Privacy policy

By using the Site, you are agreeing to the practices described in this Privacy Policy and you expressly consent to provide all personal data to RIW through the Site, as well as to processing for the purposes indicated in this Privacy Policy and subject to the Terms of Use that apply to the Site.

Throughout this Privacy Policy, we use the term “personal data” to describe information that can be associated with an identified or an identifiable person.  Personal data includes, but is not limited to a name, an identification number, location data, and an online identifier.

We ask that you read this Privacy Policy from time to time.  We may modify it at any time in our sole discretion.  If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent, where required by law, either through your registered email address or by prominent posting on this Site.

The following topics are covered below:

• Personal Data We Collect About You
• Personal Data We Collect Through Automated Means
• How We Protect Children’s Privacy
• How We Use the Personal Data We Collect About You
• Do Not Track
• When We Share Your Personal Data
• How We Use Cookies
• How Protect Your Personal Data
• How Long We Retain Your Personal Data
• Links to Other Websites
• Location and Transfer of Personal Data
• Additional State- and Country-Specific Notices
• Notice to Residents of California
• Rights of Individuals Located in the UK and European Union
• How You Can Contact Us

We collect data about you through a third-party service provider that collects information on our behalf when you interact with the Site, including when you log in to the Site, create an account, or join our mailing list. The personal data we collect includes the following information:

Data that you provide:

Name;
Email address;
Phone number;
Company name;

Information that you choose to submit in connection with your comments or inquiries or when you apply for a job.

You are not required to provide personal data as a condition of using our Site.

We automatically collect information about the devices that you use to interact with the Site, as well as information about how you interact with the Site.  The information that we automatically collect includes the following:

• IP address and other device identifiers;
• Location (based on IP address);
• Web browser type and version;
• Pages you visit while on the Site;
• Time spent on those pages;
• Date, time and for how long you visited the Site;
• Contact information, including telephone number from device; and
• Documents you downloaded from the Site.

This data that we automatically collect may be associated with any personal data that you have provided to us.

The Site is a general audience site and is not directed at or designed to be used by children under the age of 16.  If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete that information.

We use the personal data that we collect about you to do the following:

Communicate With You

• Provide information about products and services that we offer, including sending promotional materials and other communications;
• Respond to your inquiries;
• Send you information relating to investor relations that you request to receive;
• Process your employment application and communicate with you about employment opportunities; and
• Deliver advertisements to you about products that may be of interest to you.

Manage and Improve Our Business Operations

• Operate and manage the Site;
• Operate, evaluate and improve our business, including by managing, enhancing, improving and analysing our products, services, business and the performance and functioning of the Site;
• Develop new products and services based on our analysis of consumer preferences;
• Manage our communications and other internal functions;
• Enforce our agreements;
• Study how users use the Site so that we can give users a better online experience;
• Perform other market research, such as determining industry trends and growth opportunities based on consumer activity; and
• Assist our Sales and Marketing teams to perform their functions.

Ensure a Secure Online Environment and Comply with Legal Requirements

• Protect against and detect fraud, abuse or other unlawful activity;
• Enforce the Site’s Terms of Use, other corporate policies, and industry standards; and
• Comply with all applicable laws and reporting obligations.

Opt-Out Policy 

If you no longer want to receive marketing emails from us, please follow the “unsubscribe” or “opt out” instructions in the email you receive from us.  We will process your request within a reasonable period of time.

Analytics 

We may use third-party analytics services on our Site.  The analytics providers may use technologies such as cookies, web server logs, and web beacons to help us analyse visitors’ use of our Site.  The information collected through these technologies, including your IP address, may be disclosed to the analytics providers and other relevant third parties that use the information to analyse the use of the Site.

Our Site does not collect personal data about your online activities over time and across third-party websites or online services.  Therefore, “do not track” signals transmitted from web browsers do not apply to our Site, and we do not alter our data collection and use practices upon receipt of such a signal.

We may share your personal data with our affiliates and subsidiaries for the purposes described in this Privacy Policy and with contractors, service providers and other third parties that support our business and perform functions on our behalf, as described below.  RIW does not and will not sell to, or share your personal data with, non-affiliated third parties.

Third parties providing services on our behalf.  We may engage third parties to perform services in connection with our business operations.  These services may include (a) products and/or experience customisation; (b) distribution of marketing and promotional material; (c) website evaluation; (d) data collection, storage, management, analysis and, where applicable, deletion; and (e) other services designed to maximise our business potential.  These third parties may have access to certain information, including personal data, to the extent necessary to perform their duties and functions.

