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Terms of Service and Privacy Policy for the FOL·Ai web-app

Terms of Service

 

Thank you for choosing FOL·Ai™.

Introduction

These Terms govern use of our APIs, FOL·Ai™, and other services for businesses.

These Terms are an agreement between RSe Global Ltd (“RSe” or “We”) and you (“Customer” or “You”) that governs your use of our Services (as defined below). By signing up to use the Services, you agree to be bound by these Terms. You represent to us that you are lawfully able to enter into contracts and, if you are entering into these Terms for an entity, that you have legal authority to bind that entity. These Terms also refer to and incorporate the other guidelines or policies we may provide in writing (the “RSe Policies”) and any ordering document signed by you and RSe or RSe webpage that you use to purchase the Services (an “Order Form”) (collectively, the “Agreement”).

Services

  1. Use of Services. We grant you a non-exclusive right to access and use the Services during the Term (as defined below). This includes the right to use RSe’s application programming interfaces (“APIs”) to integrate the Services into your applications, products, or services (each a “Customer Application”) and to make Customer Applications available to End Users (as defined below). “Services” means any services for businesses we make available for purchase or use, along with any of our associated software, tools, documentation, and websites, but excluding any Third Party Offering.
  2. Third-Party Offering. Third parties may offer products, services, or content through the Services (“Third Party Offering”). If you elect, in your sole discretion, to access or use a Third Party Offering (including by making it available via a Customer Application), your access and use of the Third Party Offering is subject to this Agreement and any additional terms applicable to the Third Party Offering.
  3. Responsibilities for Your Account. You must provide accurate and up-to-date account information. You are responsible for all activities that occur under your account, including the activities of any end user (each, an “End User”) who is provisioned with an account under your account (an “End User Account”) or accesses the Services through your Customer Application. You may not make account access credentials available to third parties, share individual login credentials between multiple users on an account, or resell or lease access to your account or any End User Account. You will promptly notify us if you become aware of any unauthorized access to or use of your account or our Services

Restrictions

We own all right, title, intellectual property and interest in and to the Services, and in no event shall such ownership or intellectual property rights transfer to you. You only receive rights to use the Services as explicitly granted in this Agreement. You will not, and will not permit End Users to:

  1. use the Services or Customer Content (as defined below) in a manner that violates any applicable laws or RSe Policies;
  2. use the Services or Customer Content in a manner that infringes, misappropriates, or otherwise violates any third party’s rights;
  3. reverse assemble, reverse compile, decompile, translate, engage in model extraction or stealing attacks, or otherwise attempt to discover the source code or underlying components of the Services, algorithms, and systems of the Services (except to the extent these restrictions are contrary to applicable law);
  4. use Output (as defined below) to develop any artificial intelligence models that compete with our products and services.;
  5. use any method to extract data from the Services other than as permitted through the APIs;
  6. or
    buy, sell, or transfer API keys from, to or with a third party.

Content

  1. Customer Content. You and End Users may provide input to the Services (“Input”), and receive output from the Services based on the Input (“Output”). We call Input and Output together “Customer Content.” As between you and RSe, and to the extent permitted by applicable law, you (a) retain all ownership rights in Input and (b) own all Output. We hereby assign to you all our right, title, and interest, if any, in and to Output.
  2. Our Obligations for Customer Content. We will process and store Customer Content in accordance with our privacy policy. We will only use Customer Content as necessary to provide you with the Services, comply with applicable law, and enforce RSe Policies. We will not use Customer Content to develop or improve the Services.
  3. Your Obligations for Customer Content. You are responsible for all Input and represent and warrant that you have all rights, licenses, and permissions required to provide Input to the Services. You are solely responsible for all use of the Outputs and evaluating the Output for accuracy and appropriateness for your use case, including by utilizing human review as appropriate.
  4. Similarity of Output. You acknowledge that due to the nature of our Services and artificial intelligence generally, Output may not be unique and other users may receive similar content from our services. Responses that are requested by and generated for other users are not considered your Output. Our assignment of Output  above does not extend to other users’ output or any content delivered as part of a Third Party Offering.

