PRIVACY POLICY

1. GENERAL

   1. Revenio CapitalLimited together with any group companies (“we” “us” “our”) are committed to protecting andrespecting your privacy. For the purposes of data protection legislation, weare the data controller and we will process your personal data in accordancewith the General Data Protection Regulation (EU) 2016/679 and national lawswhich relate to the processing of personal data. Please read the followingcarefully to

2. VISITORS TO OUR WEBSITE

   1.  We may collect andprocess personal data about you in the following circumstances:

      1. whenever you provideinformation to us when reporting a problem with our Site, making a complaint,making an enquiry or contacting us for any other reason. If you contact us, wemay keep a record of that correspondence;
      2. details of yourvisits to our Site including, but not limited to, traffic data, location data,weblogs and other communication data, whether this is required for our ownbilling purposes or otherwise, and the resources that you access (see section2.2.2 on Cookies below); and
      3. whenever youdisclose your information to us, or we collect information from you in anyother way, through our Site.

   2.  We may collect andprocess personal data about you in the following circumstances:

      1. IP Address
         
         We may collectinformation about your device, including where available your Internet Protocoladdress, for reasons of fraud protection. We may also collect information aboutyour device’s operating system and browser type, for system administration andto report aggregate information to our advertisers. This is statistical dataabout our users' browsing actions and patterns, and does not identify anyindividual.
      2. Cookies
         
         Our Site usescookies to distinguish you from other users of our Site. This helps us toprovide you with a good experience when you browse our Site and also allows usto improve our Site. For detailed information on the cookies we use and thepurposes for which we use them see our Cookie Policy

   3. We may use yourpersonal data for our legitimate interests in order to:

      1. provide you withinformation or services that you requested from us;
      2. ensure thatcontent from our Site is presented in the most effective manner for you and foryour device;
      3. improve our Siteand services;
      4. process and dealwith any complaints or enquiries made by you; and
      5. contact you formarketing purposes where you have signed up for these (see section 6 forfurther details).

3. CLIENTS

   1. In order toprovide our services to you we need to collect your personal information suchas your name, contact details, address and financial information. We will usethis information in order to fulfil our contractual obligations, comply withlegal obligations or for our legitimate business interests.
   2. In order to perform our contactwith you, we may also need to share personal data with third parties. Pleasesee section 9 below for more details.
   3. We will retain your informationas long as we require this to provide you with our services and then for anappropriate period of time thereafter. The subsequent period of time will bedetermined by the nature of the services we provide to you and our legalobligations in this regard. In any event we will retain your personalinformation for a minimum period of seven years.

4. SUPPLIERS

   1. We will collectdetails such as key contacts names, email address and telephone in order tocontact you about goods or services we’ve ordered from you, to place furtherorders and to pay you for the goods or services you’ve supplied. We will keepthe personal data for a minimum period of seven years further to being providedwith the goods or services.

5. IF YOU FAIL TO PROVIDE PERSONAL DATA

   1. Where we need tocollect personal data by law, or under the terms of a contract we have with youand you fail to provide the data when requested, we may not be able to performthe contract we have or are trying to enter into with you. In this case, we mayhave to cancel a service you have with us but we will notify you if this is thecase at the time.

6. MONITORING AND RECORDING

   1. We monitor and record communications with you(such as telephone communications and emails) for the purpose of fraudprevention and compliance with our legal or regulatory obligations. We retainsuch information for a period of seven (7) years.

7. AUTOMATED PROCESSING

   1. We do not undertake automated decision making with your personal data.

8. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

   1. We will only use your personal data where the lawallows us to. Most commonly, we will use your personal data in the followingcircumstances:

      1. for performance of a contract we enter into with you;
      2. where necessary for compliance with a legal orregulatory obligation we are subject to; and
      3. for our legitimate interests (as described within thispolicy) where your interests and fundamental rights do not override theseinterests.

