REAKT LTD
Windsor Avenue, Wimbledon, London, SW19 2RR, United
Kingdom
Last updated: 2022-07-19
Welcome to REAKT LTD’s Privacy and Data Protection Policy (“Privacy Policy”).
At REAKT LTD (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.
This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.
The individuals from which we may gather and use data can include:
This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
REAKT LTD is your Data Controller and responsible for your Personal Data.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to
this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise
your legal rights surrounding your Personal Data please contact the DPO using the details set out below:
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our
behalf (known as “Processors”). The responsibilities below may be assigned to an individual or
may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following
responsibilities:
“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
below. Not all of the following types of data will necessarily be collected from you but this is the full scope
of data that we collect and when we collect it from you:
We also collect, use and share Aggregated Data. Aggregated Data could be derived from your Personal Data but is
not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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 Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and
others. For example, we may conduct research on your demographics and usage. Although this aggregated data may
be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data
with others, including service providers, our affiliates, agents and current and prospective business
partners.
For the purposes of our business we also collect what is known under the GDPR as special categories of Personal
Data. We collect the following types of special Personal Data:
In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal
justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data.
The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a
box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our
contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as
fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet
our legitimate interests - this covers aspects that can be reasonably expected as part of running our business,
that will not have a material impact on your rights, freedom or interests. Examples could be your address, so
that we know where to deliver something to, or your name, so that we have a record of who to contact moving
forwards.
For the special categories of data that we collect, the enhanced legal justification we rely on is:
We will only use your Personal Data when the law allows us to.
You will receive marketing and new content communications from us if you have created an account and chosen to
opt into receiving those communications. From time to time we may make suggestions and recommendations to you
about goods or services that may be of interest to you.
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 contact us.
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.
Under certain circumstances, you have the following rights under data protection laws in relation to your
personal data:
Right to be informed. You have a right to be informed about our purposes for processing your
personal data, how long we store it for, and who it will be shared with. We have provided this information to
you in this policy.
Right of access. This enables you to receive a copy of the personal data we hold about you and
to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5
below for more details on how you can make a data subject access request.
Right to rectification. You have a right to request correction of the personal data that we hold
about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may
need to verify the accuracy of the new data you provide to us.
Right to erasure. You have the right to ask us to delete or remove personal data where there is
no good reason for us continuing to process it, where you have successfully exercised your right to object to
processing (see below), where we may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may not always be able to comply with
your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of
your request.
Right to object. You can object to the processing of personal data we hold about you. This
effectively allows you to stop or prevent us from processing your personal data. Note that this is not an
absolute right and it only applies in certain circumstances, for example:
Right to restrict processing. You have the right to request the restriction or suppression of
their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
Right to data portability. You have the right to request the transfer of your personal data to
you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen,
your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or where we used the information to
perform a contract with you.
If you wish to make a request under any of these rights, please contact us at team@reakt.to
You may delete your account at any time – this will remove your account page from our systems and our related
software. We guarantee this will delete all stored data.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent
unauthorized access to your account and personal information by selecting and protecting your password
appropriately and limiting access to your computer or device and by signing off after you have finished
accessing your account.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are
entitled to ask us for a notice identifying the categories of personal customer information which we share with
our affiliates and/or third parties for marketing purposes, and providing contact information for such
affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please
submit a written request to team@reakt.to.
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data
collected by us is only accessible by a limited number of employees who have special access rights to such
systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data,
we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen
had the data remained in our possession. However, unfortunately no transmission of data over the internet is
guaranteed to be completely secure. It may be possible for third parties not under the control of REAKT LTD to
intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal
Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is
done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
You can ask us to stop sending you marketing messages at any time by You can ask us to stop sending you marketing
messages at any time by unsubscribing, changing your account preferences, or contacting support.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided
to us as a result of interactions with us not related to your marketing preferences.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if
your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the
right to access your Personal Data (or to exercise any of your other rights). This is a security measure to
ensure that Personal Data is not disclosed to any person who has no 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 may also share Personal Data with interested parties in the event that REAKT LTD anticipates a change in
control or the acquisition of all or part of our business or assets or with interested parties in connection
with the licensing of our technology.
If REAKT LTD is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your
Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the
Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations
your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or
this Privacy Policy.
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage
you to read the privacy policy of every website you visit.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it
for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
Your information may be stored and processed in the US or other countries or jurisdictions outside the US where
REAKT LTD has facilities. By using REAKT LTD, you are permitting and consenting to the transfer of information,
including Personal Data, outside of the US.
We keep our Privacy Policy under review and will place any updates here.
By using REAKT LTD, you consent to the collection and use of data by us as set out in this Privacy Policy.
Continued access or use of REAKT LTD will constitute your express acceptance of any modifications to this
Privacy Policy.
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended
to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be
used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be
ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to
a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if
your request or question is polite, reasonable and there is no relatively obvious other way to deal with or
answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorised to contract on behalf of REAKT LTD, waive rights or make representations (whether
contractual or otherwise). If anything contained in an email from a REAKT LTD address contradicts anything in
this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to
a waiver of any REAKT LTD rights, the email content will be read down to grant precedence to the latter. The
only exception to this is genuine correspondence expressed to be from the REAKT LTD legal department.