DATA PROTECTION AND PRIVACY POLICY

Effective Date: 2 July 2020

INTRODUCTION

Rezolve Limited. (we), are committed to protecting and respecting your privacy. 

This policy applies to personal information we collect from you, or that you provide to us, in connection with your use of the Rezolve app (the App) and any Services offered by us through the App (the Services). We need this personal information in order to ensure that the App and the Services offer you the best possible experience using Rezolve. Whenever we collect and process personal information from you, we will only use it responsibly and in accordance with applicable laws and with your benefit in mind, to continually improve your Rezolve experience.

By accessing and/or using the App and its Services you consent to us collecting, using, storing and sharing your personal information in the ways set out in this policy.

As explained in more detail below, please note that you permit us to share certain information with third parties. This includes third parties who make their products or services available to you through the App (Third Party Providers). Third Party Providers are not under our control and process your personal information in accordance with their practices and privacy policies (if any); we are not responsible for and do not endorse their content or their privacy policies (if any). You will need to make your own independent judgement regarding your interaction with any Third Party Providers including the purchase and use of any products or services accessible through them, therefore please review their privacy policies for information about their own privacy practices.

The App is not permitted for use by children under 13 years of age. We do not knowingly solicit data online from, or market to, children under 13 years of age.

We may amend this policy by posting a revised version on www.rezolve.com so we recommend that you check the current version available from time to time. If we do make changes to this policy, we will update the ‘Effective Date’ at the top of this page and the revised version will be effective from the date posted. However, we will give you 30 days’ prior notice of any substantial or material changes to this policy by posting notifications on or otherwise communicating the notification to you in accordance with our terms of service for the App (Terms of Service). If you do not accept any amendment to the policy then you should stop accessing and using the App and close your account in accordance with the procedure set out in the Terms of Service; you should do this immediately or, where you have received 30 days’ prior notice, before those 30 days expire. Your continued use of the App will be deemed your acceptance of any updated policy. Please note that for the purpose of this section, a “substantial” or “material” change means a change which we believe in our reasonable opinion to either reduce your rights or increase your responsibilities but which does not simply relate to a new product or services nor a change we are required to make to comply with applicable law.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

  • Registration information: We will collect various personal information which you choose to provide when you register with us (including your name, mobile phone number, email address, date of birth and payment details).
  • Device information: We may collect information about the mobile telephone, tablet or other device (Device) you may use to download the App, including, where available, the Device’s identifiers, operating system, browser type and network information. From time to time we may associate Device information with registration information and will treat the combined information as personal information in accordance with this policy for as long as it is combined.
  • Location information: The App and Services include geolocation and location presence awareness technology and functionality which require access to your location data. You will be asked to provide your consent before we collect and process your location data and you can withdraw your consent to this at any time by disabling the location services option for the App within the settings on your Device.
  • Log information: When you use the Services or view content on sites operated by Third Party Providers, we may automatically collect and store certain information in server logs, including but not limited to products you viewed or searched for, internet protocol (IP) addresses, internet service provider (ISP), clickstream data, browser type and language, viewed and exit pages and date or time stamps. We may also create a unique device ID and unique user ID as part of the authentication process for your use of the App and you hereby consent to us using your information for this purpose.
  • Additional information:
  • if you contact us or members of our corporate group entity, for example if you report a problem with the App, we may keep a record of that correspondence;
  • information you voluntarily provide to us in response to any surveys, competitions or promotions;
  • loyalty card information relating to a third party loyalty scheme which you may choose to provide to facilitate loyalty card benefits by using the App and its Services; and
  • we may also collect information about you from third parties such as details of transactions you carry out through any Third Party Providers, including any transactions which you have commenced but not completed.

HOW WE STORE YOUR PERSONAL INFORMATION

By allowing us to release your personal information to a Third Party Provider, the data that we collect from you may be transferred to, and stored at, a destination outside your country of use/residence. It may also be processed by staff operating outside your country of use/residence who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services.

We take all steps reasonably necessary to ensure that your data is treated securely. In particular, all information you provide to us is stored on secure servers and any information we process relating to your payment transactions will be sent over an encrypted connection or other secure network to Third Party Providers. We also adopt strict procedures and security features to prevent unauthorised access as outlined in our Rezolve Security Policy, a printed copy of which can be requested via support@rezolve.com.

You should also be aware, however, that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data during its transmission to Third Party Providers; any transmission is at your own risk.

We will not keep personal information any longer than is necessary for the fulfilment of the purposes set out below.

USES MADE OF THE INFORMATION

We may use your data for the following purposes:

  • For our business purposes, such as data analysis, audits, developing new products, operating and improving the App and its Services, identifying usage trends and determining the effectiveness of our communications;
  • To personalize your experience on the App or through its Services by presenting information tailored to you and to your geographic location This is intended to make the App more useful to you, for example by allowing us to send notifications to your Device using the signal of any ‘Rezolve Beacon’ devices which have been deployed within range of your location;
  • To provide customer service, including to respond to your enquiries and fulfil any of your requests for information;
  • To send you important information regarding the App and/or other technical notices, updates, security alerts, and support and administrative messages;
  • To send you marketing or promotional information about services or products that may be of interest to you, including where we e-mail you such information on behalf of Third Party Providers.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from law enforcement and other government authorities including public and government authorities outside your country of residence; (d) enforce or apply this policy or the App’s end user licence agreement (EULA); (e) to protect our rights, privacy, property or safety, and/or that of our affiliates, you or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain; and
  • In any other way that is envisioned by this privacy policy or the EULA.

DISCLOSURE OF YOUR INFORMATION

In order to fulfil the purposes set out above, we may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as well as any of our strategic business partners or third party agents, contractors or service providers under contract who provide business operations support such as credit reference and fraud prevention activities. Our service agreements with those third parties dictate that they only use your personal information strictly in connection with the services which they are contracted to perform for us.

We may disclose your personal information to a Third Party Provider (including, where relevant, the payment service provider of that Third Party Provider) so that they can fulfil any requests or orders which you have initiated, for example where you wish to purchase certain goods or services from that site. Please note, however, that your personal information may then be used by the third party in accordance their own privacy policy (for example, to contact you pursuant to your interactions with them) and so you will need to review the privacy policy of that third party for information about their privacy practices.

We may also share your personal information with a Third Party Provider in relation to user interaction with the App or its Services, for example in order to help them improve their understanding of user trends, preferences and behaviour and the quality of the services they deliver.

Finally, we may disclose your personal information to the following third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal information – but never any sensitive payment card data – to the prospective seller or buyer of such business or assets;
  • if Rezolve Limited. or substantially all of its assets are acquired by a third party, in which case personal information held by it about its users will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request;
  • we believe in good faith that the disclosure of the information (including personal information) is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to enforce, act in compliance of, or investigate violations of, the Terms of Service; or
  • if you have otherwise provided your consent to such disclosure.

Please note that we do not disclose your personal information to any third parties except as set out in this privacy policy.

YOUR RIGHTS

You have the right to ask us not to process your personal information for direct marketing purposes and the ‘the right to be forgotten’, for us to remove your personal data if you feel it is no longer necessary to use our services. You can exercise the right at any time by contacting us at support@rezolve.com or our registered business address.

LINKS TO OTHER SITES

Our websites may, from time to time, contain links to and from the websites of other networks, advertisers and affiliates (including, but not limited to, websites on which the App or its Services are advertised). If you follow a link to any of these websites, 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 information that may be collected through these websites or services. Please check these policies before you submit any personal information to these websites or use these services.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@rezolve.com.