Effective Date: October 1, 2019
Last Updated on: December 10, 2020
Capitalized terms used in addition to terms defined elsewhere in this Policy, shall have the following meanings:
"Controller" means the natural or legal person, public authority, agency, or other body which alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“End-User” means any person or entity with whom the Subscriber interacts using the Service(s).
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller.
“Service(s)” shall have the meaning as defined in the Terms.
“Subscriber” means the natural or legal person that has subscribed to the Service(s) by agreeing to the Terms.
“Website” means the websites that Revv operates including www.revv.so
2.1 Some of the data that We collect is provided by the User while they use Our Service(s) or access, use or submit information on Our Website. This may include:
Account information entered during the creation of accounts like User’s name, email address, and phone number.
Public profile information including User’s profile picture, gender information, social preferences, etc., if they choose to register on Our Website or comment on Our blogs through any social media account.
Feedback that the User provides on Our Website or with respect to Our Service(s).
Any data which the User enters while registering to Our events, including filling of web forms, participating in surveys, contests, promotions, and communicating with Us in any manner. We may also collect some data if the User attends Our sponsored events to send communications or any updates to them.
2.2 Users are requested not to provide sensitive personal information (personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, or biometric data for uniquely identifying a natural person, information concerning health, or information concerning a natural person’s sex life or sexual orientation).
2.3 Further, while availing Our Service(s), Revv will act as a Processor while Processing most forms of Personal Data.
3.1 While the User accesses or browses Our Website, or uses Our Services, We collect some of the data automatically in Our servers through cookies or web beacons on Our website.
Cookies and Web logs - The data that We collect through these cookies and log files include:
IP address, location, browser type referring/exit pages, operating system, date/time stamp, and clickstream data.
Usage Data, language preference, usage timings, search keywords, page views (collectively, “Usage Data”)
Feedback that the User provides on Our Website or with respect to Our Service(s).
If the User subscribes to Our Service(s) and installs Our Software or mobile application, if any, on their devices, We may collect their device information and operating system information to perform Our obligations under the agreement.
3.2 In addition to the above, We may also collect data that a User shares pursuant to use of third-party technical service providers as listed in section 7.
We collect and Process the User’s data for the following reasons:
For registration and authentication, which allows Us to identify Users and give Users access Services.
For tag management which helps Revv to manage the tags or scripts needed while using Our Services in a centralized fashion.
To personalize Our Websites and/or Services to the User.
To improve Our Websites and/or Services.
To allow Us to respond better to User service requests, and facilitate User access to Our Websites and/or Services.
For marketing and advertising purposes in compliance with applicable laws.
To display personal testimonials of customers on Our Site in addition to other endorsements. If the User wishes to update or delete their testimonial, the User can contact Us at email@example.com.
To administer a promotion, survey, or other feature.
To process and complete payment transactions;
To send periodic emails regarding other products and services.
To investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities.
To comply with legal requirements.
For analytics, which will enable Us to monitor and analyze web traffic and can be used to keep track of User behavior.
For heat mapping and session recording which are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are.
For remarketing and behavioral targeting, which allows Us and Our partners to inform, optimize, and serve advertising based on past use of Our Services by the User.
We do not sell, trade, or otherwise transfer a User’s Personal Data except in accordance with this Policy. Except as necessary to provide Our Service(s) to the User, We do not share the Personal
Data We receive from the User unless:
We have their separate and explicit permission to share that information; or
We have given them prior notice that the information will be shared, and with whom (such as in this Policy)
We are required to comply with applicable law or regulation, or to comply with law enforcement;
We are required to respond to claims and/or legal process or requests;
A need arises for Us to protect Our rights or Our property, or to enforce Our Terms of Service;
We are to help ensure the safety of the public or an individual;
We are to prevent behavior that is (or that We think may be) illegal or unethical;
We may also share the User’s Personal Data with third-party service providers that provide email address management and communication contact services, network equipment and application management providers and hosting entities, credit, and debit card payment gateways and processors and other service providers which may be involved in the other types of services and activities as part of Our Services.
