Privacy Policy

Consent to process data prior to creation of App account‍

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our Privacy Policy and it is important that you read that information. 

Before creating a Renbee account, please indicate your consent to our processing of your personal data (including your name, contact details and device information) in accordance with our Privacy Policy. 

YES I consent to the processing of my personal data whilst using the Renbee App.

NO I do not consent to the processing of my personal data whilst using the Renbee.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us using the contact details provided in our Privacy Policy but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

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PRIVACY POLICY (RENBEE APP AND WEBSITE)

Introduction 

This privacy policy applies to your use of the Renbee web-based application software (which was last updated on 4 September 2023) (App) and our website (https://www.renbee.co.uk/) (Website), once you have downloaded or streamed a copy of the onto your mobile telephone or handheld device (Device).

Any of the services that are available on the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App and Website is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below. 

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED?

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

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Important information and who we are

Renbee Limited is the controller and is responsible for your personal data  (collectively referred to as "Renbee", "we", "us" or "our" in this policy

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

If you have any questions about this privacy policy, please get in touch using the details set out below:

• Name or title of data privacy manager: Tejus Patel
• Email address:   tej.patel@renbee.co.uk
• Postal address: Renbee Limited, 2 Arundel Street, 180 Strand, London, United Kingdom, WC2R 3DA

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. 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 and your duty to inform us of changes

We keep our privacy policy under regular review. 

This version was last updated on 4 September 2023. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App.

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 our relationship with you. 

Third party links

Our App may, from time to time, contain links to and from the websites of third party manufacturers, our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data: includes your first name and last name.
• Contact Data: email address and telephone numbers.
• Workplace Data: includes your position/title, accreditations/qualifications and details about the organisation that employs you.
• Transaction Data: includes details about any payments you may make through           Stripe (our payment processing service provider]. This includes details about products and services you have purchased from a third party manufacturer through using the App or details about any payments made to us.
• 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 Device you use to access the App or Website.
• Content Data: includes the types of content that you view on the App or Website.
• Profile Data: includes your username and password, your interests, preferences, feedback and survey response.
• Usage Data: includes information about how you use the App, Website and Services.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes information about where you access our App or Website from. 

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 App 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.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register or subscribe to use the App, utilise the App, Website or any of our Services, and when you report a problem with the App, Website or our Services. If you contact us, we will keep a record of that correspondence. 
• Information we collect about you and your device. Each time you visit the App or Website, we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
• Making purchases using the App. Each time you make a purchase we collect and store Transaction Data. 
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings. 
• Information we receive from other sources including third parties and publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

• Device Data from analytics providers such as Google based outside the UK;
• Contact and Transaction Data from providers of payment services such as Stripe, Inc based outside the UK. Stripe’s privacy policy can be accessed here.
• Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.

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Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App or Website and to remember your preferences. This helps us to provide you with a good experience when you use the App or Website and also allows us to improve them. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances: 

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered 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 or regulatory obligation. 

Click here to find out more about the types of lawful basis that we will rely on to process your personal data. 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. 

Purposes for which we will use your personal data

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table [Purposes for which we will use your personal data]:

• External Third Parties as set out in the Glossary.
• Allies Computing Limited (trading as Postcoder), a company that provides an address lookup functionality within the App. Postcoder’s privacy policy can be found here.
• 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.

International transfers

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

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 

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

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by Stripe, Inc, our chosen third-party provider of payment processing services will be encrypted using Transport Layer Security technology.

Where you have chosen a password that enables you to access the App or Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way (e.g. by segregating personal data collected). 

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

Details of retention periods for different aspects of your personal data are available upon request.

By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see Your legal rights 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. 

In the event that you do not use the App for a period of 2 years we will treat the account as expired and your personal data may be deleted six years thereafter.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 

Please click on the links below to find out more about these rights: 

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer or your personal data.
• Right to withdraw consent. 

You also have the right to ask us not to continue to process your personal data for marketing purposes. 

You can exercise any of these rights at any time by contacting our data privacy manager.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience on our App. 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

External third parties

Service providers acting as processors based in the United Kingdom who provide IT and system administration services.

Distributed Network Operators, Electrical Standards Agencies and other related regulatory, governmental or professional bodies based in the United Kingdom.

Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.

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:

1. if you want us to establish the data's accuracy;
2. where our use of the data is unlawful but you do not want us to erase it;
3. 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; or
4. 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.