The type of personal data that we will collect from you, and you voluntarily provide to us on this website or as part of a service or product we provide to you may include some or all of the following depending on the type of user you are:

Website Users

Businesses and individuals that visit and interact with our website.

Merchant/Partner

You are a Merchant or Partner contracted or entering into contract negotiations with Rvvup.

End Users/Payees

You are an individual purchasing a product or service from a Merchant or Partner that uses Rvvup products and services.

We use your personal data to provide the features of the website and the services you request

When you use our website or platform, we will use your personal data to provide the requested product or service. For example, if you make an enquiry on our website, or participate in an event or promotion, we will use the contact information you give us to communicate with you about the enquiry, event, or promotion. If you contact our customer services, we will use information about you, such as enquiry or payment information, or the service you have purchased to help you resolve a problem or question.

We use your personal data to establish you as a Rvvup customer

If you sign an agreement to become a Rvvup customer, we will need to collect and verify information about you and other relevant individuals to set up our products and services for you, including to provide you with support, onboarding, and integration to our platform.

To conduct KYC and Fraud Prevention checks

The personal data we’ve collected from you at agreement or at contract stage will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your or any of your related persons’ identity. If fraud is detected, you could be refused certain services.

When we and/or the fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in verifying your identity and preventing fraud and money laundering, to protect our business and to comply with legal obligations. Such processing is also a contractual requirement of the services requested. We and/or the fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

To Operate, Improve and Maintain our Business, Products and Services

We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits, and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our platform.

To Protect Our or Others' Rights, Property or Safety

We may also use personal data about how you use our website to prevent, detect, or investigate fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests, or applicable law.

To Communicate Information about our Products, Services, Events and for Other Promotional Purposes

When you consent, we will send you marketing communications and news concerning Rvvup products, services, events, and other promotions.  You can opt-out at any time after you have given your consent.

If you are an existing customer of Rvvup (for example, if you are a service user), we may use the contact details you provided to send you marketing communications about similar Rvvup products or services, where permitted by applicable law (unless you have opted out).

Service messages — Service messages are vital for keeping you informed about critical updates, essential service information, and changes in our Terms and Conditions (T&Cs).

To process transactions / provide our services

In basic terms Rvvup securely manages the payment process for you which includes handling your customers payment information, gaining authorisation for the payment, contacting the card providers and banks involved.

To process your personal data, we rely on certain lawful basis, depending on how you interact with our website, platform, or services. If we do process your personal data, we may use one or more of the following lawful basis for processing:

As necessary to perform our contract with you for the relevant product, or service, including:

• To take steps at your request prior to entering into it
• To decide whether to enter into it
• To manage and perform that contract
• To assess credit risk
• To update our records

As necessary for our own legitimate interests or those of other persons and organisations, including:

• Governance, accounting, managing, and auditing our business operations
• To search at credit reference agencies if you as an individual are over 18 and to confirm your identity
• To monitor emails, calls, other communications, and activities on your account, product, or service
• For market research, analysis and developing statistics
• To send you marketing communications, including automated decision making relating to this
• To identify and contact potential customers using publicly available information and internal insight; and
• To monitor your or their transactions to assess credit risk, and for the detection and prevention of crime.

As necessary to comply with a legal obligation, including:

• When you or any of your related persons exercise available rights under data protection law and make requests
• For compliance with legal and regulatory requirements and related disclosures
• For establishment and defence of legal rights
• For activities relating to the prevention, detection, and investigation of crime
• To verify your or any of your related persons’ identity, make credit, fraud prevention and anti-money laundering checks; and
• To monitor emails, calls, other communications, and activities on your account, product, or service.

Based on your consent, including:

• When you request us to disclose your or any of your related persons’ personal data to other people or organisations, such as a person or company handling an account or onboarding on your behalf, or otherwise agree to disclosures
• When we process any special categories of personal data about you or your related persons at your request (e.g., your or any of your related persons’ racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation); and
• To send you marketing communications where we’ve asked for your consent to do so. You are free at any time to change your mind and withdraw your consent.

We do not sell your personal data.

We may share your personal data with other organisations in the following circumstances:

• If the law or a public authority says we must share the personal data (Government bodies and agencies in the UK, e.g., the Financial Conduct Authority, the Information Commissioner’s Office
• If we need to share personal data to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk)
• External sources of publicly available information such as Companies House, Dun and Bradstreet and credit reference agencies
• Payment systems (e.g., Visa or Mastercard) and correspondent banks, who may transfer such personal data to others, as necessary to operate your service and for regulatory purposes, to process transactions, resolve disputes and for statistical purposes.
• We use data processors who are third parties who provide elements of services for us. We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold your personal data securely and retain it for the period we instruct.
• Rvvup entities for the purposes and under the conditions outlined above. This includes Rvvup Ltd, its subsidiaries, and affiliated companies.
• We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, spin-off, dissolution, or liquidation).

We use plugins on our website from social media networks such as Facebook, LinkedIn, and Twitter. You can recognise these plugins by their logos. Our plugins will not collect personal data about you unless you click on these logos. If you click on them, these plugins are activated and automatically transmit data to the plugin provider.

We do not have any influence over which data these providers collect from you. If you would like more information about their data processing, this can be found in the respective privacy policies on the websites of these providers.

We use cookies and similar techniques, such as tags/beacons and JavaScript, which are small text files stored on your device. Using cookies is a way for us to make sure that our website is continuously improved, meets your needs and can be used as a tool to optimise our marketing strategy. For us to do this, we place functional cookies to make the website function as well as marketing cookies which help us target the right people and show them advertisements. Some of these cookies track your use of our website and visits to other websites and allow us to show you advertisements when you browse other websites.

Please view our Cookie Policy for more information on our use of cookies.

The Right to be Informed about our collection and use of personal data

You have the right to be informed about the collection and use of your personal data. We ensure we do this with our internal data protection policies and through our external website privacy notice. These are regularly reviewed and updated to ensure these are accurate and reflect our data processing activities.

Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 1 month from when your identity has been confirmed.

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If you would like to exercise this right, please contact us as set out below.

Right to Correction Your Personal Information

If any of the personal information we hold about you is inaccurate, incomplete, or out of date, you may ask us to correct it.

If you would like to exercise this right, please contact us as set out below.

Right to Stop or Limit Our Processing of Your Data

You have the right to object to us processing your personal information for particular purposes, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

You can ask us to restrict processing your data, for example where:

• you’re contesting the accuracy of your personal data
• we no longer need to process your personal data, but you want us to keep it for use in legal claims
• you’ve objected to the processing by asking us to stop using your data, but you’re waiting for us to tell you if we have overriding grounds which mean we’re allowed to keep on using it

If you would like to exercise this right, please contact us as set out below.

Right to Erasure

You have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances. Where the right doesn’t apply, we’ll let you know why we can’t action your request.

This right may be applied where:

• personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
• the processing was based on your consent which you withdraw (and there are no other legal grounds for processing that data)
• you exercise your right to object and there are no overriding legitimate grounds for the processing
• there is no lawful reason to retain personal data or if the personal data must be erased to comply with a legal obligation

If you would like to exercise this right, please contact us as set out below.

Right to Portability

The right to portability gives you the right to receive personal data you have provided to a controller in a structured, commonly used, and machine-readable format. It also gives them you the right to request that a controller transmits this data directly to another controller.

If you would like to exercise this right, please contact us as set out below.

Rights in relation to automated decision making and profiling

You have rights around automated decision making and profiling. Automated decision making means a decision made solely by automated means, without any human involvement. Profiling means the automated processing of your personal information to evaluate certain things about you. You have the right to information about these kinds of processing, and the right to ask for human intervention or to challenge an automated decision.

If you would like to exercise this right, please contact us as set out below.
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For more information about your privacy rights

The Information Commissioner's Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as Rvvup are available publicly.

You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Where the same record has to be kept for more than one purpose and there is a different retention period for each of those purposes, the record is kept for the longer period.

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 requirements.

Accounting and Tax Records

We must keep accounting and tax records for a minimum of seven years to comply with Companies Act 2006. We are required to retain accounting records which:

• are sufficient to show and explain the company’s transactions;
• disclose with reasonable accuracy, at any time, the financial position of the company at that time; andenable the directors to ensure that any accounts prepared under this Act comply with the requirements of that Act.

FCA Supervised Regulations
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In summary we must keep records for five years beginning from:

• the date a business relationship ends.
• the date a transaction is completed.

The Payment Services Regulations 2017 – Part 4 – Regulation 31
31.— (1) An authorised payment institution or small payment institution must maintain relevant records and keep them for at least five years from the date on which the record was created.

(2) For the purposes of paragraph (1), records are relevant where they relate to compliance with obligations imposed by or under Parts 2 to 5 and, in particular, would enable the FCA to supervise effectively such compliance.

The Electronic Money Regulations 2011
27.— (1) Electronic money institutions must maintain relevant records and keep them for at least five years from the date on which the record was created.