Company security.  We may disclose information about our users, including personal data, when legally required to do so, at the request of government authorities conducting an investigation or to verify or enforce compliance with the policies governing our company and applicable laws.  We also may disclose such information when necessary to protect our rights, property or safety of RIW, our affiliates, business partners, customers or others, or to obtain legal advice.

Corporate change: We may disclose, share or otherwise transfer user information, including personal data, in connection with a corporate merger, acquisition, consolidation, the sale of a portion of our business or the sale of substantially all of RIW’s assets, or other fundamental corporate change, whatever form it may take.  You will be notified via email or prominent notice on our Site prior to a change of ownership or control of your personal data, if your personal data will be used contrary to this Privacy Policy.  For clarification and the removal of doubt, RIW reserves the right to transfer or share a copy of personal data collected pursuant to this Privacy Policy, offline or otherwise, to the buyer of that portion of its business related to that data.

Aggregate data.  We may disclose aggregated, non-identifiable user statistics (such as the number of users who visited a page on the Site during a specific time period) to third parties for a variety of purposes, including describing our products to prospective partners and other third parties.

This Cookie Policy explains what cookies are and how and why they may be stored on and accessed from your device when you use or visit our Site.  This Cookie Policy should be read together with the rest of our Privacy Policy.

By consenting to the use of cookies, you agree that we can store and access cookies as described in this Cookie Policy.

What are cookies?

A cookie is a small text file that can be stored on and accessed from your device when you visit our Site, to the extent that you consent.  This allows our Site to distinguish your device from those of other users of the Site.  You can find more information at www.allaboutcookies.org and www.youronlinechoice.eu.

How does our Site use cookies?

When you first visit our Site, we will ask you to consent to our use of cookies in accordance with the terms outlined in this policy.

We may use cookies to identify you, remember your preferences and track your use of our Site.

To administer our Site and for research purposes, we may contract with third-party service providers to track and analyse statistical information about usage of, and volume of traffic on our Site.  These third-party service providers may use persistent cookies to help us improve the user experience, manage content on our Site, and track user behaviour.

Our Use of First- and Third-Party Cookies

First-party cookies are cookies that belong to RIW and that RIW places on your device.  Third-party cookies are cookies that another party places on your device through our Site.

We use the following types of cookies:

Persistent Cookies. We use persistent cookies to improve your experience on the Site and to track how you use it.  This includes recording your acceptance of our Cookie Policy to remove the cookie message that appears when you first use the Site.

Session Cookies.  Session cookies are temporary and are deleted from your device when your web browser closes.  We use session cookies to help us track internet usage, as described above.

We may use the following types of cookies for the described purposes:

Strictly Necessary/Technical

These cookies are necessary to allow us to operate our Site so you can access the Site as you have requested.  These cookies, for example, let us recognise that you have created an account and have logged into that account to access Site content.  They also include cookies that enable us to remember your previous actions within the same browsing session and secure our Site.

Analytical/Performance

These cookies are used by us or our business partners to analyse how our Site is used and how they are performing.  For example, these cookies track what pages are most frequently visited and from what locations our visitors arrive.  If you subscribe to a newsletter or otherwise register with our Site, these cookies may be correlated to you.

Functionality

These cookies let us operate our Site in accordance with the choices you make.  These cookies permit us to “remember” you between visits.  For instance, we will recognise your user name and remember how you customised our Site by, for example, adjusting text size, languages, fonts, and other parts of the Site that are alterable, and provide you with the same customisations during future visits to the Site.

How do I refuse or withdraw my consent to the use of cookies?

If you do not want cookies to be dropped on your device, you can adjust the setting of your internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device.  For further information about how to do so, please refer to your browser ‘help,’ ‘tool,’ or ‘edit’ section or visit www.allaboutcookies.org.  Please note that if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access or use all or part or certain functionalities of our Site.

If you want to remove previously stored cookies, you can manually delete them at any time.  However, this will not prevent our Site from placing cookies on your device in the future, unless and until you adjust your internet browser setting as described above.

