have the following rights regarding my personal data:

  • The right to access my personal data
  • The right to rectify inaccurate personal data
  • The right to erasure ('right to be forgotten')
  • The right to restrict processing
  • The right to data portability
  • The right to object to processing

I can exercise these rights by contacting privacy@raily.app.

9. Data Protection Measures

I understand that the Company implements appropriate technical and organizational measures to protect my personal data, including encryption, access controls, and regular security audits.

10. Updates to this Consent

I understand that the Company may update this consent from time to time. I will be notified of any material changes and may be required to provide fresh consent to continue using Raily services.

11. Processing of Unnamed Accounts

I understand that if I choose not to provide my name during the registration process:

a) My consent is still valid and applies to all personal data I provide or that is collected about me through my use of the Raily services.
b) The Company will associate this consent with my account using a unique identifier (such as my email address or a system-generated ID).
c) I can update my account information, including adding my name, at any time through the app settings.
d) The absence of my name does not affect the applicability or enforceability of this consent.

12. Confirmation

By clicking the "I Agree" button or by using the Service, I confirm that:

a) I have read and understood this consent, as well as the Company's Privacy Policy.
b) I am at least 18 years old or have the necessary legal capacity to provide this consent.
c) I voluntarily agree to the processing of my personal data in accordance with the stated conditions.
d) I understand that this consent is necessary for using the Service, and that withdrawing this consent will result in the termination of my access to the Service.
e) I confirm that any information I provide is accurate and up-to-date to the best of my knowledge.

I agree to theprocessing of my personal data in accordance with the conditions set out above.

Date: 16.08.24

Summatus GmbH Frundsbergstraße 58a, Straßlach-Dingharting, 82064, Deutschland privacy@raily.app