Ravelin Privacy Policy

Last updated: 21st May 2018


Your personal data and privacy matters to us

Ravelin is a software platform built to help business sell securely online. Data security and privacy is very important to us. Personal data means any information about an individual from which that person can be identified.

Your personal data and privacy is important to us.

We are committed to safeguarding your personal data and protecting your privacy. This policy explains how we set out to do that. 

    1.  How this privacy policy applies to you

This privacy policy applies to:

    •    your use of our website, whether as a visitor or as an actual or prospective User;
    •    your receipt of our services as a User.
    •    The Customer of a User.

This privacy policy replaces any privacy policy that we have previously issued.

Any notices or statements relating to data, data protection, fair processing and/or privacy that we may issue at the time of collecting personal data about you will supplement this privacy policy.  They are not intended to override it.

We may change this privacy policy from time to time to reflect changes in the law and/or our personal data handling and data protection practices.

We encourage you to check this privacy policy for changes whenever you visit our website, as we may not always notify you of the changes.

It is important that the personal data we hold about you is accurate and current.

Please keep us informed if your personal data changes during your relationship with us.

    2.  Who we are and whether we have a Data Protection Officer (DPO)

We’re Ravelin Technology Limited, registered at 33 Bowling Green Lane, London EC1R 0BJ. 
We are the data controller and/or processor of your personal data.

References within this privacy policy to we, us, our within this privacy policy will be to the applicable data controller.

    3.  Do we have a Data Protection Officer (DPO)?

We have appointed a DPO who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights relating to your personal data, please contact the DPO using the details set out below.

    4. How to get hold of us and our DPO

You can contact us and our DPO for any data related query or to make a complaint about how your personal data is being handled using the details below:
 
    ◦    email address: privacy@ravelin.com ; or

    ◦    postal address: 33 Bowling Green Lane, London EC1R 0BJ, marking it for the attention of the DPO


    5. Who is involved in our collection, handling and use of your personal data?


The way we collect data depends on who you are and and the Services that you use. 

Ravelin website and web properties: We collect data from Users and prospective Users directly through forms on our website. 

Ravelin’s Users’ services:  Ravelin’s Users send data relating to the Customers to Ravelin for the purpose of fraud detection. The type of data, how we handle it and legitimate use is detailed in the section Ravelin as a Data Processor.

Third party service providers:  we may instruct third parties to assist us to collect, handle, or enhnace your personal data on our behalf.  Those third parties will carry out those activities in accordance with this privacy policy.

   5a. Ravelin as a Data Processor


We may collect, use and disclose certain Personal Data about Customers when acting as the User’s service provider. Our Users are responsible for making sure that the Customer’s privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a User’s data processor, we will process Personal Data in accordance with the terms of our agreement with the User and the User’s lawful instructions.


    6.  What personal data about you do we collect?
 


Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
 
    •    Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender];

    •    Contact Data includes [billing address, delivery address, email address and telephone numbers];

    •    Financial Data includes [payment card details];

    •    Transaction Data includes [details about payments to and from you and other details of products and services you have purchased];

    •    Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website];
   
    •    Profile Data includes your username, purchases or orders made by you;

    •    Usage Data includes information about how you use our website, products and services; and

    •    Marketing and Communications Data includes your preferences in receiving marketing from us.

We also collect, handle, use and share:

    •    aggregated data such as statistical or demographic data for any purpose.  Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice; and

    •    anonymised data is data created from your personal data where your identity has been removed.  

We do not collect any Special Categories of Personal Data about you, which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

Nor do we collect any information about criminal convictions and offences.

We do not intentionally collect personal data relating to children.

    7.   Where do we source your personal data from and how?

We use different methods to collect personal data from and about you including through:
 
    •    Direct interactions – you may give us your identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.  This includes personal data you provide when you:

    ◦    apply for our products or services;
    ◦    create an account on our website;
    ◦    subscribe to our service or publications;
    ◦    request marketing to be sent to you;
    ◦    enter a promotion or survey; and/or
    ◦    give us some feedback.

    •    Automated technologies or interactions – as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  


    •    Ravelin users’ services - Ravelin users send us personal data for the purposes of fraud prediction and other services.


    •    Third parties or publicly available sources – we also receive (as part of the provision of a commercial service) personal data about you from our users’ services.

    ◦    Technical Data from the following parties:
    ▪    analytics providers such as Google, Mixpanel, Looker based inside and outside the EU;

    ◦    Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Adyen, WorldPay, ACI, Braintree and many more both inside and outside the EU.   

