1. Background

Last updated: 20 January 2024

1.1 This notice (Privacy Notice) tells you how we look after your personal data when you visit our website at https://rivengroup.com/ (Website) or when you purchase our automated redaction tool, DocDefender, where you are a (prospective) customer of our business, or where you are another type of business contact, such as a supplier, job applicant or service provider.

1.2 This notice sets out what information we collect about you, what we use it for and whom we share it with. It also explains your rights under data protection laws and what to do if you have any concerns about your personal data.

1.3 We may sometimes need to update this Privacy Notice, to reflect any changes to the way our services are provided or to comply with new business practices or legal requirements. You should check this Privacy Notice regularly to see whether any changes have occurred.

2. Who we are and other important information

2.1 We are RIVEN GROUP LIMITED, registered in England and Wales with company number 14734000 with our registered address at 37 Hesketh Road, Southport, PR9 9PB (we, us or our).

2.2 For all visitors to our Website and for users who purchase our services through an organisation, we are the controller of your information (which means we decide what information we collect and how it is used).

3. Contact details

3.1 If you have any questions about this Privacy Notice or the way that we use information, please get in touch using the following details:

• Email address: info@rivengroup.com
• Postal address: 37 Hesketh Road, Merseyside, PR9 9PB

4. The information we collect about you

4.1 Personal data means any information which does (or could be used to) identify a living person. We have grouped together the types of personal data that we collect and where we receive it from below.

4.2 Type of personal data:

• Identity Data: your name and email address from your organisation's identity provider or any personal information provided (e.g. name, email address, phone number) when you contact us.
• Technical Data: internet protocol (IP) address, browser type and version, time zone setting and generic location, operating system and platform on the devices you use to access our systems from your web browser.
• Usage Data: information about how you use our systems from audit logs.

5. How we use your information

5.1 We are required to identify a legal justification (also known as a lawful basis) for collecting and using your personal data. There are six legal justifications which organisations can rely on. The most relevant of these to us are where we use your personal data to:

• fulfil our contract with you;
• pursue our legitimate interests (our justifiable business aims) but only if those interests are not outweighed by your other rights and freedoms (e.g. your right to privacy).

5.2 Below is set out the lawful basis we rely on when we use your personal data. If we intend to use your personal data for a new reason that is not listed below, we will update our Privacy Notice.

5.2.1 Contract

• To administrate or perform our contract with you.
• To process your payment information in connection with any contract we have with you.
• To send you updates about the services you have bought (e.g. confirmation of order, arrival time).

5.2.2 Legitimate Interests

• Where using your information is necessary to pursue our legitimate business interests to:
  1. improve and optimise our Website;
  2. monitor and make improvements to our Website to enhance security and prevent fraud;
  3. assess job applicants for recruitment;
  4. provide our services to you and ensure the proper functioning of our Website; and
  5. protect our business and defend ourselves against legal claims.
• Where we use your information for our legitimate interests, we have assessed whether such use is necessary and that such use will not infringe on your other rights and freedoms.

5.3 Where we need to collect your personal data (for example, in order to fulfil a contract we have with you), failure to provide us with your personal data may mean that we are not able to provide you with the services. Where we do not have the information required about you to fulfil an order, we may have to cancel the service ordered.

5.4 We may anonymise the personal data we collect (so it can no longer identify you) and then combine it with other anonymous information so it becomes aggregated data. Aggregated data helps us identify trends (e.g. what percentage of users responded to a specific survey). Data protection law does not govern the use of aggregated data and the various rights described below do not apply to it.

6. Who we share your information with

6.1 We share (or may share) your personal data with:

• Our personnel: our employees (or other types of workers) who have contracts containing confidentiality and data protection obligations.

6.2 If we were asked to provide personal data in response to a court order or legal request (e.g. from the police), we would seek legal advice before disclosing any information and carefully consider the impact on your rights when providing a response.

7. Where your information is located or transferred to

7.1 We store personal data associated with the use of our products in the region you choose for your deployment of our software.

7.2 We process all other personal data in the United Kingdom where possible.

7.3 We will only transfer information outside of the UK or EEA where we have a valid legal mechanism in place (to make sure that your personal data is guaranteed a level of protection, regardless of where in the world it is located).

8. How we keep your information safe

8.1 We have implemented security measures to prevent your personal data from being accidentally or illegally lost, used or accessed by those who do not have permission. These measures include:

• access controls and user authentication (including multi-factor authentication);
• internal IT and network security;
• regular testing and review of our security measures;
• staff policies and training;
• incident and breach reporting processes;
• business continuity and disaster recovery processes.

8.2 If there is an incident which has affected your personal data and we are the controller, we will notify the regulator and keep you informed (where required under data protection law). Where we act as the processor for the affected personal data, we notify the controller and support them with investigating and responding to the incident.

8.3 If you notice any unusual activity on the Website, please contact us info@rivengroup.com.

9. How long we keep your information

9.1 Where we act as the controller, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

9.2 To decide how long to keep personal data (also known as its retention period), we consider the volume, nature, and sensitivity of the personal data, the potential risk of harm to you if an incident were to happen, whether we require the personal data to achieve the purposes we have identified or whether we can achieve those purposes through other means (e.g. by using aggregated data instead), and any applicable legal requirements (e.g. minimum accounting records for HM Revenue & Customs).

9.3 We may keep Identity Data, Contact Data and certain other data (specifically, any exchanges between us by email or any other means) for up to seven years after the end of our contractual relationship with you.

10. Your legal rights

10.1 You have specific legal rights in relation to your personal data.

10.2 We can decide not to take any action in relation to a request where we have been unable to confirm your identity (this is one of our security processes to make sure we keep information safe) or if we feel the request is unfounded or excessive. Usually there is no cost for exercising your data protection rights, but we may charge a fee where we decide to proceed with a request that we believe is unfounded or excessive. If this happens we will always inform you in writing.

10.3 We will respond to your legal rights request without undue delay, but within one month of us receiving your request or confirming your identity (whichever is later). We may extend this deadline by two months if your request is complex or we have received multiple requests at once. If we need to extend the deadline, we will let you know and explain why we need the extension.

10.4 We do not respond directly to requests which relate to personal data for which we act as the processor. In this situation, we forward your request to the relevant controller and await their instruction before we take any action.

10.5 If you wish to make any of the right requests listed below, you can reach us at info@rivengroup.com.

10.6 Your rights include:

• Access: You must be told if your personal data is being used and you can ask for a copy of your personal data as well as information about how we are using it to make sure we are abiding by the law.
• Correction: You can ask us to correct your personal data if it is inaccurate or incomplete. We might need to verify the new information before we make any changes.
• Deletion: You can ask us to delete or remove your personal data if there is no good reason for us to continue holding it or if you have asked us to stop using it (see below). If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision. Restriction: You can ask us to restrict how we use your personal data and temporarily limit the way we use it.
• Objection: You can object to us using your personal data if you want us to stop using it. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
• Portability: You can ask us to send you or another organisation an electronic copy of your personal data.
• Complaints: If you are unhappy with the way we collect and use your personal data, you can complain to the ICO or another relevant supervisory body, but we hope that we can respond to your concerns before it reaches that stage. Please contact us at info@rivengroup.com.