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 we offer (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.

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 data you may provide (i) when you register for the Site and the Services, through your user account and (ii) your use of the Services generally.This Site is not intended for children and we do not knowingly collect 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” in this privacy policy), 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 under registration number 12735446.Please note that where we provide Services to you, Revving is the processor, and you are the controller, of any third-party personal data you provide to us (such as your customers’ name, contact details and their accounts and receivables information) to enable us to provide certain features the Services (“Third-Party Data”). The data processing provisions governing our use of such personal data are contained in our Terms and Conditions with you. You must not input, upload, provide or otherwise make available to or through the Services any Third-Party Data unless you have a legal right to do so.

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. 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.
• Third Party User Data includes email message bodies (including attachments), metadata, headers and settings when using our email integration services. For further information on this see the ‘Additional restrictions on the use of Third Party User Data’ section of ‘How we use your personal data’ below.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 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). Nor do we collect any information about criminal convictions and offences.

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 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation.

Refer to ‘Lawful Basis’ 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 legal 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.

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 legal bases 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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Purpose/Activity: To register you as a new user:Type of data: (a) Identity; (b) ContactLawful basis for processing including basis of legitimate interest: Performanceof a contract with you

Purpose/Activity: To provide the Services to you including:(a) Allowing you to participate in interactive features of the Services;(b) Providing email integration servicesType of data: (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications; (f) Third Party User DataLawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary for our legitimate interests

Purpose/Activity: To manage our relationship with you which will include:(a) Notifying you about changes to our Terms or Privacy Policy;(b) Notifying you about changes to our Services;(c) Asking you to leave a review or take a surveyType of data: (a) Identity; (b) Contact; (c) Profile; (d) Marketing and CommunicationsLawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests(to keep our records updated and to study how customers use our products/services)

Purpose/Activity:To administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Type of data: (a) Identity; (b) Contact; (c) TechnicalLawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group re-structuring exercise); (b) Necessary to comply with a legal obligation

Purpose/Activity: To deliver relevant Site content to you in the most effective manner for you and your computerType of data: (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) TechnicalLawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)

Purpose/Activity: To use data analytics to improve our website, products/ services, marketing, customer relationships and experiencesType of data: (a) Technical; (b) UsageLawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to youType of data: (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and CommunicationsLawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose/Activity: To comply with our legal obligations including the prevention of financial crime
Type of data: (a) Identity; (b) Contact; (c) Transaction; (d) Third Party User Data
Lawful basis for processing including basis of legitimate interest: To comply with a legal obligation

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties as set out in the Glossary below.

External Third Parties as set out in the Glossary below.

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.

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.

6. International transfers

Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

The country to which we transfer your personal data has been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific model contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based outside the EEA, we may transfer data to them if the country in which they will process your data has been found by the European Commission or the UK government to provide adequate levels of data protection, or once we have put in place standard contractual clauses issued by the European Commission in order to protect your data. Where we use these standard contractual clauses, we will conduct a risk assessment to ensure we are comfortable that the measures we have taken provide enough protection within the local legal framework and we will work with our overseas providers to actively identify any potential risks to your data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.

10. Glossary

LAWFUL BASIS

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.

Performance of Contract means processing your 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.

THIRD PARTIES

Internal Third Parties

Other companies in the Revving Group or connected to Revving who may provide you with access to elements of the Services, such as financial products and services.

External Third Parties

Service providers who provide payment processing services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

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. Further information on this is set out in the Payment Accelerator section.

YOUR LEGAL RIGHTS

You have the right to:

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.

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.

11. Payment Accelerator

In order to provide you with Revving’s Payment Accelerator product, we will make use of Credit Reference Agencies and Fraud Prevention Agencies.

i. What is a credit reference agency?

Credit Reference Agencies (CRAs) collect and maintain information on consumers’ and businesses’ credit behaviour.

ii. What is a fraud prevention agency?

Fraud Prevention Agencies (FPAs) collect, maintain and share, information on known and suspected fraudulent activity. Some CRAs also act as FPAs.

iii. Why do we use them?

If you apply to use the Payment Accelerator, we will check our own records but we will also contact CRAs to get information on your company’s credit behaviour with other organisations. This will help us make the best possible assessment of your company’s overall situation before we make a decision.

iv. Where do we get the information?

1. Publicly available information:

• The Electoral Register from Local Authorities
• County Court Judgments from Registry Trust
• Bankruptcy (and other similar orders) from the Insolvency Service

2. Credit information comes from information on applications to banks, building societies, credit card companies and also from the conduct of those accounts.

3. Company information and information about directors and shareholders comes from Companies House, other publicly available directories and proprietary directories at CRAs.

4. Information about proprietors of non limited businesses from publicly available directories and proprietary directories at CRAs.

v. How will I know if my information is to be sent to a CRA or FPA?

You will be told when you apply for the Payment Accelerator.

vi. Why is my data used in this way?

We and other organisations want to make the best possible decisions we can, in order to make sure that your business is creditworthy. Some organisations may also use the information to check your identity. In this way we can ensure that we all take responsible decisions. At the same time, we also want to take decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.

vii. Who controls what these agencies are allowed to do with my data?

All organisations that collect and process personal data are regulated by the Data Protection Act 1998, overseen by the Information Commissioner’s Office. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act 2000 and the Supplementary Regulations to the Representation of the People Act 2002. Use of data from Companies House, about directors, is controlled under the Companies Act 2006 and The Companies (Disclosure of Address) Regulations 2009.

viii. Can just anyone look at data held at credit reference agencies?

No, access to information is strictly controlled and only those companies that are entitled to do so, may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement it could be done without requiring your consent.

ix. What does Revving check when I apply for the Payment Accelerator?

When you apply to us for the payment accelerator, we may:

1. Check our own records for information on:

a. Your business accounts;

b. Shareholders who are beneficial owners of 10% or more of your business;

2. Search at credit reference agencies for information on:

a. your business;

b. your business accounts;

c. identity information on beneficial owners of your business;

d. If you are a director, we will seek confirmation, from credit reference agencies, that the residential address that you provide is the same as that shown on the restricted register of directors’ usual addresses at Companies House.

e. Search at fraud prevention agencies for information on your business, beneficial owners and your address(es).