Policy version: 1st of March 2024

1 Introduction

This Privacy Policy is provided by Reverl Ltd, a company registered in England and Wales under company number: 14939696 with its office at 1 Grange Rd, Besscarr, Doncaster, DN4 6SA, UK (‘we’, ‘our’ or ‘us’) for the use of our products and services including our website, and support services (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights concerning your personal data and how to contact us or the relevant regulator if you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

2 What this policy applies to

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you under their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information, see the section ‘Who we share your personal data with’ below.

3 Personal data we collect about you

The personal data we collect about you depends on the activities carried out through the Services. We will collect and use the following personal data about you:

Category of data
In more detail
Identify and account for data you input into the Services
Registration is mandatory to use the Services
· Your name and email address
· Your account details, such as username and password
Data collected when you use specific functions in the Services
Data you store online with us using the Services, including your usage history or preferences (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it per this policy as if it were)
Other data the Services collects automatically when you use it
· Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use

If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4 Sensitive Data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

If, however, you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Services (such as by publishing it through any forum feature we may make available from time to time), we will assume that you have purposefully made any such sensitive data manifestly public.

5 How your personal data is collected

We collect personal data from you directly when you sign up for the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.

At this point, we do not collect any personal information about you using cookies or similar technologies. If this were to change and we decided to collect personal data about you using cookies, you would be notified of this change using either an in-app notification or via email, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

6 How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

(i) where you have given consent

(ii) to comply with our legal and regulatory obligations

(iii) for the performance of a contract with you or to take steps at your request before entering into a contract, or

(iv) for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. When relying on legitimate interests, we will carry out an assessment to balance our interests against yours. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for
Our reasons
Create and manage your account with us
To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you
Depending on the circumstances:
· to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances:
· to comply with our legal and regulatory obligations
· in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices
Depending on the circumstances:
· to comply with our legal and regulatory obligations
· in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data
To comply with our legal and regulatory obligations, we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases, our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., concerning our performance, customer base, app and functionalities and offerings or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records
Depending on the circumstances:
· to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
· to comply with our legal and regulatory obligations
· where neither of the above applies, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
Depending on the circumstances:
· to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
· to comply with our legal and regulatory obligations
· where neither of the above applies, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
To comply with our legal and regulatory obligations
To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.
In such cases, information will be anonymised where possible and only shared where necessary
Depending on the circumstances:
· to comply with our legal and regulatory obligations
· in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

7 Marketing

We might use email marketing to inform you of our services, such as promotions.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

• contacting us at james@reverl.com

• using the ‘unsubscribe’ link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object to your personal data being used for marketing purposes, see ‘Your rights’ below.

8 Who we share your personal data with
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers.

We only allow service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to you and to us.

We or the third parties mentioned above may occasionally also need to share your personal data with:

• external auditors, e.g. about the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations;

• professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations;

• law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations;

• other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please get in touch with us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

9 How long your personal data will be kept

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis’ have access to such data.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data.

10 Transferring your personal data out of the UK

At this point, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data would be indicated in the present section and notified to you per the section on ‘Change to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

• The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do this; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.

• Any country located outside the UK/EEA: we would rely upon appropriate safeguards under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements.

If we could not or choose not to continue to rely on either of those mechanisms at any time, we would not transfer your personal data outside the UK unless we could do so based on an alternative mechanism or exception provided by UK data protection law.

11 Your rights
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data
The right to be provided with a copy of your personal data.
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations.
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability
The right to receive the personal data you provided to us in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use
The right to object:
· at any time to, your personal data being used for direct marketing (including profiling)
· in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please get in touch with us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form— via email, call or write to us—see below: ‘How to contact us’. When contacting us, please:

• provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and

• let us know which right(s) you want to exercise and the information to which your request relates

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12 Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, used, or accessed unlawfully akin to bank-level security protocols. We limit access to your personal data to those with a genuine business need to access it.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on protecting your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

13 How to complain

Please get in touch with us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

14 Changes to this privacy policy

We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example, via the Services or by other means, such as email.

15 How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

1 Grange Road, Bessacarr, Doncaster, DN4 6SA, UK
james@reverl.com