Introduction

Revving Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit or use www.revving.io (and all of its subdomains, together the “Site”) and when you use the services, features, content or applications, including those that we help to provide on behalf of our partner, Digifact Limited ("Digifact") (collectively with the Site, the “Services”). It will also tell you about your privacy rights and how the law protects you. Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

We would encourage you to read Digifact's Privacy Policy, which can be found here. As they will be the contracting party to any agreement you enter into for the provision of the Services. Please note that this Privacy Policy does not apply to your interaction with Digifact directly or any other third-party service providers.

1. Important Information And Who We Are

This Privacy Policy aims to give you information on how Revving Limited collects and processes your personal data through your use of the Services, including any personal data you may provide (i) when you register for the Site and the Services, through your user account and (ii) through your use of the Services generally.

This Site is not intended for children and we do not knowingly collect personal data relating to children.

This Privacy Policy supplements any other notices and privacy policies we may provide on specific occasions when we are collecting or processing personal data about you and is not intended to override them.

Revving

Revving Limited is the controller and responsible for your personal data (collectively referred to as “Revving”, “we”, “us” or “our”), as set out in this Privacy Policy. We are registered in England and Wales under company number 12735446, and have our registered office at 250 Wharfedale Road, Winnersh Triangle, Wokingham, Berkshire RG41 5TP, United Kingdom. We are registered with the Information Commissioner’s Office ("ICO"), under registration number ZB178923.

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.

Contact Details

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions and requests in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: legal@revving.io

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.

Third-Party Links

Our 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 personal 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.

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:

Direct interactions

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

As you interact with our Site, we will 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. Please see our cookie policy for further details.

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.

Generally, we do not rely on consent as a Lawful Basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact details provided in this Privacy Policy or by using the opt-out option in any of our marketing communications.

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.

Financial Data

As many of the Services we offer involve receivables and accounts services, we may, as a result of your use of the Services, obtain from you, financial information including information relating to your accounts, receivables, payables, accounting ledgers and accounting reports. We shall use such information solely in furtherance of the Services we provide to you and in accordance with this Privacy Policy.

Marketing

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.  

Where data that we process is anonymised, we do not require a Lawful Basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. 

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.

Cookies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

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 contact us using the contact details provided in this Privacy Policy.

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.

• 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.

• 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:

• there are appropriate safeguards in place such as binding corporate rules or the standard data protection model contractual clauses between either each of us or between us and the recipient. A copy of the appropriate safeguard can be obtained by contacting us using the contact details set out in this Privacy Policy; or

• 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.

If you wish to exercise any of the rights set out above, please contact us using the details provided in this Privacy Policy.

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.

Changes to the Privacy Policy

We keep our Privacy Policy under regular review. This version was last updated on [3 February 2023].

10. Glossary

LAWFUL BASIS

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.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the contact details provided in this Privacy Policy.