Account Administrators

  1. Super-Administrators. FOL·Ai™ accounts are managed by End Users with super-administrative privileges (“Super-Administrators”). Super-Administrators may be able to add, remove and suspend End Users’ access to your organization’s account. In addition, FOL·Ai™  Super-Administrators may be able to (a) upload and remove Content; (b) access logging and information about End Users’ use of FOL·Ai™; (c) add and remove workspaces; (d) manage billing and payments; and (e) assign and remove Administrators (as defined below) to workspaces. Customers are responsible for obtaining and maintaining all necessary consents from End Users to take the actions above and to allow RSe to deliver the Services.
  2. Administrators. FOL·Ai™ workspaces are managed by End Users with administrative privileges (“Administrators”). For workspaces which they administer, Administrators may be able to (a) add and remove End Users’ access; and (b) upload and remove Content.

Confidentiality

  1. Use and Nondisclosure. “Confidential Information” means any business, technical or financial information, materials, or other subject matter disclosed by one party (“Discloser”) to the other party (“Recipient”) that is identified as confidential at the time of disclosure or should be reasonably understood by Recipient to be confidential under the circumstances. For the avoidance of doubt, Confidential Information includes Customer Content. Recipient agrees it will: (a) only use Discloser's Confidential Information to exercise its rights and fulfil its obligations under this Agreement, (b) take reasonable measures to protect the Confidential Information, and (c) not disclose the Confidential Information to any third party except as expressly permitted in this Agreement.
  2. Exceptions. The obligations in clause above do not apply to any information that (a) is or becomes generally available to the public through no fault of Recipient, (b) was in Recipient’s possession or known by it prior to receipt from Discloser, (c) was rightfully disclosed to Recipient without restriction by a third party, or (d) was independently developed without use of Discloser’s Confidential Information. Recipient may disclose Confidential Information only to its employees, contractors, and agents who have a need to know and who are bound by confidentiality obligations at least as restrictive as those of this Agreement. Recipient will be responsible for any breach of this Section 4 by its employees, contractors, and agents. Recipient may disclose Confidential Information to the extent required by law, provided that Recipient uses reasonable efforts to notify Discloser in advance.

Security

  1. Our Security Program. We will maintain an information security program (including the adoption and enforcement of internal policies and procedures) designed to (a) protect the Services and Customer Content against accidental or unlawful loss, access, or disclosure, (b) identify reasonably foreseeable and internal risks to security and unauthorized access, and (c) minimize security risks, including through regular risk assessments and testing. 
  2. Our Security Obligations. As part of our information security program, we will: (a) implement and enforce policies related to electronic, network, and physical monitoring and data storage, transfer, and access; (b) deploy production infrastructure behind VPNs where possible; (c) require multi-factor authentication for employees; (d) configure network security, firewalls, accounts, and resources for least-privilege access; (e) maintain a logging and incident response process; (f) maintain corrective action plans to respond to potential security threats; and (g) conduct periodic reviews of our security and the adequacy of our information security program as aligned to industry best practices and our own policies and procedures.

Privacy

If you use the Services to process personal data, you must (a) provide legally adequate privacy notices and obtain necessary consents for the processing of personal data by the Services, and (b) process personal data in accordance with applicable law.

Payment, Taxes and Free Trials

  1. Fees and Billing. You agree to pay all fees charged to your account (“Fees”) according to the prices and terms on the Plans and Billing page, or as otherwise stated in an Order Form. You will receive a 30-day advance notice of any price changes on the Plans and Billing page. These changes will take effect starting from the billing cycle following the notice period.. We have the right to correct pricing errors or mistakes even after issuing an invoice or receiving payment. You authorize us and our third-party payment processor(s) to charge the payment method provided on your account on an agreed-upon periodic basis, but we may reasonably change the date on which the charge is posted. Fees are payable in G.B. pounds sterling and are due upon invoice issuance, unless otherwise agreed in an Order Form. Payments are nonrefundable except as provided in this Agreement.
  2. Taxes. Fees are exclusive of taxes, which we will charge as required by applicable law in connection with the Services. We will use the name and address in your account as the place of supply for tax purposes. 
  3. Disputes and Late Payments. To dispute an invoice, you must contact support@rse.global within thirty (30) days of issuance. Overdue undisputed amounts may be subject to a finance charge of 1.5% of the unpaid balance per month, and we may suspend the Services immediately after providing written notice of late payment.
  4. Free Trials. New Customers are eligible for a 7-day free trial. Newly incorporated companies (“New Managers”) are offered an extended free trial period until the launch date of their fund or strategy. Following the free trial, users can choose between plans available on the Plans and Billing page, or other Order Form. New Managers are required to inform RSe of the expected launch date of their fund or strategy at the time of creating their account. Upon the launch of the fund or strategy, New Managers must upgrade to a paid plan. RSe reserves the right to invoice you for any missed subscription costs in the event of a delay in upgrading to a paid plan or failure to do so.

