1. Important Information And Who We Are
This Site is not intended for children and we do not knowingly collect personal data relating to children.
Please note that where we help to provide some Services to you on behalf of our partner, Digifact Limited (please see below for further information), Revving is the processor of any third-party personal data you provide (such as your customers’ name, contact details and their accounts and receivables information) to enable us to provide those Services (“Third-Party Data”). For all other personal data that we process, Revving is the controller.
Email address: email@example.com
Postal address: Data Protection Officer, 21-22 Poland Street, London W1W 8RH, United Kingdom
Your Duty To Inform Us Of 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. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified (such as name and date of birth). 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, last name, title, date of birth and username.
Contact Data includes business address, home address, email address and telephone numbers.
Financial Data includes bank account and payment card details and information relating to your accounts and receivables. For further information on this refer to the ‘Financial Data’ section of ‘How we use your personal data’ below.
Transaction Data includes details about payments to and from you and other details of the products and services you are using.
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 the Services.
Profile Data includes your username and password, purchases or orders made by you, your preferences and survey responses.
Usage Data includes information about how you use our Site, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this 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).
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel the service we provide to you, but we will notify you if this is the case at the time.
3. How Is Your Personal Data Collected?
We use different methods to collect personal data from and about you including through:
You may give us your Identity, Contact, Financial and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
register to use our Site;
subscribe to our Services;
participate in discussion boards or other social media functions on our Site;
request marketing to be sent to you;
enter a promotion or survey; and/or
give us feedback or contact us.
Automated technologies or interactions
Third parties or publicly available sources
We will receive personal data about you from various third parties and public sources as set out below:
Identity, Contact and Financial Data from our partner, Digifact;
Technical Data from analytics providers such as Google Analytics. Further information can be found here: https://www.google.com/policies/privacy/partners);
Identity and Contact Data from data brokers or aggregators such as SmartCredit Ltd, Creditsafe Business Solutions Limited and RSM Tracker;
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register; and/or
Third Party User Data from parties such as Google, including Gmail, and Microsoft, including Office365/Outlook.
4. How We Use 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 we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Refer to ‘Lawful Basis’ in the Glossary section below to find out more about the types of Lawful Basis that we will rely on to process your personal data.
Purposes For Which We Will Use Your Personal Data
We have set out below, a description of all the ways we plan to use your personal data, and which of the Lawful Basis' we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific Lawful Basis we are relying on to process your personal data where more than one ground has been set out below.
|Purpose / Activity||Type of Personal Data||Lawful Basis|
To register you as a new user
Performance of a contract with you.
(Article 6(1)(b) UK GDPR)
To provide the Services to you including: (a) Allowing you to participate in interactive features of the Services; (b) Providing email integration services
Depending on the circumstances:
(a) Performance of a contract with you, Article 6(1)(b) UK GDPR.
(b) It is in our legitimate interests as it allows us to provide you with additional services, Article 6(1)(f) UK GDPR.
It is in our legitimate interests as it allows us to keep our records up to date, notify you about any changes to the Services and to understand how customers use our products and services, Article 6(1)(f) UK GDPR.
To administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Depending on circumstances:
(a) It is in our legitimate interests as it allows us to run our business in a secure manner, Article 6(1)(f) UK GDPR.
(b) It is necessary to comply with our legal obligations, Article 6(1)(f) UK GDPR.
To deliver relevant Site content to you in the most effective manner for you and your computer
It is in our legitimate interests as it informs how customers use our products and services and allows us to develop our business and service offering, Article 6(1)(f) UK GDPR.
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences
It is in our legitimate interests as it allows us to define types of customers for our products and services and to keep our Site updated and relevant, whilst developing our business and marketing strategy,
Article 6(1)(b) UK GDPR.
To make suggestions and recommendations to you about goods or services that may be of interest to you
Depending on the circumstances:
(a) It is in our legitimate interests to allow us to develop our products, service and grow the business, Article 6(1)(b) UK GDPR.
(b) We have obtained your consent, Article 6(1)(a) UK GDPR.
Conducting checks to verify your identity to prevent misuse of your account or to help prevent and detect fraud against you or us.
It is in our legitimate interests to allow us to minimise fraud that could be damaging for you and/or us, Article 6(1)(f) UK GDPR.
To enforce legal rights or defend or undertake legal proceedings.
Depending on the circumstances:
(a) to comply with our legal and regulatory obligations, Article 6(1)(c) UK GDPR.
(b) in other cases, it is in our legitimate interests, to protect our business, interests and rights, Article 6(1)(f) UK GDPR.
In order to conduct PEP, sanctions checks and Know Your Customer 'KYC' checks to identify you and verify the identity of our suppliers, service providers, and professional advisors and in order to meet our regulatory obligations under anti-money laundering and terrorist financing regulations.
Necessary in order to comply with our legal and regulatory obligations, Article 6(1)(c) UK GDPR.
For the purpose of audits, enquires or investigations and make disclosures to our auditors, our own legal and other professional advisors, our banks, insurers and insurance brokers and regulatory bodies for this purpose.
Necessary in order to comply with our legal and regulatory obligations, Article 6(1)(c) UK GDPR).
In order to establish, exercise or defend legal claims made by you or third parties, or otherwise for the purposes of protecting our rights and those of third parties.
Necessary in order to comply with our legal and regulatory obligations, Article 6(1)(c) UK GDPR.
We use your name and email address to send you (or the organisation you represent) marketing communications by email. We use your mobile telephone number to send you marketing communications by SMS/MMS. Our email and SMS/MMS marketing communications will include product updates, industry insights, Revving insights, information and invites to upcoming events, as well as general information about our organisation, our Site and the Services we provide.
Our email and SMS/MMS marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature services, events, offers and/or promotions that we think are most likely to appeal to you. Non-personalised marketing is marketing about our Services, events, offers and/or promotions generally and is not tailored to any individual.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another Lawful Basis to send such communications to you.
In the event we share any of your personal data with any third parties for marketing purposes, we will always ensure that we have your express consent prior to doing so.
Change of Purpose
5. Sharing Your Personal Data
We may share your personal data with the following parties (for the purposes set out above):
Internal Third Parties
Other companies in the Revving Group or connected to Revving who may provide you with access to or facilitate elements of the Services on behalf of Digifact.
External Third Parties
We will regularly share your personal information with Digifact to enable us to provide some Services to you.
Service providers who provide payment processing services.
Professional advisers including lawyers, bankers, auditors, insurers who provide consultancy, banking, legal, insurance and accounting services, accountants and tax advisers and credit and debt collection services providers.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
Analytics and search engine providers who assist us in the improvement and optimisation of our Site.
Credit reference agencies and fraud prevention agencies who provide information on your company’s credit behaviour, and external funding partners.
Any other third party that may assist us with the delivery of our customer solution.
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.
Fraud Prevention Agencies
We share personal data with fraud prevention agencies about both active and prospective borrowers.
The personal data we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money laundering and to verify your identity. If fraud is detected, you could be refused certain services or finance. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by viewing the Cifas National Fraud Database fair processing notice (https://www.cifas.org.uk/fpn).
If you provide us with false or inaccurate personal data and we suspect any unlawful activity such as fraud or money laundering, this will be recorded, and we may pass details to fraud prevention agencies.
We and other organisations may also access and use this personal data to prevent any unlawful activity, such as fraud and money laundering, including when:
checking and verifying your identity;
checking and verifying details on applications for credit, credit related or other financial products and facilities;
managing credit, credit-related or other financial products and facilities; recovering debt; and
checking details on proposals and claim for all types of insurance.
6. International Transfers of Your Personal Data
Please note that the personal data that we process may be transferred, stored and/or processed outside of the United Kingdom ("UK") and/or the European Economic Area ("EEA"). This may be the case for instance if for the purpose of providing our Services, we may need to share your personal data with a third-party supplier or in connection with the use of technical customer support services based outside the EEA. In connection with such transfers, we will always seek to ensure that:
an adequacy decision has been made by the United Kingdom or EEA (as applicable) such that the data protection regime in the relevant location or jurisdiction ensures an adequate level of protection for personal data; or
one of the derogations for specific situations in the first sub-paragraph of Article 49(1) UK GDPR (or the equivalent provisions of applicable data protection legislation in the UK) applies to the transfer, storage or processing.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.
7. Data Security
Your account information will be protected by a password for your privacy and security. To help prevent unauthorised access to your account, you should select and protect your password appropriately and limit access to your computer and browser by signing out after you have finished accessing your account.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 regulator of a breach where we are legally required to do so.
8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to erase your personal data: see Glossary below for further information.
In some circumstances we will 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.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to not be subject to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
Request the transfer of your personal data to you or to a third party. 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right To Make a Complaint
If you are dissatisfied with the way in which we have processed your personal data or you believe that we have breached data protection laws, you have the right to make a complaint to the ICO and contact details can be found at www.ico.org.uk/global/contact-us/. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Performance of Contract means processing your personal data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.