Review.Network

Review.Network and REW Token Privacy Policy


Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting review.network (website) and using the Review.Network Platform you are accepting and consenting to the practices described in this policy.

The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST (“us”, “we”, or “our”) will issue the REW Token (“Token”, “Tokens”, “REW Tokens”) and operates the Review.Network platform(“the platform”) and review.network (“the Website”, “Website Owner”). This “Privacy Policy” informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the platform and the website.

The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST is committed to respecting your privacy and protecting your personal information. We will be transparent about the information we are collecting and what we will do with it.

We will use the information you give us for the purposes described in our Privacy Policy, which include providing you with information and services you have requested and enhancing your experience with The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST and the Review.Network. We will also use the information to help us understand you better and so that we can give you relevant information. If you tell us that you don’t want to receive marketing messages, we will stop sending them. We will, of course, continue to send essential information relating to a product or service you have purchased. We will put in place measures to protect your information and keep it secure. We will respect your data protection rights and aim to give you control over your own information.

You can access our full Privacy Policy below to help you to understand better how we use your personal information. In it, we explain in more detail the types of personal information we collect, how we collect it, what we may use it for and who we may share it with.

If you have further questions please get in touch with us by emailing [email protected] or writing to, The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST, CYPRUS.

Full Privacy Policy

This Privacy Policy applies to all websites and web applications which link to this policy and are published by The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST, CYPRUS.

The Sites may contain links to other Web sites for your convenience and information. We are not responsible for the privacy practices or the content of those sites.

If you wish to amend any of the personal information that we hold about you, or update your marketing preferences, you can do so at any time through your account.

If you have any queries about how we use your personal information, please contact us at [email protected]

Information We Collect

This section details the information we may collect about you. We explain why, and how, we use it in later sections.

Account Information

If you decide to create an account or inquire about one of our products or services, we’ll ask you to provide us with some specific information, for example:

  • Basic personal details – such as your first name and last name;
  • Personal details– such as address, and proof of residency, phone number, mobile phone number, and email address;
  • Work details – such as job title, department, company name, company address, work email address and office phone number;
  • Log in details – such as username and password;
  • Payment details – such as your billing address and credit card information.
  • Passport and KYC contact details - such as Passport, Proof of Residency, Selfie /Photo Verification;
  • Financial information – such as source of funds, wealth, and other data required for due diligence purposes.

Additional information

On occasion, we might ask you to voluntarily provide additional information, for example:

  • Your opinion on our platform and services;
  • Your preferences, including newsletters or web alert topics;
  • Information we obtain from partners and public sources

In some circumstances, we collect information about you from our partners or from publicly available websites to help us better understand our audience and enhance the relevance of our content.

Information We Obtain Through Cookies And Similar Tools

We might use cookies (and similar technologies) and analytics tools across our Sites and Platform to collect information about you. This information can be used to improve the performance of the site and platform, make advertising more relevant and enhance your user experience.

  • Your usage – we might use cookies to understand how our customers use our Sites and Platform and interact with our provided interfaces. This helps us to identify usability issues and improve the assistance we can provide to users and is also used for aggregated and statistical reporting purposes.
  • Your device – we use cookies to understand what type of device you are using to show you the best version of the site.
  • Your location and IP address – we use cookies to differentiate between legitimate activity and potential fraudulent activity on our Sites and Platform. For example, we use your location and IP address to determine if you are logging in from a prohibited jurisdiction or if more than one person is using the same account.
  • Your engagement with advertisements – we use cookies to understand what advertisements you have been shown, or clicked on, to present you with advertisements that are more relevant to you.

If you wish to manage your cookies, please read below:

What Are Cookies?

Cookies are small text files which a website may place on your computer or device when you visit a site. The cookie will help the website, or another website, to recognize your device the next time you visit. Web beacons, pixels or other similar files can also do the same thing. We use the term “cookies” in this policy to refer to all files that collect information in this way.

Cookies serve many functions. For example, they can help us to remember your username and preferences, analyze how well our Sites and Platform are performing, or allow us to recommend content we believe will be most relevant to you.

The majority of websites use cookies to collect and retain personal information about their visitors. Most cookies collect general information, such as how visitors arrive at and use our Sites, the device they are using, their internet protocol address (IP address), what pages they are viewing and their approximate location (for example, we would be able to recognize that you are visiting our Sites and Platform from London).

Purpose of cookies

We group our cookies into the below categories.

