River Software Ltd Privacy Policy

(Last updated 23rd June 2022)

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors, customers and other service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors, individual members, customers and other service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. When you supply personal data to us you may indicate whether you would like to receive direct marketing communications. If you wish to withdraw consent at any time you may unsubscribe using the link at the bottom of the emails you receive or contact our customer service department via hello@teamriver.com

1.5 In this policy, “we”, “us” and “our” refer to River Software Ltd and those acting on our behalf. For more information about us, see Section 17.

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data

(c) the purposes for which we may process personal data and

(d) the legal bases of the processing

2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system, Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.4 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include name, address, telephone number, email address, gender, date of birth, educational details and employment details. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent.

2.5 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.6 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your employer, your job title or role, your contact details, any roles you hold or have held, and information contained in communications between us and you. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.

2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.8 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.9 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.10 We may process information that you provide to us when registering for or attending an event (“event data”). This data may include name, address, contact telephone, email, ICE contact, dietary requirements, institution, date of birth, gender and details of any qualifications you hold. The source of this data is you, or the person who books the event on your behalf. This data may be processed for the purposes of sending you the relevant notifications and/or newsletters, as well as the purpose of supplying the services you have explicitly purchased and keeping proper records of those transactions. The legal basis for this processing is consent.

2.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Providing your personal data to others

3.1 We may disclose your personal data to any employee of River Software Ltd insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.3 We may disclose your personal data, namely your first and last names, email addresses, postal addresses, to our suppliers or subcontractors: WeGift, Sendgrid, Love2Shop insofar as reasonably necessary for the provision of the services you have explicitly or implicitly requested from us, such as registering interest via our website or signing up to our mailing list.

3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4. International transfers of your personal data

4.1 In Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 The hosting facilities for our website are situated in the United Kingdom.

4.3 Our marketing subcontractor, Sendgrid, is situated in The United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each country. Transfers will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission

4.4 You acknowledge that personal data that you submit through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows: Your first name, last name and email address will be retained for a maximum period of 3 years. You have the right to be forgotten at any time and you may do so by emailing us and asking us to remove all data we hold pertaining to you.

5.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6. Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store all your personal data on secure servers, the data will be encrypted at rest

6.3 The following personal data will be stored by us in encrypted form: First and last names, email addresses, postal addresses, mailing list preferences and password details.

6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Your rights

8.1 In Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by email, in addition to the other methods specified in this Section 9.

9. Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10. Personal data of children

10.1 Our website and services are targeted at persons over the age of 18.

10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11. Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12. Acting as a data processor

12.1 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13. About cookies

13.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14. Cookies that we use

14.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: sessionid;)

(b) status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: sessionid;)

(c) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: csrftoken)

15. Cookies used by our service providers

15.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are:_utma, _utmb, _utmc, _utmt and _utmz.

15.3 We do not publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website). You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.

15.4 When you visit our websites, read, click or download information, and receive emailed information from us (e.g. brochures) in response to your requests, we will obtain some information via automated means from or about your device, and about how you use our website. We may also use pixel-tags and cookies that may transfer to the cookie file of your device, depending on the nature of your device. More information about these is set out below. This information helps us so we can improve our site for all our visitors and helps us make ongoing improvements so that the information on our pages can be updated and remains relevant and useful to you.

15.5 Device Data

Device Data that our websites collect include:

Technical information, your internet domain name (this might be your internet service provider, for example, BT, Sky, TalkTalk or your place of work), and Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, (e.g. Google Chrome, Microsoft Edge, Mozilla Firefox), [your device type], time zone setting, browser plug-in types and versions, operating system (e.g. Windows 10, macOS) and platform;

information about your visit (including the full Uniform Resource Locators (URL) clickstream to, through and from our websites (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages, How many and which pages you visit during a ‘session’ on our site and how long you were on the site, and page interaction information (such as scrolling, clicks and mouse-overs).

We may receive information about you if you use any of the other websites we operate or services we provide. We work with third parties (including for example business partners, sub-contractors in technical, payment and delivery services, fraud and authentication support service providers, advertising networks, analytics providers and search information providers, credit reference agencies), and may receive information about you from them.

15.6 Pixel-Tags

We may use “pixel tags,” which are small graphic files that allow us to monitor the use of our websites. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL (Uniform Resource Locator) of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, we may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our e-mail.

15.7 Web Beacons

Some of our Web pages may contain electronic images known as Web Beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web Beacons collect only limited information which includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third party advertisers. These Beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.

15.8 Cookies

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. Cookies can help a website to arrange content to match your preferred interests more quickly – most major websites use cookies. Cookies alone cannot be used to identify you.

A cookie will typically contain the name of the domain from which the cookie has come; the “lifetime” of the cookie; and a value, usually a randomly generated unique number.

Two types of cookies are used on this website:

Session Cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site.

Persistent Cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

How cookies are used on this site and what information is collected.

Session Cookies are used:

To allow you to carry information across pages of our site and avoid having to re-enter information.

Within registration to allow you to access stored information.

Persistent Cookies are used:

To help us recognise you as a unique visitor (using a number, you cannot be identified personally) when you return to our website.

To allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly.

To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally in this way.

To learn more about cookies in general and how to manage them, visit www.aboutcookies.org

16. Managing cookies

16.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en(Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences(Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/(Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies(Internet Explorer);

(e) https://support.apple.com/kb/PH21411(Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy(Edge).

16.2 Blocking all cookies will have a negative impact upon the usability of many websites.

16.3 If you block cookies, you will not be able to use all the features on our website.

17. Our details

17.1 This website is owned and operated by River Software Ltd

17.2 We are registered as River Software Limited, 04243900, England & Wales. Our Registered office address is River Software Ltd, Griffin House, 135 High Street, Crawley, West Sussex, RH10 1DQ

17.3 River Software Ltd, Griffin House, 135 High Street, Crawley, West Sussex, RH10 1DQ

17.4 You can contact us:

(a) by post, to River Software Ltd

River Software Ltd, Griffin House, 135 High Street, Crawley, West Sussex, RH10 1DQ

(b) by email, using hello@teamriver.com

18. Data protection registration

18.1 We are registered as a data controller with the UK Information Commissioner’s Office.

18.2 Our data protection registration number is Z6784034

19. Data protection officer

19.1 Our data protection officer’s contact details are: dpo@teamriver.com