Term and Termination

  1. Term. The term of this Agreement will commence upon the earlier of your online acceptance of these Terms, the Effective Date of an Order Form, or the date you first use the Services, and will remain in effect until terminated pursuant to this Section 9 (“Term”). If you purchase a subscription to the Services, the subscription term will automatically renew for successive periods unless either of us gives the other notice of its intent not to renew. Notice can be given at any time before the start of the next renewal period. 
  2. Termination. Unless you purchase Services for a committed duration, you may terminate this Agreement at any time by deleting your account. Both you and RSe may terminate this Agreement upon written notice (a) if the other party materially breaches this Agreement and does not cure the breach within thirty (30) days after receiving written notice of the breach or (b) if the other party ceases its business operations or becomes subject to insolvency proceedings. We may suspend your or any End User’s access to the Services or terminate this Agreement or any Order Form: (i) if required to do so by law; (ii) to prevent a security risk or other credible risk of harm or liability to us, the Services, or any third party; or (iii) for repeated or material violations of the RSe Policies. We will use reasonable efforts to notify you of any suspension or termination and give you the opportunity to resolve the issue prior to suspension or termination. 
  3. Effect of Termination. Termination or expiration will not affect any rights or obligations, including the payment of amounts due, which have accrued under this Agreement up to the date of termination or expiration. Upon termination or expiration of this Agreement, the provisions that are intended by their nature to survive termination will survive and continue in full force and effect in accordance with their terms, including confidentiality obligations, limitations of liability, and disclaimers. Upon termination of this Agreement, we will delete all Customer Content from our systems within 30 days, unless we are legally required to retain it.

Warranties and Disclaimer

  1. Warranties. We warrant that, during the Term, when used in accordance with this Agreement, the Services will conform in all material respects with the documentation we provide to you or otherwise make publicly available.
  2. Disclaimer. Except for the warranties in this Section 9, the Services are provided “as is” and we and our affiliates and licensors hereby disclaim all warranties, express or implied, including all implied warranties of merchantability, fitness for a particular purpose and title, noninfringement, or quiet enjoyment, and any warranties arising out of course of dealing or trade usage. Despite anything to the contrary, we make no representations or warranties (a) that use of the Services will be uninterrupted, error free, or secure, (b) that defects will be corrected, (c) that Customer Content will be accurate, or (d) with respect to Third Party Offerings.

