ResponseTap is now part of Infinity – and things are going to get a whole lot better for our customers. Find out more here. 0800 138 7600 Privacy Policy Privacy Policy for visitors to ResponseTap’s website Introduction Thanks for visiting ResponseTap. This privacy policy aims to give you information about how ResponseTap collects and processes your personal data when you visit our website at www.responsetap.com or otherwise contact us, and how we process and use personal data of our customers who we engage with in the use of the services that we provide to them. ResponseTap is an analytics provider whose software allows website owners to understand the usability of their websites and the effectiveness of their marketing (the “Services”). This information enables our customers to improve the service that they provide to their website visitors. If you are a user of or visitor to one of our customer’s websites and you would like information about how we process your data, please click here for a link to our ‘Privacy Policy for ResponseTap Services (provided via our customers’ websites)’. 1. About us and the services we provide ResponseTap is made up of ResponseTap Limited, a company registered in England and Wales (company number 06613420), with registered office at 7th Floor, Building 8, Exchange Quay, Salford Quays, Manchester M5 3EJ, and ResponseTap Inc., a Delaware corporation with principle offices located at 79 Madison Ave, New York, NY 10016. This privacy notice is issued on behalf of the ResponseTap group, so references to “we”, “us”, “our” or “ResponseTap”, are references to the relevant company in the ResponseTap group responsible for processing your data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, or about how we process your data, please contact us using the contact details set out in the ‘Contact Us’ section below. 2. Information Collected and how we can use such information Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). (i) Information Collected from visitors to the ResponseTap site If you are a visitor to the ResponseTap site (at www.responsetap.com), ResponseTap collects information about your use of our site, such as pages visited and links clicked, as well as information such as the referring URL, your internet protocol (IP) address, browser type and version, operating system and cookie information (such as whether you accept cookies) (“Usage Information”). ResponseTap collects such Usage Information to better understand how visitors to our site use the site. You may also provide information to us directly, such as your name, email address, telephone number, user name and password, whether via our website (for example when logging in to your account, or completing a contact request form) or when you otherwise contact us, for example by telephone or via the ResponseTap blog or social media sites, etc. You should be aware that any information you provide in the ResponseTap blog or social media areas may be read, collected, and used by others who access them. We only seek to collect personal data that is reasonable or necessary to accomplish the purpose of your interaction with ResponseTap. (ii) We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”) Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate information about the number of users accessing our website or a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. Information collected from customers of ResponseTap who use the ResponseTap Services In respect of ResponseTap’s customers (who have contracted with ResponseTap to receive the Services), we will collect certain information relating to the designated contacts or users of our customers, such as name, email address, telephone number, user name and password. Such information may be provided directly via our website (for example when such individual logs in to the relevant customer’s online account, or completes a contact request form) or when such individual otherwise contacts us, for example by telephone or via the ResponseTap blog or social media sites, etc. Please note that any information provided in the ResponseTap blog or social media areas may be read, collected, and used by others who access them. We may also ask for additional information which we require in connection with and for the purposes of you using the Services, such as billing contact information, account login details, and other information we deem relevant for the purpose of providing the Services. ResponseTap may use such information and data (to the extent that it constitutes personal data) for the purposes of performing our contract with a customer, which may include, for example, for the purposes of: processing transactions between the customer and ResponseTap; providing support in connection with the Services. We may also use such personal data for the following purposes, which we consider to be necessary for our legitimate interests: To respond to enquiries from you. To send you e-mails and updates about the ResponseTap Services, including notices about changes to the Services. To request your feedback. Enhance or improve user experience, our site, or ResponseTap Services. Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our site or the ResponseTap Services. With your prior consent, we may post your personal testimonials along with those of other satisfied customers on our site or in marketing materials in addition to other endorsements. If you are a registered user of the Services and have supplied us with your email address, ResponseTap may occasionally send you emails with information about new features, or just keep you up to date with our products or services, where permitted to do so by law. You may unsubscribe from receiving such marketing communications at any time by clicking on the unsubscribe link in the relevant email, or by contacting us at marketing@responsetap.com. 3. What basis do we have for processing your personal data We will process your personal data where we have a lawful basis for doing so. In general, our lawful basis will be that the processing is necessary for the purposes of pursuing our legitimate interests (as explained above). We may also process personal data on the basis of your consent. 4. Disclosure of your personal data We will never sell your data to third parties. We may share your personal data with: other group companies within the ResponseTap group for the purpose of providing the Services; our suppliers and service providers who we use in connection with and for the purposes of providing the Services, including for example providers of cloud storage, data centres and telecommunication providers. We require our suppliers to respect the security of your personal data and treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data to the extent required to provide the Services. We may also share your personal data with: Our legal and other professional advisors, our insurers and insurance brokers; Government agencies, regulators and other authorities. In some cases, we may choose to buy or sell business assets. In these types of transactions, user information is typically one of the transferred business assets. If ResponseTap, or substantially all of its assets, were acquired, user information is likely to be one of the assets that is transferred or acquired by a third party, and the acquirer may continue to use your personal data for the purposes set out in this policy. 