  • Operating our Sites - Some cookies are essential for the operation of our Sites and Platform. This includes cookies for the following purposes:
    • Performance – we use these cookies to monitor Site and Platform performance. This allows us to provide a high-quality experience by quickly identifying and fixing any issues that arise. For example, we might use performance cookies to track error messages, and to determine improvements to our Sites and Platform.
    • Functionality – we use functionality cookies to allow us to remember your preferences. For example, we use functionality cookies to provide you with enhanced services, such as allowing you to watch a video online or comment on a blog.
    • Analytics – we use cookies to help us understand our audience and the success of advertising campaigns. For example, we could count articles views to present ‘Most Read’ content. We could also use analytics cookies to keep track of how many advertising impressions have been served for a campaign and to manage the frequency at which you see the same adverts.
    • Fraud prevention – we use cookies to monitor and prevent suspicious activity and fraudulent traffic.

Advertising

We use cookies to serve you with advertisements that we believe are relevant to you and your interests.

Third Party Cookies On Our Sites

We might also use third party cookies on our Sites that fall into the categories above (“third party cookies”) for the following reasons:

  • to help us monitor traffic on our Sites (like many companies, we use Google Analytics to do this);
  • to identify fraudulent or non-human traffic;
  • to assist with market research;
  • to improve Site and Platform functionality;
  • to monitor compliance with our terms and conditions and copyright policy.

These third party cookies are used within programs for measurement and attribution, and management of frequency. They may also be used for personalization of advertisements based on data you have shared with third parties, to the extent that you have consented to this.

Use Of Pixels In Emails

Our emails might contain a single, campaign-unique “web beacon pixel” to tell us whether, and how many times, our emails are opened and verify any clicks through to links or advertisements within the email. We use this information for purposes including:

  • Determining which of our emails are more interesting to users;
  • Determining users’ activity and engagement with our platform and services;
  • Informing our advertisers (in aggregate) how many users have clicked on their advertisements.
  • The pixel will be deleted when you delete the email.

How To Manage Cookies

You can also manage your cookies via your browser settings. For more information, please visit your browser’s help page.

Lawful Basis For Processing

We only process personal information where we have a lawful basis for doing so, such as the following:

  • User consent – This is where you have given us explicit permission to process personal information for a given purpose. For example, if you requested to receive information about The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST’s Review.Network platform and services, we would ask for your consent if we wanted to use your personal information for any other purpose. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting customer service.
  • Legitimate business purposes – This is where we have a legitimate interest, as a business, to process personal information. For example, where we are aware of copyright infringements on our Site and Platform, it is in our legitimate interests as a business to identify those responsible. We take due care to balance our interests against your right to privacy.
  • Contractual necessity – This is where we have to process personal information to meet our contractual obligations.
  • Legal obligation – This is where we have to process personal information in order to comply with the law. For example, we process and retain customer invoice information to comply with financial regulations.

How We Use Your Personal Information

We collect personal information for eight main reasons:

  • To provide our service – We require some of your basic personal information so our services work as you would expect, for example, providing access to our platform and digital content, notifying you of changes to our services and dealing with customer services queries.
  • To improve and maintain performance – In order to provide you with the best possible user experience, we need to make sure that our platform and services work as they should. Using personal information helps us understand how our readers use our Platform and Sites so we can make improvements. This includes testing proposed developments on our Platform and Sites, reaching out to our customers with market research surveys and hosting subscriber focus groups.
  • To bill our customers – We, along with our authorized payments processors, securely process your payment information to take payments, give refunds and to detect and prevent fraudulent activity.
  • To monitor compliance with our policies and terms – We monitor for breaches of our terms and conditions and copyright policies.
  • To personalize our platform, products and services – We improve your experience of our platform, products and services by personalizing parts of our Platform, Sites and apps with the information you give us and what we learn about you. This might include showing you articles you may be interested in and recommending newsletters you may wish to sign up to. Where our Platform and Sites have such functionality, you can manage elements of personalization in your account.
  • To communicate platform and product changes and offers – We want you to get the most out of our Platform, products and services, including showcasing our latest content and newsletters. We might contact you with carefully-curated offers and promotions, exclusive event invitations and feature announcements. You are able to change your preferences at any time through your account or by contacting customer services. We also personalize our communications for strategic purposes.
  • To understand our users – We perform statistical, demographic and marketing analyses of Platform and Site users and their patterns for product development purposes. We use this information for analysis purposes, including analysis to improve customer relationships.
  • For the purposes of advertising – We need to process your information to understand the effectiveness of the advertising we serve to you and others, and to deliver relevant personalized advertising. We use the information you give us and the information we collect about you to serve you with the most appropriate advertisements.

Who We Share Your Personal Information With

We disclose personal information to facilitate the running of our business or to provide specific services you have requested. Commonly, we will disclose information to:

  • Service providers – We engage service providers who help to support our business and improve our platform and services. These service providers include, for example, fulfilment providers for delivery of our digital content and marketing; customer service agencies; organizations that host our Sites or databases; providers of online surveys, compliance and KYC providers, etc.
  • Advertisers – We, and our advertising partners, use cookies to collect personal information and serve you with advertisements that we believe are relevant to you and your interests. There is more specific information about our advertising partners and data sharing in our Cookie Policy.
  • Social media providers – We share the information of our subscribers with social media partners to create lookalike audiences for the purposes of targeted advertising on social media platforms
  • Legal processes and successors in title – We may transfer or disclose your personal information to any entity which takes over or acquires the relevant The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST
  • Legal processes and successors in title – We may transfer or disclose your personal information to any entity which takes over or acquires the relevant The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST business. We also share aggregated, non-identifiable information with third parties. Before sharing this information, we ensure that it cannot identify you as an individual. For example, we regularly release information about the size and growth of our audiences.

How Long We Retain Your Personal Information

We retain the majority of your personal information for as long as your account is active and therefore open; this allows you to continue accessing our content, products and services.

If you become inactive and are not a client, we may delete elements of the information associated with your account. We will normally warn you if your access is going to be withdrawn and give you the opportunity to retain your account.

Where we don’t need to keep all of your information in full, we will obfuscate or aggregate it, for example, web activity logs and survey responses. This is to ensure that we do not retain your information for any longer than is necessary. It is sometimes necessary for us to keep your personal information for longer periods of time, for example:

  • If there is a statutory requirement to retain it;
  • If we require the information for legal reasons or there is a legitimate business need for us to retain it;
  • To ensure we do not contact you if you have asked us not to.

How We Keep Your Personal Information Secure

We have appropriate technical and administrative security measures in place to help ensure that our users’ information is protected against unauthorized or accidental access, use, alteration, or loss. We use encryption technology, such as Transport Layer Security (TLS), to protect your personal information when you use our platform or order products or services from us.

We operate a global business, so your personal information may be processed and stored in multiple locations.

Your Rights

Under data protection laws, you have rights as an individual in relation to the personal data we hold about you. At any time, you have the right:

  • to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from whom it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
  • to request access to or a copy of any personal data which we hold about you;
  • to rectification of your personal data, if you consider that it is inaccurate;
  • to ask us to delete your personal data, if you consider that we do not have the right to hold it;
  • to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
  • to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
  • to restrict processing of your personal data;
  • to data portability (moving some of your personal data elsewhere) in certain circumstances;
  • to object to your personal data being processed in certain circumstances; and
  • not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.

We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Opting Out

You have the option of "unsubscribing" from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. To unsubscribe you can send us an email at [email protected] In addition, each electronic mailing we send you will contain details of how you can unsubscribe by clicking on the ‘unsubscribe’ link in the email.

Please note that it may take up to one month to action your request.

You can exercise these rights through your account or by contacting customer services.

Where This Privacy Policy Applies

Personal information is collected by The RN SOFTWARE TRUSTEES LTD DBA (doing business as) THE REVIEW NETWORK TRUST, which is considered the “data controller” of your personal information under European Union and UK data protection law.

Our Platform Sites are not intended for children under 16 years of age. We do not intentionally collect or use any information from children.

Our Platform and Sites may contain links to third party websites which are not subject to this privacy policy. We are not responsible for their content, use of personal information, or security practices.

If you have a query in regard to the processing of your personal information, please contact customer service directly at [email protected]

Complaints

If you have any concerns or questions about the security of our Site, this Privacy Statement or any personal information we collect from you, please do not hesitate to contact our Data Protection Officer [email protected]

Additionally, if you have any concerns about our use of your information, you also have the right to make a complaint to the Data Protection Commissioner's Office, which regulates and supervises the use of personal data in Cyprus:

1 Iasonos str., 1082-Nicosia, CYPRUS
P.O. Box 23378, 1682-Nicosia, CYPRUS
Tel: +357 22 818 456
Fax: +357 22 304 565
Website: www.dataprotection.gov.cy
Email: commissionerdataprotection.gov.cy

Changes to Privacy Statement

Any changes to our Privacy Statement will be posted on this page of the Site. We would encourage users to check the Privacy Statement each time they use the Site. If our privacy policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.