Indemnification

  1. By Us. We agree to defend and indemnify you for any damages finally awarded by a court of competent jurisdiction and any settlement amounts payable to a third party arising out of a third party claim alleging that the Services infringe any third party intellectual property right. This excludes claims to the extent arising from: (a) combination of any Services with products, services, or software not provided by us or on our behalf, (b) the Input or any training data you provide to us, (c) your failure to comply with this Agreement or laws, regulations, or industry standards applicable to you, or (d) Customer Applications (if the claim would not have arisen but for your Customer Application). If we reasonably believe that any part of the Services is likely to become the subject of an infringement claim, we will, at our expense, either (x) procure the right for you to continue using the Services in accordance with this Agreement, (y) replace or modify the allegedly infringing Service to make it non-infringing, or (z), if options (x) and (y) are not commercially practicable, we may, at our sole discretion, terminate this Agreement upon written notice to you and refund any prepaid amounts for unused Services. You agree to promptly comply with all reasonable instructions we provide regarding options (x) through (y), including any instruction to replace, modify, or cease use of the impacted Service. 
  2. By Customer. You agree to indemnify, defend, and hold us and our affiliates and licensors harmless against any liabilities, damages, and costs (including reasonable lawyers’ fees) payable to a third party arising out of a third party claim related to (a) use of the Services in violation of this Agreement (including violation of RSe Policies), (b) Customer Applications (if any), or (c) Input.
  3. Indemnification Procedure. A party seeking indemnity will provide the indemnifying party with prompt written notice upon becoming aware of any claim, reasonable cooperation in the defence of or investigation of the claim (including preserving and sharing the applicable Customer Content), and allow the indemnifying party sole control of defence and settlement of the claim, provided that the party seeking indemnity is entitled to participate in its own defence at its sole expense. The indemnifying party cannot enter into any settlement or compromise of any claim without prior written consent of the other party, which will not be unreasonably withheld, except that the indemnifying party may without consent enter into any settlement of a claim that resolves the claim without liability to the other party, impairment to any of the other party’s rights, or requiring the other party to make any admission of liability. THE REMEDIES IN THIS SECTION 10 ARE THE SOLE AND EXCLUSIVE REMEDIES FOR ANY THIRD PARTY CLAIM THAT THE SERVICES OR CUSTOMER CONTENT INFRINGE INTELLECTUAL PROPERTY RIGHTS.

Limitation of Liability

  1. Limitations on Indirect Damages. Except for (i) a party’s gross negligence or willful misconduct, (ii) your breach of Section 2 (Restrictions), (iii) either party’s breach of its confidentiality obligations under Section 4 (Confidentiality), (iv) our breach of Section 5 (Security), or (v) a party’s indemnification obligations under this Agreement, neither you nor RSe or our respective affiliates or licensors will be liable under this Agreement for any indirect, punitive, incidental, special, consequential, or exemplary damages (including lost profits) even if that party has been advised of the possibility of those damages.
  2. Liability Cap. Except for (i) a party’s gross negligence or willful misconduct or (ii) a party’s indemnification obligations under this Agreement, each party’s total liability under the Agreement will not exceed the total amount you have paid or payable to us in the twelve (12) months immediately prior to the event giving rise to liability. The foregoing limitations will apply despite any failure of essential purpose of any limited remedy and to the maximum extent permitted under applicable law.

Trade Controls

You must comply with all applicable trade laws, including sanctions and export control laws. Our Services may not be used in or for the benefit of, or exported or re-exported to (a) any U.K. embargoed country or territory or (b) any individual or entity with whom dealings are prohibited or restricted under applicable trade laws. Our Services may not be used for any end use prohibited by applicable trade laws, and your Input may not include material or information that requires a government license for release or export.

Dispute Resolution

YOU AGREE TO THE FOLLOWING BINDING ARBITRATION AND GROUP LITIGATION WAIVER PROVISIONS:

  1. MANDATORY ARBITRATION. You and RSe agree to resolve any claims arising out of or relating to this Agreement or our Services, regardless of when the claim arose, even if it was before this Agreement existed (a “Dispute”), through final and binding arbitration.
  2. Informal Dispute Resolution. We would like to understand and try to address your concerns prior to formal legal action. Before either of us files a claim against the other, we both agree to try to resolve the Dispute informally. You agree to do so by sending us notice to support@rse.global. We will do so by sending you notice to the email address associated with your account. If we are unable to resolve a Dispute within 60 days, either of us has the right to initiate arbitration. We also both agree to attend an individual settlement conference if either party requests one during this time. Any statute of limitations will be tolled during this informal resolution process.
  3. Arbitration Forum. Both you or RSe may commence binding arbitration through The London Court of International Arbitration (LCIA) , an alternative dispute resolution provider, and if NAM is not available, you and RSe will select an alternative arbitral forum. The initiating party must pay all filing fees for the arbitration and payment for other administrative and arbitrator’s costs will be governed by the arbitration provider’s rules. If your claim is determined to be frivolous, you are responsible for reimbursing us for all administrative, hearing, and other fees that we have incurred as a result of the frivolous claim.
  4. Arbitration Procedures. The arbitration will be conducted by telephone, based on written submissions, video conference, or in person in London, UK or at another mutually agreed location. The arbitration will be conducted by a sole arbitrator by LCIA  under its then-prevailing rules. All issues are for the arbitrator to decide, except a court of England and Wales has the authority to determine (a) whether any provision of this arbitration agreement should be severed and the consequences of said severance, (b) whether you have complied with conditions precedent to arbitration, and (c) whether an arbitration provider is available to hear the arbitration(s) under Section 14.3. The amount of any settlement offer will not be disclosed to the arbitrator by either party until after the arbitrator determines the final award, if any.
  5. Exceptions. Nothing in this Agreement requires arbitration of the following claims: (a) individual claims brought in small claims court; and (b) injunctive or other equitable relief to stop unauthorized use or abuse of the Services or intellectual property infringement.
  6. NO GROUP LITIGATIONS. Disputes must be initiated on an individual basis only, and cannot be brought as a plaintiff or a member in any purported group, consolidated, or representative legal proceeding. Group arbitrations, group litigations, actions under the representation of a private attorney general, and consolidation with other arbitrations are not permitted. If, for any reason, a Dispute proceeds in court rather than through arbitration, each party knowingly and irrevocably renounces any right to a jury trial in any litigation, proceeding, or counterclaim. This clause does not restrict either party's ability to participate in a settlement of claims on a class-wide basis.
  7. Severability. If any part of this Section 13 is found to be illegal or unenforceable, the remainder will remain in effect, except that if a finding of partial illegality or unenforceability would allow class or representative arbitration, this Section 13 will be unenforceable in its entirety. Nothing in this section will be deemed to waive or otherwise limit the right to seek public injunctive relief or any other non-waivable right, pending a ruling on the substance of that claim from the arbitrator.

Modifications to these Business Terms and the RSe Policies

  1. Updates. We may update these Terms or the RSe Policies by providing you with reasonable notice, including by posting the update on our website. If, in our sole judgment, an update materially impacts your rights or obligations, we will provide at least 30 days’ notice before the update goes into effect, unless the update is necessary for us to comply with applicable law, in which case we will provide you with as much notice as reasonably possible. Any other updates will be effective on the date we post the updated Business Terms or RSe Policies. Your continued use of, or access to, the Services after an update goes into effect will constitute acceptance of the update. If you do not agree with an update, you may stop using the Services or terminate this Agreement under Section 8.2 (Termination). 
  2. Exceptions to Updates. Except for an update to comply with applicable law, updates to these Terms or the RSe Policies will not apply to: (a) Disputes between you and RSe arising prior to the update; or (b) Order Forms signed by you and RSe (as opposed to an automated ordering page) prior to us notifying you of the update. However, to the extent an update relates to a Service or feature launched after an Order Form is signed it will be effective upon your first use of such Service.