In addition, you can find out how to control cookies by clicking “help” on your browser’s menu or by taking the following steps, depending on what browser you use:

On Microsoft Internet Explorer: Select Tools > Internet Options > Privacy > Settings

On Google Chrome: Select Settings > Advanced > Privacy and Security > Content Settings > Cookies

On Safari: Select Preferences > Privacy

If you are located in the EU or the U.K. we will obtain your consent before storing cookies on your browser.  For more information about the development of user profiles and the use of targeting/advertising cookies, please see www.youronlinechoices.eu, if you are located in the EU.

RIW maintains physical, technical and administrative controls to reasonably safeguard personal data.  No website, internet transmission, computer system or network is completely secure, however.  Therefore, RIW cannot guarantee that unauthorised access to information, data loss, or data destruction or alteration will never occur.

RIW will retain your personal data for as long as required to provide you with access to the Site and our services and for as long as necessary for the protection and pursuit of our legal rights and to fulfil obligations under laws applicable to our operations.  After that time, RIW will destroy your personal data in accordance with RIW’s record retention schedule.

RIW’s Site may contain links to other third-party websites that are not under our control and that we do not sponsor, endorse or maintain.  RIW is not responsible for the content or the privacy practices of such websites, and they are not governed by this Privacy Policy or any other RIW policies or Terms of Use.  Please consult the privacy policies of those websites for information about their privacy practices.

Our Sites are available in countries worldwide, and information you provide to us may be stored on servers and with third-party service providers in the United States and other countries in which we do business and whose data protection laws may differ from the jurisdiction in which you live.  When we transfer the personal data of users who are located in the EU and the U.K. to a location outside of the EEA for processing, we use an approved transfer mechanism.  A copy of the transfer mechanism that we use to effect such transfer is available to users by contacting privacy@riw.co.uk

The following additional notices apply to users located in the State of California, the EU and the U.K.

RIW processes personal data for the purposes described above.  If we use personal data in ways other than described in this Privacy Policy, we will provide you with specific notice at the time of collection.

We process personal data only when we have a legal basis to do so.  The legal basis we will rely on will be one of the following:

• You have consented to the processing of your personal data;
• The processing is necessary to perform a contract with you or fulfil a request you have made;
• The processing is necessary to comply with a legal obligation that applies to RIW; or
• The processing is necessary for purposes that are in RIW’s legitimate interests, such as protecting the security of our Site, conducting market research to improve our products and services, improving the functioning of our Site, and providing you with promotional material about products in which you have expressed interest.

If we intend to use personal data for a purpose other than the purpose for which we collected the data, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.

You can choose not to provide personal data to RIW by refraining from, among other things, using our services, applying for a job, and requesting information.  You also may refrain from submitting information directly to us.  However, if you do not provide personal data when requested, we may not be able to provide you with the full range of our products and services, or with information about our products, services, promotions, and other opportunities.

• You have certain rights regarding the personal data that we maintain about you, which in certain circumstances, you will be able to exercise. These rights are as follows:
• You may request a copy of the personal data that we maintain about you.  If we maintain your information based on your consent or so that we could enter into a contract with you, you can also request that we provide you a copy of your data in a structured, commonly used, and machine-readable format.
• If your personal data is incorrect, you may request that we correct, amend, or delete personal data that is inaccurate or incomplete.
• You may request that we erase or restrict the processing of your personal data.
• You may object to the processing of your personal data in certain circumstances when we process your data for the purposes of our legitimate interests.   

Subject to applicable law, we will comply with your request as soon as practicable, and in any event, within one month after receiving a valid request. If your request is particularly complicated, we may have to extend this period to 2 months.  Any request to exercise these rights will be assessed in accordance with applicable law and there may be circumstances where we are not legally required to comply with your request.  For example, we may reject requests that we determine are unreasonably repetitive or that risk the privacy of others.  Access and correction may be done for free, unless requests are repetitive, excessive or unfounded, in which case we may charge you the administrative costs we have incurred handling the request.

Some of these rights can be exercised online via your account. For example, you can review, modify, and delete certain information relating to your use of our Site and unsubscribe to email messages. If you are unable to manage your request via your online account then please contact us at privacy@riw.co.uk

In addition, you may at any time tell us not to send you marketing communications by email by clicking on the “opt out” or “unsubscribe” link within the marketing emails you receive from us or by contacting us as indicated below.

If you are unhappy or have concerns about the way in which we have handled your personal data, please contact us (see “How You Can Contact Us”) so that we can try to resolve the issue. We encourage you to get in touch with us first; however, you also have the right to lodge a complaint with the applicable supervisory authority.

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy.  You can reach us online at privacy@riw.co.uk.  You also can write to us at: