Privacy Policy
Summary
Pseudomys Ltd, (“Raven”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.
This policy (together with our subscriber terms and conditions, referred to herein as our “Terms”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
1. Introduction
The purpose of this privacy policy (the “Policy”) is to give you a better understanding of:
· What information we collect;
· How we use that information;
· How this information is shared; and
· Your rights.
Should you have any questions in relation to the Policy you can contact us by emailing info@raven-advisory.com or via another method as described in the ‘Contact’ section of our website.
2. Information we may collect from you
2.1 We may collect and process the following data about you:
2.1.1 information that you provide by filling in forms at www.raven-advisory.com (the “Site”, a term deemed to include any other interfaces or platforms through which we make our services available). This includes information provided at the time of registering to use the Site;
2.1.2 a record of any correspondence between us including any financial data we legitimately request from you in relation to your subscription;
2.1.3 completed surveys that we use for research purposes, although you do not have to respond to them; and
2.1.4 details of your visits to the Site and the resources that you access in doing so.
3. Where we store your personal data
3.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
3.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site. The transmission of information via the internet is not completely secure and any transmission is done at your own risk. Once we have received your information, we will use strict procedures to try to prevent it being accessed by any unauthorised party.
4. Uses made of the information
4.1 We use information held about you in the following ways:
4.1.1 to help us set up and manage your Raven account;
4.1.2 to ensure that content from the Site is presented in the most effective manner for you and for the device from which you are accessing the Site;
4.1.3 to provide you with information, products or services that you request from us;
4.1.4 to notify you about changes to our services;
4.1.5 to ensure accounts comply with our Terms; and
4.1.6 to fulfil our broader legal and regulatory obligations.
5. Disclosure of your information
5.1 We may disclose your personal information to third parties:
5.1.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
5.1.2 if Pseudomys Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers may be one of the transferred assets;
5.1.3 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, this includes co-operation with any investigation carried out by any body investigating suspected criminal or fraudulent behaviour; and
5.1.4 in order to enforce or apply our Terms and any other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with companies and organisations for the purposes of age and identity verification, fraud prevention, credit risk reduction and auditing of the gambling activity you conduct in reliance on your Raven subscription.
6. Your rights
6.1 We will assist you if you choose to exercise any of your rights over your personal data, including:
6.1.1 withdrawing your previously granted consent to process your data from that point onwards.
6.1.2 correcting of any personal data that is incorrect or out of date;
6.1.3 access to your personal data that we hold or process (see section 7 below for more information on this);
6.1.4 deleting any of your personal data that we process, though please note that in relation to any request to delete such data we may be subject to legal and/or regulatory requirements to keep personal data for a longer period, in particular pursuant to any applicable statutory limitation period;
6.1.5 asking us to provide you or another company you nominate with your personal data, including in a format which enables you to transfer your personal data to another organisation (‘the right to portability’);
6.1.6 lodging a complaint with any relevant Data Protection Authority. The relevant Authority in Guernsey is the Office of the Data Protection Authority (https://www.odpa.gg/).
7. Access to your personal information
You are entitled to request access to the information held by us about you. Any access request will be dealt with by us within one month of being made by you and we will endeavour to provide such data to you in a format of your choice.
8. Retention of your personal data
We will keep your data for the period that you remain a subscriber of Raven. Once your subscription is terminated we will keep your data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal and/or regulatory obligations.
9. Changes to the privacy policy
Any changes we make to this Policy will be updated to this page and where we deem such changes to be material we will notify you by email with the relevant details.
Last amended on 1 September 2021