    ◦    Identity and Contact Data from publicly available sources


    8.  What do we do with your personal data?

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

    •    where we need to perform the contract we are about to enter into or have entered into with you;

    •    where it is necessary for our legitimate interests in the provision of a service to our Users,  and your interests and fundamental rights do not override those interests; and

    •    where we need to comply with a legal or regulatory obligation.

Section 12 sets out a description of what we will do with your personal data and our legal justification for doing so.



    9.  Other use related information

    •    Sales and marketing communications from us – we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.  We call this communications. 

You will receive promotional communications from us if you have:

    ◦    requested information from us;

    ◦    retained our services as a client;

and, in each case, you have not opted out of receiving that promotion.

    •    Third party marketing – we will never share your personal data with any company outside our organisation or group of companies for marketing purposes.

    •    Opting out/withdrawing consent – you can ask us or those third parties to stop sending you promotional or marketing messages by following the opt-out links on any promotional or marketing message sent to you or by contacting us at any time on privacy@ravelin.com.

Where you opt out of receiving these promotional or marketing messages, this will not apply to personal data provided to us as a result of registering with us as a User of our services. 

    •    Cookies – you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  

    •    Change of purpose – we will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email privacy@ravelin.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


    10. Who do we share your personal data with?

We may share your personal data with the following entities:
 
    •    the entities listed in Appendix 1;

    •    third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; and

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which includes this privacy policy.


    11.  What are the legal grounds for our collection, handling, use and sharing of your personal data?

 

Legal basis for processing

Purpose or Activity

1. To register you as a User

Performance of a contract with you

2. To provide a fraud detection service for our Users

Necessary for our legitimate services (to provide fraud detection for our Users of which you may be a Customer)  

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Necessary for our legitimate interests (to develop our products/services and grow our business)
 


 

    12.  Where do we send your personal data to for storage or other specific purposes?
 

We’re based in the UK and will not transfer your personal data outside the EEA.  
 
If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.


13.     How will we look after your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an authorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority where we are legal required to do so.

 14.   How long will we keep your personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Right of erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

    15.    What are your legal rights in respect of your personal data that we handle?

We set out below a list of the legal rights that all individuals have under data protection laws in relation to our handling of your personal data. Where we process data on the behalf of our Users for the purposes of fraud detection then Ravelin possesses certain exemptions from the rights laid out below and will refer requests back to the originating User. 
 
    •    Right to be informed – about the processing of your personal data, including the safeguards used to protect any of your personal data in the event that we transfer it outside the EEA;
 
    •    Right to have inaccuracies corrected – the right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
 
    •    Right to object – to the processing of your personal data for certain purposes, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests;
 
    •    Right to restrict processing – of your personal data;
 
    •    Right of erasure – of your personal data also known as the “right to be forgotten”;
 
    •    Right to request access – to your personal data and to obtain information about how we process it;
 
    •    Right to move, copy or transfer – your personal data, also known as “data portability”;
 
    •    Rights in relation to automated decision making – which has a legal effect or otherwise significantly affects you; and
 
    •    Right to complain – in all circumstances, you may complain to:
 
    ◦    us in relation to the handling of your personal data; or
 
    ◦    the Information Commissioner’s Office which enforces data protection laws, whose contact details are set out on www.ico.org.uk.
 
Procedure to exercise your legal rights
 
    •    Contact us – if you wish to exercise any of your legal rights please contact us at privacy@ravelin.com.  We’ll explain first whether or not the right you wish to exercise applies.
 
    •    Fees – you will not have to pay a fee to access your personal data or to exercise any other rights that apply.  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in these circumstances.
 
    •    Request for further information – we may need to request certain information from you to help us confirm your identity and ensure that your right to access your personal data (or to exercise any of your other rights that apply).  This is a security measure to ensure that any personal data is not disclosed to any persona who has not right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response. We will also seek to establish if we are the correct party for this request.

    •    Response time – we try to respond to all legitimate requests within one month.  Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

   Appendix 1

List of third party service providers:

    •    Data storage providers – we store all of our data with Google Cloud, within the EEA.

    •    Visitors to our websites – when someone visits www.ravelin.com, we use a third party services, to collect standard internet log information and details of visitor behaviour patterns.  We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it;

    •    Advertising - we may use third-party advertising companies to serve advertisements to you. These service typically serve cookies on your browser and use anonymised, aggregated data to recognise you on other properties. We may use Google Adwords, Ad Roll, Linkedin, Facebook, Natify or other services, each of which has its own Privacy Policy we would encourage you to consult.

  •    Third Party services. In the provision of our fraud detection services we may use external services to enhance data. All services we use will be listed here.