|Date of version:||5.5.2021|
|Created by:||Be Secure update drafted, , awaiting review by directors|
|Approved by:||Brian Siney|
Scope of Application
“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. Revoke collects the following categories of Personal Information;
How we use Personal Information
Revoke may use Personal Information it collects for the following purposes:
We use your contact information, other identifying information, and biometric information to:
Marketing and Advertising Purposes
We use your contact information, other identifying information, and internet or other electronic activity to:
Maintenance and Improvement of the Services
We use your contact information and internet activity or other electronic activity to:
Security and Fraud Prevention or to comply with law
We use your contact information, other identifying information, financial information, biometric, internet activity or other electronic activity to:
Services provided to our customers
The main services we offer to our customers are as follows;
We have designed our services to comply with the requirements of the new European data protection law in the areas of Privacy By Design and Default.
For Data Protection Requests and Dark Web Searches, we provide these services as an integral part of our contractual services to you, which have been communicated in our app services notices and in our Terms of Business.
For the Privacy Checks and Mailbox Search services, you are being offered these services on an “opt-in” or “opt-out” basis, i.e. you can select to use or not use or use for a selected period of time, these specific services. These services will help facilitate the cleaning up of your digital estate, and to help us avoid contacting organizations on your behalf with whom you would have had no previous relationship.
The Revoke app’s use and transfers to any other app information received from Google API will adhere to Google API Services User Data Policy, including the Limited Use requirements.
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.
For more details on these services, please see our Terms of Business.
Data collection methods
We collect Personal Information in the following ways;
We collect Personal Information directly from you
We collect information passively from you
We collect information about you from third parties
We share your Personal Information
Personal information may be shared with the following third parties:
Third-party service providers are bound by the requirements of the Data Processor Agreement obligations, where your Personal Information is to be processed to high standards of confidentially and with the required security standards and arrangements to be in place.
Choices regarding sharing and marketing practices.
You can opt-out of receiving our marketing emails. To stop receiving our promotional emails, follow the “unsubscribe” instructions in any promotional message you receive from us. Even if you opt-out of receiving these marketing messages, we will still send you transactional messages. These include responses to your questions or other necessary information about your account.
You can opt-out of receiving push notifications from our mobile app. To do so, turn off notifications in your mobile device’s settings.
If you are subscribed to receive text messages from Revoke regarding your account and would like to opt-out, you may do so by going to the “My Settings” section of the Revoke app where you can turn off email, SMS, and push notifications. However, if you opt-out, we may not be able to provide the services to you.
Special notice regarding children
Our Services are not directed to children under 16 years of age. No one under age 16 may provide any information to or on the Services. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on the Services, through any of its features, register on the Services, make any purchases through the Services, use any of the interactive or public comment features of the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
Security of your Personal Information
As part of the Revoke consumer onboarding process your personal identification data, photo identification, and any other biometric data, is encrypted once it has been expertly verified by our service provider. Revoke does not have access to your encrypted data as only you will have the required digital encryption key to access it.
Social media platforms
When we use social media platforms e.g. Facebook, Twitter, Instagram, we only operate it so as to promote our own business and we would not knowingly engage in activities that go beyond this scope. Consumers (and other data subjects) are advised to refer to the respective privacy notices of these social media platforms to check your data protection and privacy rights. Revoke cannot be held responsible for third party social media platforms or websites activities.
Transfer and access to Personal Information
Only those third parties who are properly authorized to do so, and in accordance with this Policy, will have access to your Personal Information and for the purposes as stated in this Policy. Third parties are bound by the confidentiality and security provisions of the relevant service provider contracts and Revoke’s Terms of Business when engaging with Revoke.
Revoke may transfer data outside of the United States where it is necessary for the performance of the contract agreed by you. Wherever your Personal Information is transferred, stored or processed by us or our Service Providers, we will take reasonable steps to safeguard the privacy of your Personal Information. Such steps may include obtaining your consent, or only transferring Personal Information to Service Providers if they agree to comply with reasonable physical, electronic and procedural safeguards designed to protect Personal Information or if they put in place adequate measures themselves.
Retention of data
Revoke will only retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected.
Summary of the important data retention periods are as follows;
This is subject to the exception where the data cannot be deleted for legal or regulatory reasons.
Consumer privacy rights
Where a consumer in California wishes to exercise their privacy rights under applicable data protection and privacy laws, they should contact Revoke’s data protection manager at email@example.com or call our US toll-free number, +1 (279) 3560049. Before helping you with your inquiry, we may ask you to verify your identity or the identity of your authorized agent.
Consumers have the following rights under CCPA;
You have the right to request information about your Personal Information such as the categories of Personal Information collected, the categories of sources from which we collected, the purposes for collecting, the categories of third parties and the purpose for which we shared your data with them. You may also request information about the specific pieces of Personal Information we have collected about you.
You have the right to request that we delete Personal Information that we have collected from you. This right is subject to certain exceptions e.g. necessary for detecting security incidents, protecting or defending against legal claims and others.
Each consumer request to exercise the rights noted above will be reviewed against the requirements of the Californian Consumer Privacy Act (“CCPA”), and other relevant data privacy laws, and in certain circumstances these rights may not be exercisable by the company. Full explanations will be given in such cases.
Making a complaint
Complaints under Californian Consumer Privacy Act (“CCPA”):
Consumers can make a complaint under CCPA to the Office of the Attorney General, California, by completing an online form when you access this link,
Revoke is committed to the security of your Personal Information and has implemented appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your Personal Information or accidental loss or destruction of your Personal Information.
Our Security Policy is available on our website at https://revoke.com/personal/security/.
Our website is encrypted using HTTPS (Hypertext Transfer Protocol Secure). In HTTPS the communication protocol is encrypted using Transport Layer Security (TLS). This provides a secure method of communication with us and any Personal Information uploaded onto our website is securely managed by our website data processor services.
Email communications are scanned using the latest version of anti-virus and malware software deployed by our business. Personal Information held by Revoke Limited is only available to authorized members of staff. No staff member of the Revoke group of companies is able to access decrypted Photo ID or biometric data (Selfie).
Our computer systems have secure audit trails and we have robust backup capabilities in place to ensure that our services can continue uninterrupted for our consumers.
Management and employees are trained in their data protection responsibilities and obligation to handle Personal Information in a confidential manner.
Change to this Policy
Revoke may update this Policy at any time. The updated Policy will appear on our website www.revoke.com and www.atam.id and in our Terms of Business.
This Policy was last updated on May 6, 2021.
If you have any questions, concerns or complaints with respect to this Policy or the handling of your privacy or Personal Information, please contact our data protection manager at firstname.lastname@example.org.
We take security seriously which is why we’ve been assessed and certified for addressing cybersecurity effectively and mitigating the risk from Internet-based threats.