Revoke is evolving. Whilst we transition, please note that some pages and information may be outdated.
This Privacy Policy is for the Revoke app and services.
V1.8 Last Updated: 30th May 2023
This Data Protection Policy outlines Revoke’s commitment to its customers, suppliers and other individuals to operate its business activities in a manner that meets the compliance obligations of the Data Protection (Jersey) 2018 Law (“DPJL”), the Data Protection (Bailiwick of Guernsey) Law 2017, Data Protection Act 2018, (UK) and the General Data Protection Regulation (EU) 2016/679 and all other global Data Protection Laws in force.
Revoke understands and respects your right to privacy, and we are committed to ensuring the confidentiality and security of your personal data and the personal data processing activities within our organisation by applying the appropriate technical and organisational measures required to achieve this objective.
This document covers the policies and procedures for processing personal data in a compliant manner and outlines the rights of the data subjects in respect of that data. The Privacy Notice below explains how we may use, process, and store your personal data.
When you use our Services, you enter into an agreement with us and are directed to this Privacy Policy and the Terms and Conditions which form part of that agreement.
Each time you use our Services, or provide us with information, the processing of your Personal Data will be governed by the current version of this Privacy Policy and Terms and Conditions.
If you do not agree with the terms of this Privacy Policy or the Terms and Conditions, please refrain from using our Services.
Data Controller:
Revoke Limited trading as Revoke is the data controller of all personal data and data processing activities of its data protection app business. The company runs the “Revoke” app and associated services. It also operates the www.revoke.com website. The company’s head office and Registered Office is located at 2nd Floor, Conway House, 7-9 Conway Street, St Helier, Jersey, JE2 3NT.
Revoke Limited is registered as a data controller with the Jersey Office of the Information Commissioner and its number is 61116.
Reference documents:
Scope of application:
This policy applies to our business activities and the personal data processing of the data subjects within the European Economic Area (EEA), UK, Jersey, and Guernsey in the Channel Islands and the rest of the World.
Personal data:
Personal data means any information relating to an identified or identifiable natural person. Revoke collects the following categories of personal information;
From Customers:
Purposes of data processing;
Revoke uses the personal data noted above for the following range of activities;
| Purpose | Lawful bases for processing |
| The provision of Revoke app services | Processing is undertaken in the performance of a Contract – i.e. the use of our app or service |
| The provision of customer guidance and support services | Processing is undertaken in the performance of a Contract – i.e. the app services |
| To advertise and market our Revoke app services and features, and keep you updated on any new or existing customer services which may be available to you | Legitimate interest basis for Revoke to promote its business products and services. You have the right to object to such processing by contacting our data protection manager. |
| Managing security and access controls to the Revoke app, Revoke’s computer systems, computer platforms, website and vendor related applications
|
Legitimate interest basis for Revoke to protect its business app, computer systems, platforms and website and vendor related applications. You have the right to object to such processing by contacting our data protection manager. |
| Establishment and exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. | Legitimate interest basis for Revoke to protect and assert its legal rights and the legal rights of others. You have the right to object to such processing by contacting our data protection manager. |
| Obtaining or maintaining insurance cover, managing risks, or obtaining professional advice. | Legitimate interest basis for Revoke to protect and assert its legal rights and the legal rights of others. You have the right to object to such processing by contacting our data protection manager. |
| Comply with legal, tax and regulatory obligations. | In the performance of a task carried out in compliance with a Legal obligation.
|
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 data protection law in the areas of Privacy By Design and Default.
Data collection methods:
We collect personal data in the following ways:
Information collected:
Customer personal data will only be used by us where you are using our Revoke app and associated services.
The personal data collected is used to;
Personal data may be used for the legitimate business interest of Revoke as indicated in this Privacy Policy.
Only personal data that is necessary for the purposes of assisting our customers with the provision of products or services as outlined above are actively collected.
Recipients of data:
Personal data collected may be disclosed or transferred to;
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. Customers (and other data subjects) are advised to refer to the respective privacy notices of these social media platforms to check their data protection and privacy rights. Revoke cannot be held responsible for third-party social media platforms or website activities.