We may also share the User’s Personal Data with service providers who assist us with our marketing and advertising as outlined in this Policy. Note that We do not share Personal Data about Users with third parties for their own marketing purposes unless the User has agreed to that sharing.
The User can choose to provide explicit consent to connect their email accounts with their Account. Once connected, We will securely access and analyze the relevant content related to the Services provided by Us. We encourage the User to review their Personal Data prior to signing in through the applicable service. We do not under any circumstances store the User’s email messages, email messages headers, message bodies, or attachments. We only access the User's email account for scanning purposes and display information immediately as it is returned. We request read-only access to the User’s email account, and will not attempt to alter or modify User’s email account or email messages in any way, except as otherwise agreed by the User through additional consent.
Further, Our Site includes social media features and widgets that are either hosted by a third-party or hosted directly on Our Site; User’s interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. The User should check their privacy settings on these third-party services to understand and change the information sent to Us through these Services. This data may be combined with the other information We collect and might include aggregated levels of specific data.
If the User is a Data Subject from the European Economic Area, Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which We collect it. We will normally collect Personal Data from the User only where it is needed to perform a contract with the User, where the Processing is in Our legitimate interests and not overridden by the User’s data protection interests or fundamental rights and freedoms, or where We have the User’s consent. In some cases, We may also have a legal obligation to collect Personal Data from the User. If We Process User Personal Data with reliance on their consent, the User may withdraw their consent at any time. If the User has questions or needs further information concerning the legal basis on which We collect and use their Personal Data, please contact Us at the addresses set forth in section 13.
We shall delete all customer data submitted to the Services in accordance with the Terms. Personal Data shall be processed and stored for only as long as required by the purpose they have been collected for. Personal Data collected for purposes related to the performance of a contract between Revv and the User shall be retained until such contract has been fully performed. Data collected for the purposes of Revv’ legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Us within the relevant sections of this document or by contacting us.
Revv may be allowed to retain certain data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for defense of legal claims, for the performance of a legal obligation, or upon order of a government or judicial authority.
Revv is committed to protecting the Personal Data the Users share with Us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures, as mandated by law, to help protect Personal Data from unauthorized access, use, or disclosure.
We recommend all Users take every precaution in protecting their Personal Data when they are on the Internet. For example, change passwords often, use a combination of letters and numbers when creating passwords, and make sure a secure browser is used. If the User has any questions about the security of their Personal Data, they can contact Us at firstname.lastname@example.org.
Users may exercise certain rights regarding their data processed by Revv. Any requests to exercise User rights can be directed to the Us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Us as early as possible and always within one month. In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if data is being processed by Revv, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, Revv will not process their data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from Revv’s records.
Receive their Data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Any Personal Data that a User provides to Us when interacting with Our Services or Websites will be transferred to the USA and India. In the event a user enters Personal Data through Our Services, then this Personal Data may be transferred to or another country where We have engaged a sub-processor which We operate the Service. The information that We collect from the User may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be Processed by staff operating outside the EEA who work for Us or Our partners. If a User is a resident of the European Economic Area and when their Personal Information is Processed outside EEA, We will ensure that the recipient of the User’s Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or We will ask the User for their prior consent to such international data transfers.
Where the Services are made available to an End-User through a Subscriber, that enterprise is the Controller of the End-User’s Personal Data. In such a case, the End-User’s data privacy questions and requests should be submitted to the Subscriber in its capacity as the End-User’s Controller. If the End-User is an individual who interacts with a Subscriber using Our Services, the End-User will be directed to contact Our Subscriber for assistance with any requests or questions relating to their Personal Data. We are not responsible for Subscribers’ privacy or security practices which may be different from this notice. Subscribers to Our Services are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of Personal Data in connection with the use of Our Services by End-Users.
With the exception of Personal Data collected when a User registers for an account to access or utilize Our Service(s) and other information We collect in connection with their registration or authentication into Our Service(s), this Notice does not apply in connection with access and use of Our Service(s). The security and privacy practices, including how We protect, collect, and use electronic data, text, messages, communications, or other materials submitted to and stored within the Service(s) by the User, are detailed in and governed by Our Terms or such other applicable agreement between the Subscriber and Us relating to the access to and the use of such Services.