Miscellaneous

  1. Headings. Headings in these Terms are inserted solely for convenience and are not intended to affect the meaning or interpretation of these Business Terms.
  2. Feedback. If you provide us with feedback regarding the Services (“Feedback”), you grant us the right to use and exploit Feedback without restriction or compensation.
  3. Publicity. RSe may use your name and may disclose that you are a customer of RSe in advertising, promotion and similar public disclosures. To opt-out, send an email to support@rse.global. You shall not publicly use RSe's name or marks without our written approval.
  4. Entire Agreement. This Agreement is the entire agreement between you and RSe with respect to its subject matter and supersedes all prior or contemporaneous agreements, communications and understandings, whether written or oral. You agree that any terms and conditions contained within any purchase order you send to us will not apply to this Agreement and are null and void.
  5. Relationship of the Parties. For all purposes under this Agreement, you and RSe will be and act as independent contractors and will not bind nor attempt to bind the other to any contract.
  6. No Third Party Beneficiaries. There are no intended third party beneficiaries to this Agreement, and it is your and RSe’s specific intent that nothing contained in this Agreement will give rise to any right or cause of action, contractual or otherwise, in or on behalf of any third party.
  7. Force Majeure. Except for payment obligations, neither you nor RSe will have any liability for failures or delays resulting from conditions beyond your or RSe’s reasonable control, including but not limited to governmental action or acts of terrorism, earthquake or other acts of a perceived higher being, labour conditions, or power failures. 
  8. Assignment. This Agreement cannot be assigned other than as permitted under this Section 16.8 (Assignment). We may assign this Agreement to an affiliate without notice or your consent. Both you and RSe may assign this Agreement to a successor to substantially all the respective party’s assets or business, provided that the assigning party provides reasonable (at least 30 days) prior written notice of the assignment. This Agreement will be binding upon the parties and their respective successors and permitted assigns. 
  9. Notices. All notices will be in writing. We may provide you notice using the registration information or the email address associated with your account. Notice will be deemed given on the date of receipt if delivered by email or on the date sent via courier if delivered by post. We accept notice at this address: RSe Global Ltd, Suite 5, 5th Floor, City Reach, 5 Greenwich View Place, London, E14 9NN, United Kingdom, or by email at support@rse.global.
  10. Severability. In the event that any provision of this Agreement is determined to be illegal or unenforceable, that provision will be limited or eliminated so that this Agreement will otherwise remain in full force and effect and enforceable.
  11. Jurisdiction, Venue, and Choice of Law. This Agreement shall be governed by and construed in accordance with the laws of England and Wales, excluding its conflicts of law rules or principles. Except as provided in Section 13 (Dispute Resolution), all claims arising out of or relating to this Agreement shall be brought exclusively in the courts of England and Wales.

Privacy Policy

 

Introduction

Important information and who we are

Welcome to RSe Global Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At RSe Global Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include Customers and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Your Data Controller

RSe Global Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to contact@rse.global.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

  • Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see ‘The Legal Basis for Collecting That Data’ below for more information);
  • Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
  • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
  • Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
  • Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
  • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
  • Maintain a record of all categories of processing activities carried out on behalf of a Controller;
  • Cooperate, on request, with the supervisory authority in the performance of its tasks;
  • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
  • Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

Legal basis for data collection

Types of data / Privacy policy scope

“Personal Data” 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).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

  • Profile/Identity Data: This is data relating to your first and last names and job title.
  • Contact Data: This is data relating to your work addresses, email addresses and phone numbers.
  • Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
  • Transactional Data: This is information of details and records of all payments you have made for our services or products.

We may also collect and use Aggregated Data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

  • “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
  • “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
  • “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
  • “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

How we use your personal data

Our data uses

We will only use your Personal Data when the law allows us to.

Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Your rights and how you are protected by us

Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
  • Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section ‘How to request your data and the process for obtaining it’ below for more details on how you can make a data subject access request.
  • Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.
  • Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
    1. Where we are processing your personal data for direct marketing purposes.
    2. Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
    3. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
    1. If you want us to establish the data's accuracy.
    2. Where our use of the data is unlawful but you do not want us to erase it.
    3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at contact@rse.global.

Your control over RSe Global Ltd’s use of your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our related software.

We guarantee this will delete all stored data.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password and multi-factor authentication (MFA) for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to contact@rse.global.

How RSe Global Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including encryption and adhering to industry best practices and regulations. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of RSe Global Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

Opting out of marketing promotions

You can ask us to stop sending you marketing messages at any time by opting out from within your company user profile, or clicking on the unsubscribe link at the bottom emails.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Your data and third parties

Sharing your data with third parties

We may also share Personal Data with interested parties in the event that RSe Global Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If RSe Global Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

Third-Party Links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

How long we retain your data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Age limit for our users

You must not use RSe Global Ltd unless you are aged 18 or older. If you are under 18 and you access RSe Global Ltd by lying about your age, you must immediately stop using RSe Global Ltd.

This website is not intended for children and we do not knowingly collect data relating to children.

International transfer data

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where RSe Global Ltd has facilities. By using RSe Global Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.

Notification of changes and acceptance of policy

We keep our Privacy Policy under review and will place any updates here. This version is dated 1 November 2023.

By using RSe Global Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of RSe Global Ltd will constitute your express acceptance of any modifications to this Privacy Policy.

Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).

Our staff are not authorised to contract on behalf of RSe Global Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a RSe Global Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any RSe Global Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the RSe Global Ltd legal department or Directors.

Terms of use

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of RSe Global Ltd and any affiliated applications.