Any data that is held by us will be stored on our servers which are located in the European Union, Netherlands and Ireland.
Revoke engages the services of those vendors who are operating under the respective data protection compliant agreements and where they are using Standard Contractual Clauses or other approved data transfer mechanisms, where appropriate.
Any transfer of data is done in a secure way and in compliance with Data Protection Laws.
Retention of data:
Revoke will only retain your personal data for as long as is necessary to fulfil 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.
Data subject rights:
Where a data subject in the European Union (or any “adequate/equivalent” status country) wishes to exercise their rights under applicable data protection laws, they should contact Revoke’s data protection manager at dpo@revoke.com.
Data subjects have a number of rights available to them;
You can assert this right by accessing your personal data or by contacting us directly via our website www.revoke.com or email dpo@revoke.com. We would request that any request to access personal data must be made to Revoke in writing and provide sufficient detail to identify the Personal Data that you are seeking.
Where you have identified that we have recorded your data incorrectly, you can contact us directly to update your information.
This right applies in certain specific circumstances; where the accuracy of personal data is contested and the data controller needs time to verify details; where processing is deemed unlawful but the data subject opposes erasure and requests restriction instead; where there is an objection to data processing under legitimate interest legal bases and pending verification that the legitimate interest overrides the data subjects rights; the purpose of processing is no longer valid but it is required by the data subject for the establishment, exercise or defence of legal claims.
This right is available to data subjects to request exclusion from any direct marketing activities or communications, including profiling to the extent that it is related to such direct marketing activities, and to any automated means using technical specifications in the context of information society services
You can delete or uninstall the Revoke app at any time. Revoke will not however be able to delete all our personal data to the extent that it is necessary to meet its legal obligations
This is a new right and only applies to those processing activities that are conducted under the legal basis of Consent or on Contract and the processing is carried out by automated means. Your data can be transferred to another data controller or to you directly where technically feasible
The data subject can object to automated decision-making and profiling in certain circumstances and request human intervention in the decision-making process. Revoke does not make any decisions based on purely automated means, but if we do, you have a right to object
Where the processing of personal data is conducted with Consent as the legal basis, the data subject can withdraw consent at anytime.
Each data subject request to exercise the rights noted above will be reviewed against the requirements of the Data Protection (Jersey) Law 2018 and other relevant data protection laws, and in certain circumstances (e.g. restriction, erasure, objection, data portability) these rights may not be exercisable by the company. Full explanations will be given in such cases.
Making a complaint:
The Jersey Office of the Information Commissioner (“JOIC”), Channel Islands, is an independent statutory authority where you can make a complaint or learn more about data protection in Jersey. Their office is located at 2nd Floor, 5 Castle Street, St. Helier, Jersey, JE2 3BT. Their website is www.jerseyoic.org and their telephone number is 01534 716530.
Security features:
Revoke is committed to ensuring the security of your personal data and has implemented appropriate commercially reasonable technical, physical, and organisational measures to prevent unauthorised or unlawful processing of your personal data or accidental loss or destruction of your personal data.
Our Security Policy is available on our website here.
Email communications are scanned using the latest version of anti-virus and malware software deployed by our business. Personal data held by Revoke is only available to authorised members of staff.
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 customers.
Management and employees are trained in their data protection responsibilities and obligation to handle personal data in a confidential manner.
Change to this notice:
Revoke may update this Privacy Notice at any time. The updated notice will appear on our website www.revoke.com and in our Terms of Business.
This Privacy Policy was last updated on 30th May 2023.
Contact details:
EU Representative:
Revoke has appointed Formiti Data International, The Black Church, St. Mary’s Place, Dublin, Ireland 7, as its EU Representative. They can be contacted on +353 1 485 3752 or by email using info@formiti.com.
UK Representative:
Revoke has appointed Formiti Data International, Suite 2a, Blackthorn House, St. Paul’s Square, Birmingham, Warwickshire, England, as its UK Representative. They can be contacted on +44 121 582 0192 or by email using info@formiti.com.
Revoke:
If you have any questions, concerns, or complaints with respect to this Privacy Policy or the handling of your privacy or personal information, please contact our data protection manager at dpo@revoke.com.