Reformo Software Privacy Policy

Effective as of 8th February 2021

  1. Introduction & About
  2. You, your data, and your rights
  3. Personal data we collect from you
  4. What we use your personal data for
  5. Sharing of your personal data
  6. Data retention & deletion
  7. Transfer to other countries
  8. Sub-Processors
  9. Data Safety
  10. Children
  11. Policy Changes
  12. Contact Details

1. Introduction & About

For you to enjoy the use of Reformo Software Ltd services (referred to as “Reformo Software”, “us”, “we”, our”) and for Reformo Software to provide you with as great a service as possible we need to collect and process some of your personal information.

Your privacy and the security of your data is, and always will be of the utmost importance to us. This is reflected in our own core business values of transparency and fairness.

The aim of this Privacy Policy (“Policy) is to set out what personal data of yours we process, how long we process it for, what it’s used for, and who has access to it. The Policy will also set out your rights and the choices you can make regarding the personal data that we collect and process.

This Policy applies to all Reformo Software products and services.

Reformo Software acts as a data controller. This means that we exercise overall control over the purpose and means of processing any personal data. Reformo Software is registered with the United Kingdom’s Information Commissioner’s Office.

For details on how to get in contact with us if you have a question or a concern please see Section 12.

2. You, your data, and your rights

The General Data Protection Regulations (or “GDPR”) set out the rights that you have to your personal data. We are proud that our platforms give you the opportunity to easily access and control your personal data. GDPR sets out seven clear principles:

  • Lawfulness, fairness, and transparency
  • Purpose limitation
  • Data minimisation
  • Accuracy
  • Storage limitation
  • Integrity and Confidentiality
  • Accountability

GDPR gives you the rights to:

  • Access – gives individuals the right to obtain a copy of their personal data as well as other supplementary information. It helps individuals to understand how and why you are using their data, and check you are doing it lawfully
  • Rectification – gives the right for individuals to have inaccurate personal data rectified or completed if it is incomplete.
  • Erasure – the right for you to delete your personal data
  • Restrict – gives individuals the right to restrict the processing of their personal data in certain circumstances. This means that an individual can limit the way that an organisation uses their data.
  • Object – gives individuals the right to object to the processing of their personal data in certain circumstances.
  • Data portability – allows individuals to obtain and reuse their personal data for their own purposes across different services.
  • Right to individual decision making – restricts us from making automated legal or significant decisions with your data.

Your Privacy Settings (Found at https://auth.reformosoftware.com/ ) ensure you can control, make changes to, and request access to your personal data.

Your Contact Preferences (Found at https://auth.reformosoftware.com/ ) give you control of how often or little we contact you. You can toggle on or off the different types of communications you might receive (although we try to keep non-essential communications to a bare minimum).

Reformo Software does store cookies on your device when using our products and services (we try to keep these to a minimum).

The type of cookie used is dependent on its purpose:

  • Strictly necessary – these cookies are essential for use of the features of our platforms, such as authentication
  • Functionality – these cookies allow us to remember choices that you have already made (e.g. your username or your language)

3. Personal Data we collect from you

Please see the tables for an overview of the categories of personal data that we collect, and how we collect it.

The below table describes personal data collected when you sign up for any Reformo Software services

Categories of Personal Data

Description of Categories

User Data

This data is provided by you and allows you to sign up to and use Reformo Software’s services. This may include username, email address, phone number, birth data, street address, country

The below table describes personal data collected through the use of any Reformo Software services.

Categories of Personal Data

Description of Categories

Usage Data

This is the personal data that is collected about you when you’re accessing and/or using the Reformo Software services, including:

  • Information about your type of Reformo Software service plan
  • Information about your interactions with the service, such as your search queries (and associated date and time), actions (and associated date and time)
  • Technical data such as details about the browser software you are using, the IP address you are accessing our service from, and reports of any errors you encounter while using our services. This data is used to ensure the smooth running of our services and prevent abuse

The below table describes personal data that you choose to give us that enables us to provide you with additional features and functionality

Categories of Personal Data

Description of Categories

Payment & Purchase Data

We may collect certain personal data if you sign up for a trial or purchase any of our Paid Subscription services.

The information that is collected may include your name, date of birth, credit or debit card type, expiration data, certain card details, postal or ZIP code, mobile phone number, details of your purchase and payment history. Any payment information will be stored in compliance with relevant legislation.

Survey Data

When you complete any forms or respond to a survey, we collect the personal data you provide.

The below table describes personal data about you that we collect from various third parties. These third parties will vary over time, but include the following

Categories of third-party sources

Description of Categories

Payment Partners

If pay for our services, we may receive data from our payment partners to enable us to send you invoices, process your payment, and provide you with what you’ve purchased.

4. What we use your personal data for

When you use Reformo Software’s services, we use different technologies to process your personal data that we have collected. Please see the below table which sets out the reasons why we process your personal data, and the associated legal bases we rely upon to process your personal data, and the categories of personal data (as identified in Section 3: Personal data we collect from you) used for each purpose:

Description of why Reformo Software processes your personal data

Legal Basis for said processing

Categories of personal data used by Reformo Software for said processing

To provide and personalise Reformo Software services.

