REKKI
This is REKKI Limited's (we/us/our) privacy
policy for the REKKI app as well as all websites, platforms and services that
link to the REKKI app which are operated by REKKI (together, the "App") unless covered by a separate
privacy policy.
REKKI Limited is
incorporated in England with company number 07849223 and registered address
Unit 3 NW Works, 135 Salusbury Road, London, NW6 6RJ.
This Privacy Policy describes who we are, why
and how we collect, process, and disclose your personal information (also
referred to herein as personal data) in conjunction with your access to and use
of the App and your rights and how to contact
us if you need to. This policy applies to all users of the App unless covered
by a separate privacy policy.
All those subject to this policy are referred
to as “users” for purposes of this policy. Our App allows buyers and suppliers to
contact and converse with each other primarily for the purpose of making and
fulfilling orders of goods.
Our contact details are set out at the end of this policy.
Our App is not intended for children under 18
years of age. No one under age 18 may provide any information to or on the App.
We do not knowingly collect personal information from children under 18. If you
are under 18, do not use or provide any information on this App or through any
of its features. If we learn we have collected or received personal information
from a child under 18 without verification of parental consent, we will delete
that information. If you believe we might have any information from or about a
child under 16, please contact us.
We are the controller in relation to the
personal data processed in accordance with this policy (except where this
policy explains otherwise).
Please read the following carefully to
understand our views and practices regarding your personal data and how we will
treat it. Your continued use of the App after
we make changes is deemed to be acceptance of those changes, so please check
the policy periodically for updates.
We may process your personal data if:
● You or the business
/ company you work for are a user of our App.
● You or the business
/ company you work for use our App or the services provided through the App.
● You work for a
buyer, a supplier or for someone who uses our services.
Information
we collect from you or from a third party
We may process your personal data that we
have either obtained from you or obtained from somewhere else. Personal
data which is not collected directly
from you may be collected:
● From any websites or
apps operated by us that you may use.
● From third parties we
work closely with (including, for example, business partners, sub-contractors
in technical, payment and delivery services, advertising networks).
Personal
data relating to you that we process may include:
● Your name.
● The name and address
of who you work for.
● Your phone number
and email address (these details may relate to your work or to you personally,
depending on the nature of our relationship with you or the company that you
work for).
● Information about
you that you give us by communicating with us by phone, by email, via our
website, via social media or otherwise.
It includes personal data you give us or that we obtain when you use our
website, enquire about our services and App, or contact us to report a problem,
or do any of these things on behalf of the person or company that you work for.
● Other information
relating to you which it is necessary for us to process in order to enter into
or perform a contract with you or the company you work for.
Information that we obtain from you when you use our Apps
may include:
● Information obtained
from you or the person you work for relating to transactions with us involving
you or the company you work for (for example: (i)
conversations; (ii) details of goods, items, ingredients or services that you
may order or receive orders for through the App; (iii) any images or other
media shared through the App; and (iv) names of other users.
● Information about
how you use the App, including when you stop using the App and when you are not
using all the functions of the App.
●
Technical information, including establishing what device
you have used to access the App, the Internet protocol (IP) address used to
connect your computer to the Internet, your login information, browser type and
version, time zone setting, browser plug-in types and versions, operating
system and platform.
●
Location data - we don’t currently collect location data,
but if we decide to do so in the future, the App will explicitly ask for your prior consent. If you agree, it will be used to
allow us to provide you with specialised features. Most mobile devices allow
you to control or disable the use of location services for applications in the
device’s settings menu.
●
With your prior consent, access to and uploading onto our
servers of your address book. This will
allow you to, amongst other things, start chats with, send messages, invite
your contacts to existing chats and generally interact with your contacts. It
will also allow you to see which of your contacts is already on REKKI, access
your contacts who are on the App more easily and mean that the App is more
efficient for you to use.
Our App uses cookies and/or other similar
technologies such as device-ID, in-App codes, pixel tags or web beacons to
collect and store certain information.
These typically involve pieces of information or code that a website
transfers to or accesses from your computer hard drive or mobile device to
store and sometimes track information about you. Cookies and similar
technologies enable you to
be remembered when using that computer or device to interact with websites and
online services and can be used to manage a range of features and content as
well as storing searches and presenting personalised content.
Our App uses cookies and similar technologies
to distinguish you from other users of our App.
This helps us to provide you with a good experience when you use our App
and also allows us to improve our App.
A number of cookies and similar technologies
we use last only for the duration of your web or app session and expire when
you exit the App. Others are used to
remember you when you return to the App and will last for longer but in any
case no longer than 13 months.
We use these cookies and other technologies
on the basis that they are necessary for the performance of a contract with
you, or because using them is in our legitimate interests (where we have
considered that these are not overridden by your rights), and, in some cases,
where required by law, where you have consented to their use.
We use the following categories of cookies on
Rekki.com and any web browser versions of our App:
●
Necessary Cookies: These cookies are required to ensure
you can move around the website and use its features by, for example, remembering
your login details.
