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Relucent Privacy Policy

1. Introduction​

Who we are and what we do​

This Privacy Policy covers Relucent Ltd (collectively, "Relucent", "we", "us", or "our"). We provide online services and tools for businesses and individuals through our owned-and-operated websites, including Relucent.dev, our branded applications for mobile devices, and our experimentation websites (collectively, the "services").

Acceptance and Changes​

By registering for, downloading, or using our services, you accept this Privacy Policy, which is part of out Terms of Service. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at accordion.relucent.dev. If we change the Privacy Policy in a way that materially lessens our commitments to you, we will provide notice through one or multiple of the following means:

  • Email (for registered users)
  • Alert pop-ups on our website
  • Alert pop-ups and notifications in our apps

2. Children's Privacy​

We do not knowingly collect personal information from individuals who are under the minimum ages specified herein. You must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian's account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to Relucent without your consent, you may ask us to delete such information by contacting us at privacy@relucent.dev.

3. Data We Collect About You​

We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as "your data" for short.

Account Information​

We facilitate account creation through the use of third-party authentication platforms (e.g., Google Sign-In, Facebook). By signing in through a third-party authentication platform you authorise us to obtain account information from the third-party platform.

Where possible, we do not directly store your account details ourselves - only the third-party authentication reference. Some data may be stored temporarily in your browser or device, or in a cache, in order to improve our services' speed and performance.

Permissions requested in third-party authentication flows is intended to be "as little as possible", taking into account your intended use of our services.

Financial Information​

To make a purchase, you may need to provide a valid payment method (e.g. credit card or PayPal account). Your payment information is processed, collected and handled solely by our authorised payment vendors and, in the ordinary course of transaction processing, we do not directly collect any credit or debit card numbers or details.

Privacy information for our authorised payment providers is detailed accordingly below:

  • Paypal
  • Mollie

Content You Submit​

...

Automatically-Collected Information​

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in out Cookie Policy.

Physical Products​

We collect your shipping address to send you physical products you have ordered.

Information Collected by Third Parties​

Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).

We may obtain data from third parties about you. We may combine that data with information we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.

4. How We Use Your Data​

We may use your data for the following purposes:

Identification and Authentication​

We use your data to verify you when you access your account.

Operating Our Services​

We use your data to provide our services, process and fulfil orders, provide customer support, and to otherwise comply with our contractual obligations you. We (and/or our third-party vendors) use your financial information to process purchases made by you and to pay amounts you have earned.

Communicating With You​

We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).

Improving Our Services​

We use your data to understand how our services are being used and how we can improve them. In general, we analyse aggregated (anonymised) data, rather than specific user data. We may, however, need to analyse a specific case to address a specific problem (e.g., a bug that affects only a few accounts).

Customising Your Experience​

We use your data to personalise the service to you. This may include remembering your preferences for language or display settings or displaying options that may be relevant to you, based upon your use of our service.

Marketing And Advertising​

We use your data to show you ads on third-party sites, and to measure the effectiveness of those ads.

Exercising Our Rights​

Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.

We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a court order.

Protecting Your Information​

Where appropriate, we may anonymise, backup, and delete certain data. Some data accessible to you through our services may not be accessible or readable to us, through the use of encryption methods.

We may use algorithms and other automated means to implement any of the above.

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

  • Performance of a contract
  • Legitimate commercial interest
  • Compliance with a legal obligation; or
  • Consent

If you require further information about the balancing test that Relucent has undertaken to justify its reliance on legitimate interest as a lawful basis of processing, see [Section 15] form information on how to contact us.

5. With Whom We Share Your Data​

We share data with third parties as follows:

  • As you instruct: We make your profile and videos available to others as you instruct in using our services. We may share your data with persons whom you have granted account-level access.
  • With your consent: We may share your data with third parties where we have obtained your express consent to do so.
  • Authorised vendors: We may share your data with third-party vendors that help us operate our services, process orders, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors, and shipment vendors.
  • Advertising:
  • Affiliates and advisors: We may share your data with our auditors ad advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. We may share your data with our affiliates to the extent necessary to provide you with the services ordered.
  • Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction, as discussed in Section 6.
  • Aggregated or anonymised information: We may publically disclose non-personal, aggregated, or anonymous information such as our number of visitors and registered users.

We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

Organisation-Administered Accounts​

If an organisation establishes a direct relationship with us, they may, with prior notice, send an invitation to you to create or link a personal account to the organisation.

This means that the organisation may do the following:

  • They may access information about your account's activity in relation to the organisation and its resources
  • They may restrict, remove and control access and permissions within the organisation and its resources

The organisation, however, cannot do the following:

  • They cannot delete your personal account
  • They cannot see or edit your sensitive personal account details, such as your password
  • They cannot access, restrict, remove, or control information related to other organisations that have been made available to your personal account

7. Data Retention​

We retain your data for as long as you have an account. When you close an account we will delete its personal content (not resources or data administered by an organisation). We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymise it.

If we receive legal process pertaining to your account, we will retain your data for as long as we, in good faith, believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data indefinitely to defend or assert our rights.

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