Privacy Policy

Background

Risk Memo Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our websites and iOS and Android applications, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our site AND/OR You will be required to read and accept this Privacy Policy as part of Our Terms of Sale that your are required to agree to when creating an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

"Our Site"

means this riskmemo.com website or any subdomain of this website e.g. app.riskmemo.com and the Risk Memo iOS or Android mobile application registered to Risk Memo Ltd

"Account"

means an account required to access and/or use certain areas and features of Our Site;

"Account Owner"

means the owner/purchaser of a Subscription under which Accounts are assigned;

"Account User"

means the a user of Our Site, for example an employee invited to use Our Site under an Account Owner's Subscription;

"Account Administrator"

means an Account User that has been granted access by the Account Owner to some or all of the data within their Subscription;

"Data Processor/Controller"

Risk Memo Ltd is a Data Processor with respect tour Our Site. The Account Owner is the Data Controller. Click here for EU website examples of both;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by Risk Memo Ltd, a limited company registered in England under company number 10891390.

Registered address: 5 Beech Mews, Davenport Park, Stockport, SK2 6LB.

Representative: Alistair Scott, founder & CEO of Risk Memo Ltd

3. What Does This Policy Cover?

This policy only applies to Our use of your data on Our Site in order to perform our role as "Data Processor". All data within an Account is owned and controlled by the Account Owner, typically your employer, who performs the role of "Data Controller".

If you do not wish to share your personal data with the Account Owner, do not use Our Site.

Risk Memo does not accept any responsibility nor has any control over personal data collected, stored, shared or deleted by the Account Owner on Our Site. For the Account Owner's use of your personal data, you must refer to the privacy policy of the Account Owner.

Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

If you believe the Account Owner is misusing your personal data on Our Site, please contact support@riskmemo.com. We will assist you to the extent to which we are permitted by UK law.

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

The following does NOT include data collected by the Account Owner via their use of Our Site.

Identity Information including name, title, date of birth and gender.

User input by you or your Account Administrator.

Contact information including your address, email address and telephone numbers.

User input by you or your Account Administrator.

Business information including the business name, address, telephone number and your job title.

User input by you or your Account Administrator.

Payment information including card details and billing address.

User input by the Account Administrator via Stripe payment gateway service.

Profile information including your login details and purchase history.

User input by you or your Account Administrator.

Technical information including your IP address, browser type and version, your device type, your use of Our Site including time spent, page visits and actions performed on Our Site.

First and third-party cookies e.g. google analytics – see cookie policy.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following describes how we may use your personal data, and our lawful bases for doing so is with your explicit consent:

Registering you on Our Site and managing your account.

  • Your personal and business identification information, such as names and contact details and business addresses.
  • Payment information and card details.
  • Profile information and login details.

Communicating with you.

  • Personal identification and contact information.
  • Profile and Technical information for automated communications, e.g. push notifications and emails.
  • Business and subscription information

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We do not use automated systems for decision making and/or profiling.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

Due to the nature of Our Site and its purpose of record keeping, we will keep your data until you request it to be deleted.

9. How and Where Do You Store or Transfer My Personal Data?

Some of our service providers (as detailed below) are located outside of the UK and the EU so it may be necessary for the personal data that we collect from you to be transferred to or accessed from outside the UK and EU in order for us to provide our site and service to you. If we do this, we will look to ensure that the data is protected in one of the ways approved under data protection laws and the data will be treated according to the principles set out in this policy.

We use Google firebase services to host and manage Our Site. The majority of Firebase services run on a global Google infrastructure. Google may process your personal data at any Google Cloud Platform location or Google data centre.

All other third-party service providers:

Google Firebase

Hosting, user authentication, app database and file storage

Mail Chimp

Email marketing and customer communications

Intercom

Website chatbot and support site

Stripe

Payment processor

Google Analytics

Website and application anonymous user interaction data collection

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
  • procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
  • All of your data is encrypted.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?

  1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving marketing emails from us which you may do by unsubscribing using the links provided in our emails).
  2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

To use the features and functions available on Our Site you will be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

To access personal data collected by the Account Owner you must contact the Account Owner to request access. Risk Memo will only share or provide copies of data owned and controlled by the Account Owner with the express permission of the Account Owner, or as required by UK law.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for email, website chat services. In addition, Our Site uses analytics services provided by google analytics, which also use Cookies. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling us to better understand how people use OurSite.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, simply start a conversation with the chat bot on this website or email support@riskmemo.com.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

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