●
Performance Cookies: We use these to collect anonymised
information about how users use our website. Our use of performance cookies
includes our use Google Analytics to help us understand how you arrive at and
use our site.
●
Functionality Cookies: These cookies assess and remember
choices you have made such as the country you visit our website from or
language. These help us to provide you with an experience more appropriate to
your selections and to make the visits more tailored and pleasant.
You can withdraw your consent to these
cookies at any time through the following options:
·
Google Analytics cookies may be removed by
downloading the Google Analytics Opt-out Browser Add-on; and
·
any other type of cookies may be removed
through your browser settings.
Information you give to us:
We will use this
information to:
●
Facilitate the creation of and to assist our efforts to
secure your account through the App, including by allowing us to verify your
identity.
●
Identify you as a user in our system and maintain a
record of your transactions and interactions through the App.
● Take steps in order
to enter into any contract or carry out our obligations arising from any
contract entered into between you or the company you work for and us including:
o supplying services,
including reports on the purchases or sales you make and from or to whom, to
you or the company you work for or receiving them from you or the company you
work for, as the case may be;
o providing you or the company you work for
with the information and services you request from us;
o administering your/your
company's account with us;
o notifying you about
changes to our service.
● Provide you with
information about our services we feel may interest you or the company you work
for, if you have given your consent to receiving marketing material from us.
See 'Our promotional
updates and communications'.
● Ensure in our
legitimate interests that:
o content from our App
is presented in the most effective manner for you and for your device;
o we provide you or
the company you work for with the information and services you request from us.
Information we collect about you from your use of our App
We will use this
information in our legitimate interests, where we have considered these are not
overridden by your rights to:
● administer the App
and for internal operations, including product development, troubleshooting,
data analysis, testing, research, statistical and survey purposes.
● analyse your use of
the App and where you stop using or are not using all functions of the App,
contact you through the in-App help chat.
● keep our App safe
and secure through account verification.
● to improve our App
to ensure that content is presented in the most effective manner for you and
for your device.
● to allow you to explore
suppliers on the platform or other services that you may have an interest in,
or that will provide a business advantage for you/your business.
We are only permitted to use
your data when we have a lawful basis to do so. The table below provides an
overview of the legal bases that REKKI relies on to use your data. Where the
legal basis is consent, you can withdraw consent at any time. Where the legal
basis is legitimate interests, you have a right to object to our use of your
data.
|
Purpose for which data is used
|
Data
|
Legal Basis
|
|
To provide you
with the app and app services |
Name, email address,
mobile phone number, contact list or address book entries.
|
Contractual necessity.
|
|
To verify your identity
and prevent fraud and to ensure the safety and security of users
|
Mobile phone number and email address.
|
Legitimate interests – it
is in our legitimate interests to ensure that accounts are not set up
fraudulently and to safeguard users of the Services.
|
|
To carry out research and
analysis to help us improve the Services
|
Log and usage data,
including IP address, traffic statistics, clickstream data, mobile carrier
and search terms
|
Legitimate interests – it
is in our legitimate interests to analyse the way in which users are
accessing and using our services so that we can further develop and improve
the App and the Services.
|
|
To respond to
correspondence and queries that you submit to us
|
Mobile phone number,
account information, email address and IP address
|
Legitimate interests – it
is in our legitimate interests to respond to your queries to ensure that we
provide a good service to users and troubleshoot problems.
|
|
To ensure that the App is
accessible and is in the right
language and use |
Phone and operating
settings, language settings as well as approximate locations data based on
your IP address. |
|
|
Localisation |
Location data when you use
the Services
|
Consent |
Chat and
Order Information
We confirm that we will not disclose to third parties that are not part
of the chat any orders or chats that take place between users of the App in any
way which would allow a user and/or the company they work for to be identified
directly or indirectly. This means that no user will be able to see what
another user that is not part of the chat orders in a way that would link it
directly or indirectly to that user.
We may however collect and distribute aggregated and anonymised
information (information relating to our users that we combine together so that
it no longer identifies an individual user) about our users and any orders they
place though the App. If we choose to do
this we will ensure that no individual user or company can be directly
identified from that data.
Where permitted in our legitimate interest or
with your prior consent where required by law, we will use your personal
information for marketing analysis and to provide you with promotional update
communications.
You can object to further marketing at any time by
changing your privacy settings in the App
or by sending us an email to dataprotection@rekki.com.
We may share certain aggregated and
anonymised information with:
● other users of the
App; and
● our current and
prospective business partners.
You cannot be identified from aggregate information used for these
purposes.
We may share your personal data with:
●
Any member of our group, which means our subsidiaries,
our ultimate holding company and its subsidiaries, who support the processing
of personal data under this policy or an employee thereof.
● Third parties that
may have access to this information in the course of their business with us,
including:
o
our business partners and sub-contractors for the
performance of any contract we enter into in relation to our App or other
dealings we have in the normal course of business with you or the person that
you work for; and
o
our auditors, legal advisors and other professional
advisors or service providers;
● In relation to
information obtained via our App:
o
analytics and search engine providers that assist us in
the improvement and optimisation of our App and subject to the cookie section
of this policy.
