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Privacy Statement - Ricochet Technologies Ltd

This Privacy Policy was published on 13th November 2018 and updated on 23rd January 2019.

The team at Ricochet Technologies Ltd (Ricochet) are committed to compliance with EU- General Data Protection Regulation (GDPR) 2016/679, dated April 27th 2016.

The following explains why we collect personal information, when we collect it and how we use it, the conditions under which we may disclose it to others and how we keep it secure.

This Privacy Policy applies to the use of our products and services, and other everyday business activities, such as sales, marketing, contracts and recruitment.

Who are we?

The team at Ricochet builds and delivers automated services for sales prospecting, lead generation and stakeholder engagement.

Our company’s headquarters and registered office is located in Newcastle-upon-Tyne at Studio 4H, Sunco House, 5 Carliol Square, NE1 6UF.

Ricochet Technologies Ltd is registered with the ICO (reference number ZA446186). The data controller and our Data Protection Officer is Kev Price, who can be contacted at privacy@ricochet.ai.

When do we collect personal data about you?

  • When you are using one of our products or services, usually during the onboarding and account creation process;
  • When you interact with us in person, through email correspondence or through our website;
  • When we collect personal information from other legitimate sources, such as our customers, third-party data aggregators, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.

We may collect personal data if it is considered to be of legitimate interest, and if this interest is not overridden by your privacy interests.

Why do we collect and use personal data?

We collect and use personal data mainly to create user accounts for our products and services, create customer profiles, take payments and stay in touch. We may also collect personal data from our customers, public sources or social networks you have given consent to.

We may use your information for the following purposes:

  • Sending you email marketing which you have requested. This requires your consent, and your subscription preferences can be changed at any time;
  • Sending you information about the products and services that you have purchased from us;
  • Performing direct sales activities in cases where you have provided consent, or where legitimate and mutual interest is established;
  • Replying to incoming requests, such as customer support;
  • Providing you with access to our sales prospecting products and services, either on a free, trial or paid basis;
  • Creating a business profile using personal data collected by our customers. We only use this data if you have given your consent to them to share your personal data with others;
  • Performing contractual obligations such as order confirmation, payment, invoice, reminders etc.
  • Conducting customer surveys about our products and services; and
  • Processing a job application.

Our lawful basis for collecting personal data

Collecting personal data based on consent

The collection of personal data based on consent is done by using forms that store documentation related to the consent given by the individual. We typically use these forms during our onboarding process and for creating your account and subscription to email marketing, such as newsletters. Individual consents will always be stored and documented in our systems.

Collecting personal data based on contracting

We use personal information for fulfilling our obligations related to contracts and agreements with customers, partners and suppliers.

Collecting personal data based on legitimate interest

We may use personal data if it is considered to be of legitimate interest, and if the privacy interests of the individuals do not override this interest. Legitimate interest is appropriate when personal data is used in ways that people would reasonably expect and that has a minimal privacy impact.

Typically, the personal data processed by us on this legal basis is either:

  • Publicly available names and business email addresses published on business websites, which have been published in the express interest of encouraging direct contact from third parties, or information published on social media websites;
  • Personal data collected by our customers when the business you represent purchased services from them. We only use this data if you have given your consent to them to share your personal data with others. This data is never shared, sold or traded with any third parties.

Consent is not required by Privacy and Electronic Communications Regulations (as outlined in the ICO’s Direct Marketing Guidance under Business-to-Business Texts and Emails) since the personal data is not subsequently used by us for the purposes of direct marketing.

We consider this use of personal data is proportionate and has a minimal privacy impact. A copy of our most recent Legitimate Interests Assessment (LIA) is available where required.

What type of personal data is collected?

We may collect names and email addresses, in addition to your company’s name and contact information. We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails. From our websites we may collect IP-address and actions taken on the site.

If you apply for a job at Ricochet, we collect the data you provide during the application process. We don’t collect or process any special categories of personal data.

How long do we keep your personal data?

We store personal data for as long as we find it necessary to fulfill the purpose for which the personal data was collected, while also considering our need to answer your queries or resolve possible problems, to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your personal data for a reasonable period of time after your last interaction with us. When the personal data that we have collected is no longer required, we will delete it in a secure manner. We may process data for statistical purposes, but in such cases, data will be anonymised.

Your rights to your personal data

You have the following rights with respect to your personal data:

  • The right to request a copy of your personal data that Ricochet holds about you;
  • The right to request that Ricochet corrects your personal data if inaccurate or out of date;
  • The right to request that your personal data is deleted when it is no longer necessary for Ricochet to retain such data;
  • The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications;
  • The right to request that we provide you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract;
  • The right to request a restriction on further data processing, in case there is a dispute in relation to the accuracy or processing of your personal data;
  • The right to object to the processing of personal data, in case data processing has been based on legitimate interest.

The use of cookies

We use cookies to collect information as you navigate the company’s websites. This usually includes standard information from your web browser, such as browser type and browser language; your Internet Protocol (“IP”) address; and the actions you take on the company’s websites, such as the web pages viewed and the links clicked.

This information is used to make websites work more efficiently, as well as to provide business and marketing information to the owners of the site, and to gather such personal data as browser type and operating system, referring page, etc for the purposes of understanding how visitors use a website.

Cookies and similar technologies help us tailor our website to your personal needs, as well as to detect and prevent security threats and abuse. If used alone, cookies do not personally identify you.

Do we share your data with anyone?

We do not share, sell or trade your information with any third parties without your consent, except in the following instances:

If required by law

We will disclose your personal information if required by law or if we, as a company, reasonably believe that disclosure is necessary to protect our company’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will attempt to ensure that your privacy rights continue to be protected.

Use of data processors

We use data processors to process personal data in order to provide our products and services. We are responsible for making sure they commit themselves to adhere to this Privacy Policy and applicable data protection legislation.

If a data processor processes personal data outside the EU/EEA area, it must be in accordance with the EU Privacy Shield Framework, EU Standard Contractual Clauses for transfer to third countries, or another specifically stated lawful basis for the transfer of personal data to a third country.

As per the requirements of the GDPR, Ricochet only works with processors who can provide sufficient guarantees to meet the requirements of the GDPR. We currently have a Data Processing Addendum (DPA) with the following data processors, which may process your personal data in order for us to provide our products and services:

  • Amazon Web Services (AWS)
  • The Rocket Science Group LLC (trading as Mailchimp)
  • Stripe Payments Europe, Ltd.

Changes to this Privacy Policy

Ricochet Technologies Ltd reserves the right to amend this Privacy Policy at any time. The applicable version will always be found on our websites.

If we make changes that significantly alter our privacy practices, we will notify you by email prior to the change taking effect.