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V0.8 Last Updated: 26th October 2021
1 About Revoke
These Terms & Conditions (“Terms”) govern your relationship with the Revoke service (the “Service”) operated by Revoke Limited (“Revoke”, “us”, “we”, or “our”), a company registered with the Jersey Financial Services Commission, Registration Number 124314.
These Terms tell you who we are, how we act on your behalf, and establish a contractual relationship between you and Revoke. You can read more about our Privacy Policy and our Security Policy to understand how we keep your personal data safe, and why you can trust us. Unless otherwise defined, the terms used in these Terms have the same meanings as in our Privacy Policy.
By using the Service, you confirm that:
If you do not agree to be bound by these Terms, you may not use the Service.
We reserve the right to change these Terms at our sole discretion, by posting an amended version on the Service. You can always view the latest version of these Terms in the main menu of the Service or on our website. All amended Terms automatically take effect from the date of posting, unless otherwise stated.
Your continued use of the Service will constitute your acceptance of the amended Terms.
2 How Revoke Works
Revoke makes it easy for you to exercise your data protection rights. Revoke communicates with organisations on your behalf in order that your wishes can be executed efficiently. We also carry out a dark web search for your personal data that may have been hacked or otherwise exposed.
The information available on the Service is made available for general information purposes only, and should not be construed as or relied upon as legal advice, whether in relation to your data protection rights or otherwise. For legal advice, please speak to a qualified legal practitioner.
For efficient execution of your requests and to act on your behalf, it is necessary for Revoke to identify you by using a government-issued photo ID document (Passport, Driving Licence or National ID). This information is encrypted in a way that only permits the designated recipient of the information to view it. Our security policy includes further details on our approach to encryption (we use the most advanced levels of elliptic curve encryption, more secure than typical secure online services such as banking, and equivalent to military-grade encryption).
After we have identified you, we can communicate with organisations on your behalf to ensure that your rights are respected and requests relating to your data are executed. We will communicate with you periodically to keep you informed of the progress of any requests you may have made.
Personal Data Access Requests
At your request we may make a personal data access request on your behalf. You can make up to 10 requests a week on an Essential Subscription, 25 requests a week on a Plus subscription and 50 requests a week on a Premium subscription with these amounts resetting every Monday.
We are not able to guarantee whether or how an organisation will respond to your request. However, we will endeavour to follow-up with an organisation regarding any outstanding request, and you may choose to submit a complaint with a competent data protection supervisory authority if you are unhappy with their response.
Any personal data retrieved from organisations is encrypted in such a way that only you can access it. Revoke is unable to access this data; the decryption key is stored on your phone.
Dark Web Search
We carry out a dark web search to check whether your personal data has been the subject of a breach, hacked, stolen, or inadvertently made public. We summarise the results of the search for you, and once we have verified your email address and identity we share with you the data that we have found to have been compromised. If those companies with whom you’ve been involved in a breach are in our database, we will automatically populate your companies list so that you can send requests to them if you desire.
If your personal data has been compromised, you can choose to follow up on it by either (i) upgrading to Revoke Premium in order to get help from our partner organisation Cyberscout, which specialises in personal cybersecurity advice; or (ii) nonlegal advice in the process for registering your interest in making a legal claim or commencing other proceedings to the extent they may be available under applicable law. Services offered by Cyberscout are governed by their separate terms of use and privacy policy. In the event that you register your interest in making a legal claim or bringing other legal proceedings as a result of a breach of your data rights, we will inform you of the options available at that time based on your circumstances.
Privacy Checks
We allow you to link your online accounts to see which companies have access to your personal data as well as provide security and privacy setting recommendations so you may better protect yourself when using them. We do not store any personal data except for the list of companies with access to your accounts so that we can populate a custom list of companies for you to send requests to. Any companies we do not have in our database are noted for us to add which you’ll be notified about when added after which they will automatically appear in your list.
Mailbox Search
We offer this service to our customers so that you can link your email accounts with Revoke and authorise us to search for companies who are sending you marketing communications. We only look at the to/from header details of your email communication, not the text or body of your email correspondence. We only look for domain names we recognise as belonging to a company in order to populate a custom list of companies for you to send requests to. Any companies we do not have in our database are noted for us to add them to our database which you’ll be notified about when added after which they will automatically appear in your list.
3 Authorisation
By accepting these Terms, you are giving Revoke permission to act on your behalf as described in these Terms (“Authorisation”). This Authorisation is replicated in a standard form letter sent to companies when communicating on your behalf.
Revoke will only act on your behalf to exercise your data protection and cybersecurity rights, and only when requested by you.
When you indicate that you would like to exercise your data protection rights with a particular organisation, regulatory body, court, authority or other entity, Revoke will communicate with that entity on your behalf. Examples of communication include (but are not limited to) the following:
We will never request on your behalf for data to be deleted without giving you an opportunity to check what data will be deleted.
To facilitate the cleaning up of your digital estate, and to avoid contacting organizations on your behalf with whom you would have had no previous relationship, Revoke helps you identify companies that hold your personal data. We do this through our Dark Web Search, Privacy Checks, and Mailbox Search features. We never contact a company on your behalf without your explicit permission.
4 Security
Revoke is secure by design.
All personal data is encrypted at rest and in transit, at the message and transport layer.
Revoke uses advanced Elliptic Curve encryption methods to ensure that even we can’t access personal data which is sent to you by companies after we have made an access request on your behalf.
Only you can access this data, using the private key stored on your phone.
Personal data you have provided for the purposes of communicating effectively with companies and exercising your data protection rights is only unencrypted to share with the intended recipient of your request. This data is protected by a one-time password that the recipient must enter, confirming they are the intended recipient of your request.