Other
disclosures we may make
We will disclose
your personal information to third parties:
●
in the event that we sell or buy any business or assets,
in which case we will disclose your personal data, if necessary, to the
prospective seller or buyer of such business or assets subject to the terms of
this privacy policy;
●
if REKKI Limited or substantially all of its assets are
acquired by a third party, in which case personal data held by it about its
customers will be one of the transferred assets; or
●
if we are under a duty to disclose or share your personal
data in order to comply with any legal obligation, or in order to enforce or
apply our supply terms and other agreements with you or the company you work
for; or to protect the rights and / or property of REKKI Limited and its group
companies (e.g. in the context of litigation), or the rights, property and
safety of our customers, or others. This includes exchanging information with
other companies and organisations for the purposes of fraud protection and
credit risk reduction and to prevent cybercrime.
REKKI does
not sell, trade, or rent personal data to any other third parties.
The data that we process in relation to you
may be transferred to and stored at a destination outside the European Economic
Area ("EEA") that may not be subject to equivalent data protection
law. It may also be processed by staff situated outside the EEA who work for us
or for one of our suppliers.
We may transfer your personal data outside of the EEA:
●
in order to process it;
●
in order to enable us to provide the services to and
fulfil our contract with you or the company your work for;
●
where we are legally required to do so; or
●
in order to facilitate the operation of our group of
businesses, where it is in our legitimate interests and we have concluded these
are not overridden by your rights.
The data that we process in relation to you
may be transferred to the USA on servers hosted by 3rd party
providers providing storage and data processing services. In this context, we
use AWS cloud – a secure, private cloud platform.
AWS participates in the EU-US Privacy
Shield framework.
Where your information is transferred anywhere
else outside the EEA, we will take all steps reasonably necessary to ensure
that your data is subject to appropriate safeguards, such as relying on a
recognised legal adequacy mechanism, and that it is treated securely and in
accordance with this privacy policy as provided by Article 46(2) and (3) of the
GDPR.
All information you
provide to us is processed on our secure servers. Where we have given you (or
where you have chosen) a password which enables you to access certain parts of
our App, you are responsible for keeping this password confidential. We ask you
not to share a password with anyone.
Unfortunately, the transmission of
information via the internet is not completely secure. Although we will do our
best to protect your personal data by using a
level of security appropriate to the risk, we cannot guarantee the
security of your data transmitted to our App; any transmission is at your own
risk. Once we have received your information, we will use strict procedures and
security features to try to prevent unauthorised access.
Our website may, from time to time, contain
links to external sites. We are not responsible for the privacy policies or the
content of such sites.
We retain personal
data for as long as you have an account with us in order to meet our
contractual obligations to you and for five years after that to identify any
issues and resolve any legal proceedings. We may also retain aggregate
information beyond this time for research purposes and to help us develop and
improve our services. You cannot be identified from aggregate information
retained or used for these purposes.
The GDPR makes a number of rights available
to you as a data subject, which are the following:
●
to be provided with a copy of your personal data held by
us;
●
to request the rectification of your personal data held
by us, for instance to correct (or update) any personal data about you that is
inaccurate (or out of date) or incomplete;
●
to request that we restrict the processing of your
personal data in certain circumstances (while we verify or investigate your
concerns with this information, for example);
●
to object to the further processing of your personal
data, including the right to object to marketing;
●
to request the erasure of
your personal data held by us (e.g., if the personal data are no longer
required in connection with the contractual relationship, or if you withdraw
your consent, where applicable);to request that your
provided personal data be moved to a third party or, where processing is automated and is necessary for the performance
of a contract, to receive personal data, which you have provided to us, in a
structured, commonly used and machine readable format.
You may opt out at any time from allowing
further access by us to your location data by
changing the privacy settings on your device or by emailing us at dataprotection@rekki.com.
If you are using the mobile phone version of
the App, you can also stop all information collection by un-installing the App.
You may use the standard un-install processes as may be available for your
mobile device.
If you would like us to delete your account,
please use the “Delete Account” function in the app. On receiving such a
request, we will delete or anonymise your personal data so that it no longer
identifies you. To protect information from accidental or malicious
destruction, we may maintain residual copies for a brief time period (generally
several weeks). But, if you delete your account, your information and content
will be unrecoverable after that time.
Your
right to withdraw consent:
Where the processing of your personal
information by us is based on consent, you have the right to withdraw that
consent without detriment at any time by contacting us.
How to
exercise your rights
You can also exercise the rights listed above
at any time by contacting us at dataprotection@rekki.com.
If your request or concern is not
satisfactorily resolved by us, you may approach your local data protection
authority, (see https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html ). The Information
Commissioner is the supervisory authority in the UK and can provide
further information about your rights and our obligations in relation to your
personal data, as well as deal with any complaints that you have about our
processing of your personal data.
Any changes we make
to our privacy policy in future will be posted on our App at and, in relation
to substantive changes, will be notified to you by e-mail. This policy was last
updated on 3rd September, 2019.
Our full details are: REKKI Limited and we
are contactable at dataprotection@rekki.com.