5. Release of your information for legal purposes We may disclose personal data about you: when required to do so in order to comply with any applicable, laws, regulations or enforceable governmental or public authority request; where such disclosure is reasonably necessary to (i) enforce applicable terms of service, including investigation of potential breaches; (ii) detect, prevent, or otherwise address fraud, security or technical issues; (iii) respond to user support requests; or (iv) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organisations for fraud protection and spam/malware prevention. 6. Right to access, edit, and remove your information The European Union’s General Data Protection Regulation provides you with rights in relation to your personal data in certain circumstances: The right to request access to personal data we hold about you. You may have the right in accordance with applicable data protection law to have personal data we hold about you rectified or restricted. You may, in some circumstances, have the right to have personal data we hold about you deleted (although note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request). In some circumstances, you may have the right to receive or ask for your personal data to be transferred to a third party. You have the right to object to how we process your personal data in certain circumstances, including the right to ask us not to process your personal data for marketing purposes. Where we are processing personal data relating to you on the basis that we have your consent to do so, you may withdraw your consent at any time (this will not affect the lawfulness of any processing carried out before you withdraw your consent). If you withdraw your consent, we may not be able to provide certain products or services to you. When you request access to personal information that we hold about you, we may ask you to verify your identity before providing such information to you, or making any requested changes. We may also contact you to ask you for further information in relation to your request. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above in respect of our processing of your personal data, please contact us at dpo@responsetap.com. You may have the right to lodge a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please do contact us in the first instance and we shall endeavour to resolve your complaint. 7. Updates to your personal data It is important that the personal data we hold about you is accurate and correct. Therefore, please keep us informed if your personal data changes during your relationship with us. If you are a registered user, you can also update personal details via your online account with us. 8. Security Measures We adopt a wide range of appropriate technical and organisational measures designed to protect the security of our site and the ResponseTap Services. Our data storage facilities have extensive protection and detection systems. Further details of these, and our other measures designed for security and privacy are available upon request. 9. International Transfer ResponseTap Limited stores and processes personal data on servers based in the European Union. In respect of Customers who have contracted with ResponseTap Inc in the USA, the data will be processed by ResponseTap Inc in the USA, and we may therefore store information on servers in the United States or Europe. We may also share personal data within the ResponseTap group which will involve transferring data outside the European Economic Area (“EEA”) to ResponseTap Inc in the USA. As the USA has not been deemed to provide an adequate level of protection for personal data by the European Commission, we have put in place specific contractual provisions which have been approved by the European Commission which give personal data the same protection as it has in Europe. Some of our telecommunication providers are based outside the European Economic Area and to the extent that the services that they provide to us involves any processing of personal data, we will ensure that appropriate measures are in place. For transfers of personal data outside the EEA, as described above, we will ensure that appropriate safeguards are implemented, including: Transferring personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or Putting in place specific contracts approved by the European Commission which give personal data the same protection as it has in Europe. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA. 10. Children and Special Categories of Personal Data Our site is intended for a general business audience and we do not knowingly collect personal data from children, nor do we seek to collect or anticipate that we will collect any data that would be considered to be ‘special categories of data’ (meaning details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health data, genetic or biometric data). 11. Cookies Use of cookies by ResponseTap on our site Cookies are small data files placed on your computer by the websites you visit and can be used to help recognise you when you return to a website. We, or third party service providers, may use cookies to, among other things, measure activity, personalise your experience, remember your viewing preferences, or track your login status when accessing our site. For some of these purposes, our cookies may be tied to personal data. Blocking Cookies When you first visit our website, you will be given the opportunity to opt-out of having cookies set on your device. You can also set your browser to reject cookies, or to alert you when websites set or access cookies. You can also manually delete individual or all of the cookies on your computer by following your browser’s help file directions. ResponseTap may also use its analytics software to analyse a website visitor’s interaction with the ResponseTap website, including when the visitor makes a telephone call to ResponseTap. You may opt-out of this activity by clicking here and a cookie will be set on your device to advise us of your selection the next time you visit our website from that device. Please see our cookies policy here for more information about cookies. 12. Retention of data 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. 13. Links to third party websites Our Site may include links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their websites. 14. Changes We may amend this Privacy Policy from time to time. When there are changes to this Privacy Policy, we will update this page. The date on the bottom will always indicate when we last made changes. 15. Contact Us If you have any questions or concerns regarding the way in which we process personal data, please contact us at dpo@responsetap.com or via postal mail at: ResponseTap Limited 7th Floor, Building 8 Exchange Quay Salford Quays Manchester, UK M5 3EJ To comply with the General Data protection Regulation (2016/679) we have also appointed a European representative. If you wish to contact them, their details are as follows: Bird & Bird GDPR Representative Services SRL Avenue Louise 235 1050 Bruxelles Belgium eurepresentative@responsetap.com Effective Date This Privacy Policy is effective from: 1st January 2021. UK & EUROPE © ResponseTap 2021 0800 138 7600 By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyse site usage, and assist in our marketing efforts.More Information Cookie Settings Accept All Cookies