External Privacy Notice
1 Introduction
1.1 At Re-Invent, we recognise and respect the importance ofprotecting the privacy of our customers.
1.2 This Privacy Notice describes how Re:Invent (“we”, “our” or “us”) collects and processes personaldata about you through visiting or using www.reinventecom.com (“Website”), communications with us and engaging in our dual brandingmarketing service which matches retail companies and organisations (“Brands”) based on complimentary customer bases of eachof the Brand (“Services”) as our web application offers (“Web App”).
2 What we are responsible for
2.1 Re:Invent is only responsible for any processing of personal datacollected through your use of our Website or where you, as a representative ofone of our Brands, enters into a contract with us. We are the data controller andresponsible for how and why your personal data is collected and for protectingit. This Privacy Notice applies only to instances where we act as a datacontroller.
2.2 When we offer our Services to Brands, through third party eCommerceplatforms such as Shopify and Klaviyo, the Brands to which we are providing ourServices, will provide us with certain personal data which we will process onthe Brand’s behalf. This may include personal data about a Brand’s end users.In such instances, Re:Invent acts as a data processor, and we have contractuallycommitted ourselves to process your personal data on behalf and under theinstruction of the respective Brand, who is the data controller. The Brand willbe responsible for protecting, keeping and using your personal data in linewith data protection laws and if you have any queries in relation to this,please contact the Brand in question.
2.3 If you have any questions about this privacy policy or our privacy practices, please contact us by email at bryn@reinventecom.com
3 The personal data we collect and how
3.1 We collect personal data about you from a variety of sources, including:
3.1.1 from you directly when you use our Website or contact us;
3.1.2 from information we generate about you during our relationship with you, such as technical data collected from user behaviour and analytics; and
3.1.3 from information we collect about you from other sources, such as the Brands that we provide Services to and third parties eCommerce platforms such as Shopify and Klaviyo (“eCommercePlatforms”). The sources also include publicly available sources such associal media sites.
3.2 Depending upon your use of our Website and Services, we may collect and hold some or all of the personal and non-personal data set out in the table below.
3.3 You may also interact with other third party providers who process additional data outside that which is listed within the table below, where this is the case your data is not processed or seen by us.
1 How we use your personal data and the basis on which we use
To allow you to browse our Website and contact us
● personal and contact details; and
● technical information collected from your computer or mobile device when browsing our Website.
We use your personal data to ensure we can run our business, by enabling you to browse our Website and contact us about our Services. We also use your data where it is necessary to verify your identity, to satisfy legal or regulatory requirements to which we are subject or to exercise our legal rights. For example, to detect, prevent and respond to fraudulent activity and claims e.g. intellectual property infringement claims, violations of law or our Terms and Conditions.
It is in our legitimate interest to operate our business in an efficient, safe and lawful way and protect it from fraudulent or other unlawful activity. In some case, we are under a legal obligation (whether by a regulatory authority or a court order) to conduct certain checks.
● To allow you to log in to our Web App to access the Services:
● To allow you to log in to our Web App to access the Services:
● communications with us
● technical information; and
● information generated about you.
We use your personal data to allow you to log in via the Website to be re-directed to the Web App where Brands have access to the Services.
It is on the basis that we have a contract with your business to fulfil our obligations in providing you the Services.
To inform you about us, our events or other news that may interest you
● personal and contact details.
We use your personal data to better understand your preferences and to personalise the messages we send to you. This includes sending you information about other services we may offer, discounts and news or events that we may hold from time to time.
This is on the basis of your consent and you may opt out at any time.
To improve our business
● personal and contact details;
● communications with us
● technical information; and
● information generated about you.
We analyse information about how you use our Website and Services to provide an improved experience for the users of our business. We may use your data for testing and development, site analytics.
This is on the basis of your consent and you may opt out at any time.
5.1 We may share your personal data with third parties under the following circumstances:
5.1.1 We share your personal data with our service providers and business partners. The third parties in question belong to the following categories:
5.1.1.1 Professional service providers, such as messaging services, IT software providers, customer services, marketing and research agencies, profile and behavioural analytics companies and website hosts who help us to run our business and carry out our Services– for example, Microsoft Clarity for user behaviour and Website debugging analytics.
5.1.1.2 Credit reference agencies, law enforcement and fraud preventionagencies, so we can help tackle fraud.
5.1.1.3 Governmental bodies and regulators to comply with our legal obligations.
5.1.2 As required by law
5.1.2.1 We may share your personal data with law enforcement agencies, courts, other government authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
5.1.3 In the context of a transaction
5.1.3.1 We may share your personal data with potential partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal data to use it in a manner that is consistent with this Privacy Notice.
6 Information Security and Storage
6.1 We implement physical, technical, and organisational security measures designed to safeguard the personal data we process through our Services. These measures are aimed at providing on-going integrity and confidentiality for your personal data. We evaluate and update these measures on a regular basis. However, no information system is impenetrable, so we cannot guarantee the absolute security of your information.
6.2 We retain your personal data for in line with our company retention policy, as required to comply with any legislation, to investigate or defend against potential legal claims and to help us prevent fraudulent activity e.g. trying to open multiple accounts. We only retain information for as long as it is required.
7 International Data Transfers
7.1 In some cases, your personal data will be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal data as the UK.
7.2 We will put in place appropriate safeguards (such as regulator approved standard contractual terms) to provide adequate protection for your personal data in accordance with applicable legal requirements. For more information on these safeguards or to obtain a copy of such safeguards, please contact us as set out above.
8 Your Rights
8.1 You may, in certain circumstances, have rights regarding the personal data we hold about you. These may include the rights to access, correct, delete, restrict or object to our use of, or processing of your personal data. You also may request to receive a portable copy in a usable electronic format of your personal data. Where you have provided your consent to any use of your personal data, you can withdraw this consent at any time.
8.2 We encourage you to contact us as above to update or correct your information if it changes or if the personal data we hold about you is inaccurate.
8.3 Please note that we may require additional information from you in order to honour your requests. There may be situations in which we will not be able to comply with your request due to our legitimate interests or regulatory obligations to governmental bodies.
8.4 If you would like to discuss or exercise any rights you may have, please contact us using the contact details provided above. If you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the UK data protection regulator, the Information Commissioner’s Office, https://ico.org.uk/ .
9 Changes to the Policy
9.1 We may modify or update this Privacy Notice from time to time. If we make any revisions that materially change the ways in which we process your personal data, we will notify you of these changes before applying them.
Last Updated: 15 August 2023
