Reva App Limited respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data when you visit our website and/or use our “Banish” app (regardless of where you visit it from) and will inform you about cookies and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this policy.
1. Important information and who we are
Purpose of this policy
This policy, together with our terms and conditions as set out here aims to give you information on how Reva App Limited collects and processes your personal data through your use of our website and or our app, including any data you may provide through them when you sign up or subscribe. It will also inform you what cookies are and why they are used.
It is important that you read this policy together with any other policy 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 policy supplements other notices and privacy policies and is not intended to override them, and applies to your use of our website and our app, once it has been downloaded to your mobile telephone or handheld device (“Device”).
Neither our website or our app are intended for children, and we do not knowingly collect data relating to children. If you become aware of any child accessing our website and/or app and potentially providing personal data without the consent of their parents, please contact our outsourced Data Protection Officer using the details set out in the “Contact details” section below.
Please read the following carefully to understand how we will use and treat your personal data.
Reva App Limited is the controller and responsible for your personal data (collectively referred to as “Reva App Limited”, “we”, “us” or “our” in this policy).
We have appointed an outsourced Data Protection Officer who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this policy or our privacy practices, please contact our outsourced Data Protection Officer using the following contact details:
Email address: firstname.lastname@example.org (please add “Reva App” to the email subject line)
Postal address: GDPR Assist UK Ltd., Unit B, Lostock Office Park, Lynstock Way, Lostock, Bolton, BL6 4SG
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance if there is an issue which we can help you with in relation to our use of your personal data.
Changes to the policy and your duty to inform us of changes
We keep our policy under regular review. This version was last updated on December 2020. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you in other ways including via a push notification or when you next start our app. Any new policy may be displayed on-screen and you may be required to read and accept any changes to continue your use of the App.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website and our app may include links to third-party websites, platforms, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, platforms, plug-ins and applications and are not responsible for their privacy and cookie statements. When you leave our website or our app, we encourage you to read the privacy and cookie policies of every website, platform, plug-in or applications you visit before you submit any personal data to them.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Health Data includes information relating to your mental health, your levels of activity and calories burned during a workout.
- Contact Data includes billing address, email address and telephone numbers.
- Content Data includes information stored on your Device, including friend lists, login information, photos, videos or other digital content, check-ins,
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes (but is not limited to) internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and our app, the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of its wireless network interface or its mobile phone number), mobile network information, your mobile operating system, the type of mobile browser you use or time zone settings.
- Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, our app and our services including, but not limited to, traffic and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data includes your current location disclosed by GPS or other technology.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data (including your Health Data) but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.
Other than the Health Data (set out above) we do not collect any other Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We also do not collect data about your physical health, or any medical condition, and you must ensure any activities are appropriate for you.
In order to provide our services, such as recommending classes you may enjoy, we may read and/or write data to your Device with your consent. We will not use this information for marketing or advertising purposes or share it with any third party without your specific consent.
With regard to Health Data, we collect we ask for your explicit consent to process that data. We obtain this consent separately for example when you sync your device to your account or grant us access to your exercise or activity data from a service we provide. You can withdraw your consent at any time
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Health, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website and/or our app, we will automatically collect Technical Data about your Device, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Location Data We may use GPS or other technology to determine your current location if we introduce new features into our app. Some of these services may require your personal data to be able to work. If you wish to use them, you will be asked to consent to your personal data being used for this purpose, and can withdraw your consent at any time by disabling Location Data in your Device’s settings. .
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks; and
(c) search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services including, but not limited to, Stripe (www.stripe.com).
- Identity and Contact Data from data brokers or aggregators.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into 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 obligation.
- Where you have consented to our doing so.
Please see below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of personal data||Lawful basis for processing including basis of legitimate interest|
|To install the App and register you as a new user||Identity Contact Financial Technical||Performance of a contract with you|
|To process in-app purchases and deliver your services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||Identity Contact Financial Transaction Technical Marketing Communications Location||(a) Performance of a contract with you (c) Necessary for our legitimate interests (to recover debts due to us)|
|To enable you to partake in a beta or other test of our products and services, prize draw, competition or complete a survey||Identity Contact Device Profile Marketing Communications||(a) Performance of a contract with you (c) Necessary for our legitimate interests (to study how users use our products/services, to develop them and grow our business)|
|To administer and protect our business, our website and our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity Contact Device||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity Health Contact Device Content Profile Usage Marketing Communications Location||(a) Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy) (b) Consent in relation to Health Data|
|To use data analytics to improve our website, app, products/services, marketing (including via case studies, investor and other presentations), user relationships and experiences||Identity Health Contact Device Content Profile Usage Marketing Communications Location||(a) Necessary for our legitimate interests (to define types of users for our products and services, to keep our website and/or our app updated and relevant, to develop our business and to inform our marketing strategy) (b) Consent in relation to Health Data|
|To make suggestions and recommendations to you about products or services that may be of interest to you and to promote our business and services to third parties||Identity Health Contact Device Content Profile Usage Marketing Communications Location||(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent in relation to Health Data|
If we rely upon consent as our lawful basis for processing your Personal Data and our purposes for processing changes, we will inform you and obtain your consent again before any further processing takes place.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website and app. They include, for example, cookies that enable you to log into secure areas of our website and app, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website and app when they are using it. This helps us to improve the way our website and app work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website and 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 website and app, the pages you have visited and the links you have followed. We will use this information to make our website, our app and the advertising displayed on or through them more relevant to your interests.
We will ask for your consent to install any cookies which are not strictly necessary
Change of purpose
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 get 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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
We do not transfer your personal data outside the European Economic Area (EEA)
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
All personal data which you provide to us is stored on our secure servers, and is secured at rest by Amazon Web Services, who provide hosting services to us. Your Personal Data is encrypted between your device and any external hosting storage via Hypertext Transfer Protocol Secure (“HTTPS”), which is a more secure method of the standard “HTTP”” protocol used to send data between browsers apps, and devices. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our website or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
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.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our users (including Contact, Identity, Financial and Transaction Data) for six years after they cease being users for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use our App for a period of more than 12 months, then we may treat the account as expired and your personal data may be deleted.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”).
Request correction of the personal data that we hold about you.
Request erasure of your personal data.
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.
Request the transfer of your personal data to you or to a third party.
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 services to you. We will advise you if this is the case at the time you withdraw your consent.
Choices in relation to automated processing and profiling – you have the right to request that you are not made subject to any decision based solely on automated processing, including profiling, which produces any legal effect concerning you or any other similarly significant effect upon you.
If you wish to exercise any of those rights, please contact our outsourced Data Protection Officer using the details set out in the “Contact details” section above.
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the Reva App Limited Group.
External Third Parties
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- Marketing and advertising agencies who provide advice with our marketing and advertising.