You can read more about our approach to security in our Security Policy.
5 Privacy
Revoke cares deeply about data protection and your rights; transparency and privacy are core to Revoke’s ethos.
You can find out more about Revoke’s stance on privacy in our Privacy Policy.
6 Payment
Premium services are offered via in-app purchases and subscriptions via the Apple App Store or Google Play Store from which you originally downloaded the application.
Purchases and subscriptions are non-refundable.
7 Your Use of the Service
You agree that you will be solely responsible for any and all activity in relation to your use of the Service.
You must not access, collect or use information from the Service, proprietary or otherwise, without our express prior written consent, or other than as outlined in these Terms.
By accepting these Terms, you agree that you will not modify, rent, lease, loan, sell distribute, create derivative works of, decompile, reverse engineer or attempt to extract the source code from the Service, unless in accordance with our express prior written consent. You shall not exploit the Service in any unauthorised way whatsoever, including but not limited to by trespass or burdening network capacity.
You may be able to access other websites from within the Service. However, these Terms do not apply to your web activity outside the Service.
To the extent that use of the Service requires the use of any third-party terms of agreement, you must comply with such terms.
You agree that from time to time, the software may download and install updates and/or any other additional features to improve the Service.
8 Warranties and Representations
To the fullest extent permissible by law, the Service is provided on an “as is”, “as available” and “with all faults” basis, without any express or implied warranties, representations or endorsements as to (i) the Service; (ii) the content on or in relation to the Service, our users or third parties; and (iii) security associated with the transmission of information through the Service.
We do not guarantee that our Service will always be safe, secure and/or error free, or that our Service will always function without disruption or delays.
9 Limitation of Liability
Except where prohibited by law, we shall not be liable to you for any loss or damage of any kind, including, but not limited to, any direct, indirect, economic, exemplary, punitive, special, incidental or consequential losses or damage that are directly or indirectly related to:
10 Indemnification and Settlement
By agreeing to these Terms, you agree to indemnify, defend and hold us harmless, including, but not limited to, our managing members, shareholders, employees, parent or related companies, affiliates, licensors, and suppliers, from and against any and all complaints, charges, damages, losses, costs, liabilities and expenses (including legal fees and costs) arising from your actions, your use (or misuse) of the Service, your breach of the Terms, and/or your violation of any applicable law.
In the event that both you and Revoke are involved in legal proceedings arising out of the circumstances mentioned in the previous paragraph, we reserve the right to handle our legal defence as we see fit and to request your cooperation at any time during the execution of our defence strategy. In any event, you will not settle any claim without our express prior written consent.
11 Termination
We reserve the right to terminate, at any time and at our sole discretion, your use of, or access to the Service and/or your account.
You may delete your account at any time from the menu in the Revoke app. After you select the deletion of your account, and the account remains inactive for a period of three (3) weeks, the account will be deleted. Following deletion, certain data may be retained by us as described in our Privacy Policy.
These Terms will remain in effect even after your use of or access to the Service is terminated, or you delete your account.
12 Dispute Resolution
All claims and disputes arising out of or in connection with these Terms and access to or use of the Service shall be subject to the exclusive jurisdiction of the courts of Jersey, Channel Islands, UK.
Any claims under the Terms must be made on an individual basis; class actions are not permitted.
13 Other
If any provision of these Terms is found by a competent court to be unlawful, void or otherwise unenforceable, the parties agree that such provision shall be deemed severable from these Terms and shall not affect the validity and enforceability of any of the other remaining provisions.
You will not assign these Terms, or assign any rights or delegate any obligations under these Terms, in whole or in part, whether voluntary or by operation of law, without express prior written consent by Revoke. Any purported assignment or delegation by you without the appropriate express prior written consent by Revoke shall be considered null and void.
We may assign any and all of our rights and obligations under these Terms in connection with a merger, acquisition, transfer, sale of all or part of the Service, or any other assets, or by operation of law or otherwise.
These Terms, any updates, and any other documents mentioned in these Terms, constitute the entire agreement between you and Revoke, and supersede any other prior agreement between you and Revoke.
Our failure to insist upon or enforce strict performance of any provision of these Terms will not be construed in any way as a waiver of any provision or any of our rights.
14 Additional Terms for Apple iOS
These additional terms in this Clause 14 apply when the Service is installed on an iOS Apple device.
These Terms are an agreement between you and Revoke, and not with Apple. Apple is not responsible for this Service and the contents thereof.
We grant you a non-transferable licence to use the Service only on Apple-branded products that you own or control, and as permitted by the usage rules set forth in the App Store Terms of Service, except that the Service may be accessed and used by other accounts associated with you via Family Sharing or volume purchasing.
Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the Service.
In the event of any failure of the Service to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the Service to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Service.
Apple is not responsible for addressing any claim by you or any third party relating to the Service or your possession and/or use of the Service, including, but not limited to (i) product liability claims; (ii) any claim that the Service fails to conform to any applicable legal or regulatory requirement; and (iii) claims arising under consumer protection or similar legislation.
Apple is not responsible for the investigation, defence, settlement and discharge of any third party intellectual property infringement claim.
You represent and warrant that (i) you are not located in a country that is subject to a US Government embargo, or that has been designated by the US Government as a “terrorist supporting” country; and (ii) you are not listed on any US Government list of prohibited or restricted parties.
Apple, and Apple’s subsidiaries, are third party beneficiaries of these Terms, and upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms against you as a third party beneficiary thereof.
15 Contact Us
If you have any questions, comments or complaints about these Terms, or any other aspect of the Service, please get in touch with us via the following contact details: help@revoke.com.