KonnekApp Platform Privacy Notice

INTRODUCTION AND PURPOSE OF THIS PRIVACY NOTICE

This privacy notice (“notice”) aims to give you information on how REAS Group Ltd (“we”, “us”,“our”) collects and processes your personal data when:

(i) you use the KonnekApp Platform(“platform”); or
(ii) you download and use our KonnekApp mobile application (“app”).

It will also tell you about your privacy rights and how the law protects you.The platform and the app are not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy notices and is not intended to override them.

THE CONTROLLER AND WHO WE ARE

For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act2018, (collectively the “Data Protection Laws”) the Data Controller is REAS Group Ltd, registered inEngland and Wales under company number 09917141, with registered office address at 3 Charles Pym Road, Aylesbury, Buckinghamshire, HP19 9RY.

YOUR PERSONAL INFORMATION AND HOW WE COLLECT IT

We collect and process some or all of the following types of information from you in the course of your use of the platform and/or app:

● Information that you provide in the course of communications with us. This includes information you provide when requesting further details of our platform or app.
● Information that you provide by filling in forms on the platform and/or app. This includes information provided when you register as a user of the platform or app.

This information includes:
o First Name
o Surname;
o Email address;
o Phone Number;
o Company Name;
o Business Function;
o Job Title; an do Location data.

● The app automatically collects information about the device you use such as the manufacturer, model type, International Mobile Equipment Identity number, and serial number.
● Any information provided by you when using our platform or app and/or making complaints.
● If you contact us, we may keep a record of that correspondence.
● We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
● Details of your visits to the platform and/or app including, but not limited to, traffic data, location data, timestamps, weblogs and other communication data, the resources that you access and the frequency, duration and timing of your access to those resources.

If you have provided us with the personal data of another person, you confirm that they consent to the processing of their personal data and that you have informed them of our identity and the purposes(as set out above or elsewhere) for which their personal data will be processed.Information We Collect From Other SourcesWe may also collect and process limited personal data provided by your employer outside the platform – your name, email address and phone number – in conjunction with information collected by the platform (see above) to allow your employer to identify you in relation to the platform.

USES MADE OF YOUR INFORMATION

Purposes of and lawful basis for processing:
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.

We process your data in order to provide you with our platform and/or app and to perform our obligations and exercise our rights pursuant to either or both of our app end user licence agreement, as presented to you upon installation of the app on your mobile device, and our platform terms and conditions as presented to you when you sign up to use the platform. This includes allowing you to participate in interactive features of our app, when you choose to do so. Performance of a contract is the lawful basis on which we collect and use your personal data for these purposes.

We rely on your consent as the lawful basis:
● to install the app on your device;
● to register you as a user of the platform and/or the app;
● where you have agreed to participate in a survey, and for the processing of such personal information as has been collected through that survey;
● for sending and receiving any of your messages to organisations using the KonnekApp platform; and
● for sharing your data with organisations (defined below).We rely on legitimate interest as a lawful basis for processing to:
● authenticate your account on our platform or app and keep the platform and app secure;
● correspond with you when providing you with materials, offers and information we feel may be of interest to you.
● help you navigate and access resources and services on our platform and/or app, to ensure that content on the platform and/or app is presented in the most effective manner for you and for the device(s) you use to access and view the platform and/or app;
● deal with complaints or to respond to communications from users of our platform and/or app;
● to administer and protect our business, the platform and the app, including troubleshooting, data analysis and system testing; and
● alert you to any news and/or changes to our platform and/or app.

Communicating with organisations: 
We provide certain features that let you communicate directly with and send messages to organisations who use the KonnekApp platform (“organisation(s)”). When you communicate with organisations by sending or receiving messages, we will store and process your communications and information related to them. We share the content of the messages with the organisations you have sent them to.We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURE OF YOUR INFORMATION

We will only share your information with third parties listed below for the purposes described above in the “Uses made of your information” section. If you are a user of the app and have consented within the app for us to share your data with organisations, then we will share that data with the organisation(s) for whom you have given your consent. We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UKCompanies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

● in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
● if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets; or
● if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
● to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with to provide the platform and/or app; or
● in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties without giving you notice.

STORING YOUR PERSONAL DATA

SecurityWe take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also depend on you to protect your information. Where required, please set up a strong password and keep it confidential. If you become aware of any breach of security, please notify us immediately.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the platform or app; any transmission is at your own risk.

The platform and/or app may, from time to time, contain links to and from the websites of third party organisations, our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and terms of use and that we do not accept any responsibility or liability for these policies and terms of use. Please check these policies before you submit any personal data to these websites.Keeping your personal data up to dateIt is important that the information you provide to us is accurate and up to date, and that you inform us without delay of any significant change.If your personal details change you may update them by contacting us using the contact details below.We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In particular:

● Where we hold your personal data subject to a legal requirement (e.g. as required by HMRC),we will hold your data with the relevant legally required period.
● Where we hold your personal data in connection with the performance of a contract with you, we will hold your data for so long as that contract is in force.
● Transaction records containing personal data will be held for a period of seven (7) years.
● All correspondence may be retained for at least 2 years after you last communicated with us.
● Data such as IP addresses will be retained for a period of 1 year from its first entry into our logs or longer if required in our performance of a contract with you.
● Data collected in relation to your interaction (such as ‘clicks’) with content on our platform and/or app shall be retained indefinitely and aggregated into non-personal and statistical data on expiry of the retention period for the IP address associated to such data.

If you have consented to sharing your data with any organisation(s), we advise that you check the privacy/data protections policies for such organisation(s) for information on how they process the data we have shared with them.

Where we store your personal data:

All information we hold about you is stored on secure servers in the United Kingdom.

The data that we collect from you may be transferred to, and stored at, a destination outside theUnited Kingdom or European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to appropriate safeguards (as permitted under Article 46(5) of theGeneral Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge.In summary, those include rights 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.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:
• email, call or write to us (contact details provided below),
• let us have enough information to identify you (e.g. name, login details),
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• let us know the information to which your request relates, including any account or reference numbers, if you have them.

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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information.The supervisory authority in the UK is the Information Commissioner who may be contacted athttps://ico.org.uk/concerns/ or telephone: 0303 123 1113.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES


We may collect information about your mobile phone, computer or other device from which you access the platform or app including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our platform and/or app.

Our platform and app uses cookies to distinguish you from other users of our platform. This helps us to provide you with a good experience when you use the platform and also allows us to improve the platform.

By using our platform and/or app you agree to our use of cookies as more specifically set out below. A cookie is a small file of letters and numbers that we store on your browser or device if you agree.

The cookies we use include:
● “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the platform and/or app when they are using it. This helps us to improve the way the platform and/or app works, for example, by ensuring that users are finding what they are looking for easily.
● “Strictly necessary” cookies. These are cookies that are required for the operation of our platform and app. They include, for example, cookies that enable you to log into secure are as of our platform and app.
● “Functionality” cookies. These are used to recognise you when you return to our platform or app. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
● “Targeting” cookies. These cookies record your visit to our platform and/or app, the pages you have visited and the links you have followed. We will use this information to make our platform or app, offers e-mailed to you and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You may block cookies by activating the setting on your browser or device that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies(including essential cookies) you may not be able to access all or parts of the platform or app. Unless you have adjusted your browser or device settings so that it will refuse cookies, our system will issue cookies as soon as you visit our platform or app.

CHANGES TO OUR PRIVACY NOTICE

We reserve the right to modify this notice at any time.

Any changes we may make to our notice in the future will be notified to you.

CONTACT

All questions, comments and requests regarding this notice should be addressed toprivacy@reas.group.

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