(2) For the purposes of paragraph (1), records are relevant where they relate to the institution’s compliance with this Part and, in particular, would enable the Authority to supervise effectively such compliance.

The Money Laundering and Transfer of Funds (Information) (Amendment) (EU Exit) Regulations 2019 (UK revised Wire Transfer Regulation (UK WTR))

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 – Part 4 – Regulation 40 – Paragraph 3

(3) Subject to paragraph (4), the period is five years beginning on the date on which the relevant person knows, or has reasonable grounds to believe—

(a) that the transaction is complete, for records relating to an occasional transaction; or

(b) that the business relationship has come to an end for records relating to—

(i) any transaction which occurs as part of a business relationship, or

(ii) customer due diligence measures taken in connection with that relationship.

Legal Claims
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The Money Laundering and Transfer of Funds (Information) (Amendment) (EU Exit) Regulations 2019 (UK revised Wire Transfer Regulation (UK WTR))

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 – Part 4 – Regulation 40 – Paragraph 4 & 5
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(4) A relevant person is not required to keep the records referred to in paragraph (3)(b)(i) for more than 10 years.

(5) Once the period referred to in paragraph (3), or if applicable paragraph (4), has expired, the relevant person must delete any personal data obtained for the purposes of these Regulations unless—

(a) the relevant person is required to retain records containing personal data—

(i) by or under any enactment, or(ii) for the purposes of any court proceedings;

(b) the data subject has given consent to the retention of that data; or

(c) the relevant person has reasonable grounds for believing that records containing the personal data need to be retained for the purpose of legal proceedings.

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. Platforms, systems, and facilities in which personal data are processed are protected by secure network architectures that contain firewalls and intrusion detection devices.

Our commitment to security and safeguarding your data includes the following key aspects:

‍Encryption: All data transmitted between your device and our systems is encrypted using industry-standard encryption protocols, such as Secure Socket Layer (SSL) technology. This ensures that your payment details remain confidential and secure during transmission.

‍Data Storage: We store your personal data in secure, access-controlled environments with robust security measures in place. We only utilise data centres and cloud infrastructure that adheres to industry-leading security standards.

‍Access Control: Access to your personal data is restricted to authorised personnel who require it for legitimate purposes, such as processing payments and providing customer support. Access is granted on a need-to-know basis, and strict authentication mechanisms are in place.

‍Compliance with Standards: We comply with industry-specific data security standards and regulations, including Payment Card Industry Data Security Standard (PCI DSS) compliance. Our adherence to these standards ensures the secure handling of payment card data.

‍ISO 27001: We are proud to hold ISO 27001 certification, an internationally recognised framework for information systems security management. This certification reflects our dedication to implementing robust security practices, ensuring the confidentiality, integrity, and availability of your data.

‍Cyber Essentials Plus: Cyber Essentials Plus is the highest level of certification within the Cyber Essentials Scheme, a UK government backed, industry supported scheme, to help organisations demonstrate operational security against common online threats.

‍Incident Response Plan: In the event of a security incident or data breach, we have a well-defined incident response plan in place. Our goal is to minimise any potential impact and notify you promptly if your data is affected.

‍Third-Party Security: When we engage with third-party service providers or partners, we assess their security practices to ensure they meet our high standards for protecting your data.

‍Regular Security Audits: We conduct regular security audits, vulnerability assessments, and penetration testing to identify and address potential security vulnerabilities in our systems. This proactive approach helps us stay ahead of emerging threats.

We securely store the personal data we collect about you within the United Kingdom. However, there may be instances where your data is transferred to or stored in a location outside of the UK.

When we transfer your data to third-party service providers situated outside the UK, we take every necessary step to ensure that your data receives a level of protection comparable to what it receives within the UK and EEA. This is achieved through one of the following safeguards:

• We exclusively transfer your personal data to countries that have been recognized by the UK and/or European Commission as providing an adequate level of protection for personal data.
• In cases where we engage specific service providers, we implement specific data protection contracts, known as Standard Contractual Clauses, approved by the UK and/or European Commission. These contracts not only grant your personal data the same protections it receives in the UK but also incorporate additional security measures as needed.

Please contact us if you want further information when transferring your personal data out of the UK.

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, the way your personal information is processed, please contact us by one of the following means:

Rvvup Ltd, FAO Data Protection Officer (DPO)

7, Savoy Court, London, WC2R 0EX

dataprotection@rvvup.com

Contact: +44 20 8164 2736