  • Performance of a Contract
  • Legitimate interest
  • Consent
  • User data
  • Usage data
  • Payment & Purchase Data

To understand, diagnose, troubleshoot, and fix issues with the Reformo Software services.

  • Performance of a Contract
  • Legitimate interest
  • User data
  • Usage data
  • Survey data

To evaluate and develop new features, technologies, and improvements to the Reformo Software services.

  • Legitimate interest
  • Consent
  • User data
  • Usage data
  • Survey data

To comply with legal obligations and law enforcement requests.

  • Compliance with legal obligations
  • Legitimate interest
  • User Data
  • Usage Data
  • Payment & Purchase Data
  • Survey Data

To establish, exercise, or defend legal claims.

  • Legitimate interest
  • User Data
  • Usage Data
  • Payment & Purchase Data
  • Survey Data

To conduct business planning, reporting, and forecasting.

  • Legitimate interest
  • User Data
  • Usage Data
  • Payment & Purchase Data

To process your payment.

  • Performance of a contract
  • Compliance with legal obligations
  • User Data
  • Payment & Purchase Data

To detect fraud, including fraudulent payments and fraudulent use of the Reformo Software services.

  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate interest
  • User Data
  • Usage Data
  • Payment & Purchase Data

To conduct surveys.

  • Performance of a contract
  • Legitimate interest
  • Consent
  • User Data
  • Usage Data
  • Survey Data

5. Sharing of your personal data

Our goal is to share as little data with third parties as possible. We don’t share your personal data with advertisers.

Information that we may share includes:

Categories of Recipients

Reason for sharing

Payment processors

We will share your personal data with our payment processors as necessary to enable them to process your payments, and for anti-fraud purposes.

Law enforcement and data protection authorities

We share your personal data when believe it necessary to do so in order to comply with our legal obligations under applicable law, or respond to valid legal processes, such as a search warrant or a court order.

Purchasers of our business

We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In the event of this situations, we will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different privacy policy.

6. Data retention and deletion

We keep your personal data only as long as necessary to provide you with our services, and for legitimate and essential business purposes, such as maintaining the performance of our services, using the data to inform our business decisions, complying with legal obligations, and resolving disputes.

Upon request we will delete or anonymise your personal data so that you are no longer identifiable, unless legally allowed or if we are required to maintain certain personal data in situations including the below:

  • If there are unresolved issues relating to your account. These could include outstanding credit, or an unresolved claim
  • Where we need to retain your personal data for our legal, tax, audit, and accounting obligations. We will retain the necessary personal data for the period required by applicable law
  • Where necessary for our legitimate business interests such as fraud prevention

7. Transfer to other countries

We may share your personal data with other Reformo Software group companies in order to carry out activities specified in this policy. We may also subcontract processing to, or share personal data with, third parties located in countries other than your country. Therefore, your personal data may be subject to privacy laws that are different from those in your country. We comply with all applicable laws when data is transferred to another country.

8. Sub-Processors

We use some companies to provide parts of our services that process personal data. These companies are listed below.

Name

Purpose

Location

Digital Ocean, Inc.

Digital Ocean provide the infrastructure used to host our services.

United Kingdom

Digital Ocean, Inc.

Digital Ocean provide the infrastructure used for file storage by our services.

The Netherlands

Wildbit, LLC

Wildbit operates as Postmark and provides email infrastructure used by our services.

United States

Intuition Machines, Inc. (IMI)

IMI provides the hCaptcha anti-bot service. This is used to verify that data entered into our services (such as on the registration page) has been entered by a human and not an automated program.

United States

Functional Software, Inc. (Sentry)

Sentry provide error monitoring services. We use these to maintain a high quality of service.

United States

9. Keeping your personal data safe

We are committed to protecting your personal data and have put in place technical and organisational measures to safeguard this. However, please remember that no system is ever completely secure.

Your password protects your account, so we encourage you to use a strong password that is unique to your Reformo Software account, and to never share your password with anyone. We also encourage you to enable Two Factor Authentication on all your accounts where available.

10. Children

The Reformo Software services are not intended for the use of children. We do not offer our services to children whose age makes it illegal to process their personal data or requires parental consent for the processing of their personal data under the GDPR or other local law.

We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use Reformo Software’s services and do not provide us with your personal data.

If you are the parent or guardian of a child under the Age Limit and become aware that you child has provided personal data to us, please contact us using the details in Section 12.

If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the child’s account.

11. Policy Changes

We may make occasional changes to this policy in the future.

If we do this, you’ll be provided notice as appropriate, e.g. by sending a notification through our services or through an email. The nature of the updates will also be listed here.

Date of Change

Description of Changes

8th February 2021

Added Digital Ocean, Inc. (file hosting) and Wildbit, LLC to the list of sub-processors.

1st April 2020

Initial policy.

12. Contact Details

Thanks for reading our Policy. If you have any questions, please contact us at contact@reformosoftware.com. If you prefer, you can write to us at the below address. Please remember to include your contact details so we can get back to you!

Reformo Software Ltd
Enterprise House
127-129 Bute St
Cardiff
CF10 5LE
United Kingdom

We hope you enjoy our services!