9. DISCLOSURE OF PERSONAL DATA to third parties

   1. In addition to thethird parties mentioned above, we may disclose your information to thirdparties for our legitimate interests as follows:

      1. to staff membersin order to facilitate the provision of services to you;
      2. to our affiliated entities to support internaladministration;
      3. outsourced service providers, including by not limited topayroll and pensions services;
      4. IT softwareproviders that host our website and store data on our behalf;
      5. professionaladvisers including consultants, lawyers, bankers and insurers who provide uswith consultancy, banking, legal, insurance and accounting services; and
      6. HM Revenue andCustoms, the Financial Conduct Authority and other relevant regulators andauthorities who require reporting of processing activities in certaincircumstances.

   2. We may disclosepersonal data to the police, regulatory bodies, legal advisors or similar thirdparties where we are under a legal duty to disclose or share personal data inorder to comply with any legal obligation, or in order to enforce or apply our
      website terms and conditions and other agreements; or to protect our rights,property, or safety of our customers, or others. This includes exchanginginformation with other companies and organisations for the purposes of fraudprotection and credit risk reduction.

   3. We will not sellor distribute personal data to other organisations without your approval.

10. DATA SECURITY

    1. Unfortunately, thetransmission of information via the internet is not completely secure. Althoughwe will do our best to protect your personal data, we cannot guarantee thesecurity of your information transmitted to our Site; any transmission is atyour own risk.
    2. Information youprovide to us is shared on our secure servers. We have implemented appropriatephysical, technical and organisational measures designed to secure yourinformation against accidental loss and unauthorised access, use, alteration ordisclosure. In addition, we limit access to personal data to those employees,agents, contractors and other third parties that have a legitimate businessneed for such access.

11. ACCESS TO, UPDATING, DELETING AND RESTRICTINGUSE OF PERSONAL DATA

    1. It is importantthat the personal data we hold about you is accurate and current.  Please keep us informed if the personal datawe hold about you changes.  
    2. Data protectionlegislation gives you the right to object to the processing of your personaldata in certain circumstances or withdraw your consent to the processing ofyour personal data where this has been provided. You also have the right toaccess information held about you and for this to be provided in anintelligible form. If you would like a copy of some or all of your personalinformation, please send an email to info@revenio.co.uk. In certaincircumstances we reserve the right to charge a reasonable fee to comply withyour request.

    3. You can also askus to undertake the following:

       1. update or amendyour personal data if you feel this is inaccurate;
       2. remove yourpersonal data from our database entirely;
       3. send you copies ofyour personal data in a commonly used format and transfer your information toanother entity; or
       4. restrict the useof your personal data.
    4. We may requestspecific information from you to help us confirm your identity and your rightto access, and to provide you with the personal data that we hold about you ormake your requested changes. Data protection legislation may allow or requireus to refuse to provide you with access to some or all the personal data thatwe hold about you or to comply with any requests made in accordance with yourrights referred to above. If we cannot provide you with access to your personaldata, or process any other request we receive, we will inform you of thereasons why, subject to any legal or regulatory restrictions.
    5. Please send anyrequests relating to the above to our DataLead, Thomas Robinson at trobinson@revenio.co.uk, telephone (0044)(0)20 7255 6983 specifying your name and the action you wouldlike us to undertake

12. RIGHT TO WITHDRAW CONSENT

    1. Where you have provided your consent to the collection,processing and transfer of your personal data, you have the legal right towithdraw your consent under certain circumstances. To withdraw your consent,please contact us at info@revenio.co.uk.

13. CHANGES TO OUR PRIVACY POLICY

    1. We reserve theright to update this privacy policy at any time, and any changes we make to ourprivacy policy will be posted on this page. Please check periodically for anyupdates. If we would like to use your previously collected personal data fordifferent purposes than those we notified you about at the time of collection,we will provide you with notice and, where required by law, seek your consent,before using your personal data for a new or unrelated purpose. We may processyour personal data without your knowledge or consent where required byapplicable law or regulation.

14. CONTACT US

    1. We have appointed a Data Lead to oversee compliance withthis privacy policy. If you have any questions, comments or requests regardingthis policy or how we use your personal data please contact our Data Lead at trobinson@revenio.co.uk ,telephone (0044) (0)20 7255 6983. This is in addition to your right tocontact the Information Commissioners Office if you are unsatisfied with ourresponse to any issues you raise at https://ico.org.uk/global/contact-us/ 
       
       Last updated: June 2018.