Rally Sync Technology Ltd

Company Number 14909138

86-90 Paul Street, London, EC2A 4NE, United Kingdom

1 June 2023

Application Privacy Policy

1INTRODUCTION

1.1 Important information and who we are

Welcome to Rally Sync Technology Ltd’s Privacy and Data Protection Policy (“Privacy Policy

”).

At Rally Sync Technology Ltd (“ ”, “ ”, or “ ”) we are committed to protecting and we us our

respecting your privacy and Personal Data in compliance with the United Kingdom General

Data Protection Regulation (“ ”), the Data Protection Act 2018 and all other mandatory GDPR

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.

1.2 Your Data Controller

Rally Sync Technology 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 support@rallysynctech.com or by post to 86-90 Paul Street,

London, EC2A 4NE, United Kingdom.

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.

1.3 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 “ ”). The responsibilities below may be Processors

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 2.2 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.

2LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“ ” means any information about an individual from which that person can Personal Data

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:

Usage Data: information about how you use our application, products and services.

Performance data: monitoring the performance

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.

2.2 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:

“ ”: Certain situations allow us to collect your Personal Data, such as when Consent

you tick a box that confirms you are happy to receive email newsletters from us, or

‘opt in’ to a service.

“ ”: We may require certain information from you in order Contractual Obligations

to fulfil our contractual obligations and provide you with the promised service.

“ ”: We’re required by law to collect and process certain types of Legal Compliance

data, such as fraudulent activity or other illegal actions.

“ ”: We might need to collect certain information from you to be Legitimate Interest

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.

3HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

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

Set out below is a table containing the different types of Personal Data we collect and the

lawful basis for processing that data. Please refer to section 2.2 for more information on

the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which

we use your data may be broader than described but we will never process your data

without a legal basis for doing so and it is for a related purpose. For further inquiries

please contact us.

Activity Type of

data

Legal

Justification

Lawful basis for processing data

Activity Type of

data

Legal

Justification

Lawful basis for processing data

When the

customer

interacts with the

product

Technical

Data

Usage

Data

Legitimate

Interest

Necessity

We need to know insights from the

value of different features in order

to improve, maintain and scale the

product

3.2 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.

4YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 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 4.3 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:

(i) Where we are processing your personal data for direct marketing purposes.

(ii) 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.

(iii) 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:

(i) If you want us to establish the data's accuracy.

(ii) Where our use of the data is unlawful but you do not want us to erase it.

(iii) 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.

(iv) 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

support@rallysynctech.com.

4.2 How Rally Sync Technology Ltd protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate

disclosure. 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 Rally Sync Technology 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.

4.3 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.

5YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may also share Personal Data with interested parties in the event that Rally Sync

Technology 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 Rally Sync Technology 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.

6HOW 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.

7INTERNATIONAL TRANSFER OF DATA

Your information may be stored and processed in the US or other countries or jurisdictions

outside the US where Rally Sync Technology Ltd has facilities. By using Rally Sync Technology Ltd,

you are permitting and consenting to the transfer of information, including Personal Data,

outside of the US.

8NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

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

June 2023.

By using Rally Sync Technology Ltd, you consent to the collection and use of data by us as set out

in this Privacy Policy. Continued access or use of Rally Sync Technology Ltd will constitute your

express acceptance of any modifications to this Privacy Policy.

9INTERPRETATION

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

SeedLegals - Privacy Policy - PYCP-2-2022-10-22

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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, etc.).

Our staff are not authorised to contract on behalf of Rally Sync Technology Ltd, waive rights or

make representations (whether contractual or otherwise). If anything contained in an email from

a Rally Sync Technology 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 Rally

Sync Technology 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 Rally Sync

Technology Ltd legal department.