REKKI

 

PRIVACY POLICY

 

This Policy

 

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 727-729 High Road, London, N12 0BP.

 

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.

 

Information we collect about you

 

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.

 

Cookies and other technologies

 

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.

 

 

How we use your information

 

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.

 

Our promotional updates and communications

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.

 

Who we give your information to

 

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.

 

 

Where do we store your information?

 

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.

 

 

How we protect your information

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.

 

How long we keep your information

 

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. 

Your rights

 

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 http://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.

 

Changes to this policy

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.

 

Contact us

Our full details are: REKKI Limited and we are contactable at dataprotection@rekki.com.