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  2. Privacy policy

Privacy and Data Protection Policy

Introduction
Collection of Data
Purposes for Collection, Use and Disclosure of Your Personal Data
Accuracy and Duration of Retention
Data Security
Contact Us

  1. Introduction


    Welcome to East river’s privacy policy.

    East river understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under applicable law.

    This privacy policy will inform you as to how we look after your personal data. Please read this privacy policy carefully and ensure that you understand it. By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and consent to the collection, use, processing and disclosure of your personal data as described in this policy.

    1. Information About Us

      East river Ltd, a private company limited by shares registered in England under company number 11952830 whose registered office is at 51 Eastcheap, EC3M 1JP, London, UK.

      East river Ltd is part of the East river Group, which is made up of different legal entities, including East river Pte. Ltd, a private limited company registered in Singapore with registration number 201712242C whose registered office is at 68 Circular Road, #02-01, Singapore 049422.

      This privacy policy is issued on behalf of East river Ltd so when we mention “East river“, “we”, “us” or “our” in this privacy policy, we are referring to East river Ltd in the UK. Where we refer to East river Pte Ltd we refer to the Singapore entity.

      East river Ltd acts under the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”).

    2. Personal Data

      Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

      Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and some other online identifiers. It does not include data where the identity has been removed (anonymised data).

      By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and consent to the collection, use, processing and disclosure of your personal data as described in this policy.

    3. Purpose of this policy

      The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process your personal data. Any changes to this Privacy Policy are effective after posting to this website. We recommend you to check this page from time to time to be aware.

    4. Your Rights.

      East river does not claim ownership of the information you submit via the East river Application or through other means of data collection. You have the necessary rights to such information that you submit on the East river Application.

    5. East river’s Rights.

      We own all copyrights, trademarks, domains, logos, trade dress, trade secrets, patents, and other intellectual property rights associated with our East river Application. You may not use our copyrights, trademarks, domains, logos, trade dress, patents, and other intellectual property rights unless you have our express permission and in accordance with our Terms and Conditions.

  2. Collection of Data

    1. To process your requests, we collect some personal information, such as:
      • Usage And Log Information. We collect information about your activity on our East river Application, such as service-related, diagnostic, and performance information. This includes information about your activity (including how you use our East river Application, how you interact with our staff and authorized people in our East river Application, and the time, frequency, and duration of your activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when you registered to use our East river Application, your profile photo, whether you are online and when you last used the East river Application.
      • Device And Connection Information. We collect device and connection-specific information when you install, access, or use our East river Application. This includes information such as the hardware model, operating system information, the app version, browser information, language and time zone, IP, device operations information, and identifiers, for example, the device identifier.
      • Cookies. Our website and East river Application are set up to automatically collect anonymous information about visitors to help us understand our website visitors and their traffic patterns. This information is used for statistical purposes and to improve our service. Below is a list of cookies that we use on our websites and services. The types of cookies we use are always changing. If you think we’ve missed a cookie, please let us know
      Cookie namePurpose
      Facebook AdsTells us how our ads on Facebook are working and what kinds of users are interested in East river.
      Google AdsA cookie that shows us how effective our East river ad campaigns are by tracking how many users click through to our website from a particular ad, and the demographic of those users.
      Google AnalyticsAllows us to see how many users are on the East river website, which pages they are visiting and track how many visitors joined Revolut.
      Google OptimisePart of our testing platform to help us understand whether any changes we've made to East river website pages have been well received.
      Google Tag ManagerThis cookie controls other cookies on the website.
      IntercomIntercom is a tool that allows users to chat to Support through our website. It uses a script with a visitor cookie associated with it.
      LeadinfoWe use the lead generation service provided by Leadinfo B.V., Rotterdam, The Netherlands, which recognizes visits of companies to our website based on IP-addresses and shows us related publicly available information, such as company names or addresses. In addition, Leadinfo places two first-party cookies for providing transparency on how our visitors use our website and the tool processes domains from provided form inputs (e.g. “leadinfo.com”) to correlate IP addresses with companies and to enhance its services. For additional information, please visit www.leadinfo.com. On this page: www.leadinfo.com/en/opt-out you have an opt-out option. In the event of an opt-out, your data will no longer be used by Leadinfo”.
      1. Your Personal Data.Examples of such Personal Data you may provide to us include your name, age, birth date, mobile number(s), telephone number(s), mailing or residential address, email address, passport or other identification number, and any other information relating to individuals that you have provided to us during our interaction with you..
      2. Your Messages. We retain the contents of your messages delivered to the East river Application during the course of providing East river services to you. Once your files (including photos, videos, documents) are delivered, they are kept and are accessible to East river staff and government authorities upon request. In order to improve our East river Application we store information relating to which country your device indicates you are located in, as well as the device model and operating system you are using. Additionally, your "last login" time and read receipts are visible to East river staff.

      3. We collect your Personal Data in the following ways:

        • when you contact our chatbot and/or staff, for example, via chats, emails, telephone/video calls, letters, face-to-face meetings, social media platforms, and our website;
        • when you submit forms on our East river Application;
        • when you enter information into documents we send to you via our East river Application;
        • when you request to be included in our mailing list;
        • when you respond to East river advertisements, promotions, initiatives;
        • when we receive references from affiliates and third parties, if you have been referred by them;
        • when you submit your Personal Data to us for any reason.
      4. If you provide us with Personal Data relating to a third party (e.g. information relating to your spouse, children, parents, business partners and/or employees), by submitting such information you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

  3. Purposes for Collection, Use and Disclosure of Your Personal Data

    1. Upon your request, we may disclose your personal and business information with authorised third parties, such as:

      • conducting KYC;
      • processing payments;
      • replying to your questions, feedback and requests;
      • managing East river’s business operations;
      • complying with internal policies and procedures;
      • providing updates and other communications on the development of East river’s business process and applications;
      • assessing and processing applications or requests made by you for East river products and services offered including, but not limited to, bookkeeping service, incorporation services, tax and accounting services and payroll services;
      • managing commercial risks and risk management;
      • managing the safety and security of our affiliates and employees;
      • managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance);
      • in connection with any claims, actions or legal proceedings (including but not limited to drafting and reviewing documents, transaction documentation);
      • conducting investigations relating to disputes, billing or fraud;
      • managing and preparing reports on non-compliance cases;
      • meeting or complying with any applicable laws, regulations, codes of practice or guidelines issued by legal or regulatory bodies;
      • financial reporting and audit;
      • project management;
      • requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
      • sending automatic reminders about missing documents or bank feeds needed for the service we are providing.
    2. If you have indicated that you consent to receiving marketing or promotional information via your telephone number, emails or other ways of communication, East river may contact you from time to time with information regarding our products and services.
    3. As East river relies on your Personal Data to provide products and services to you, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
    4. We will seek your consent and notify you in advance when we collect information for purposes other than listed above or for purposes unrelated to the original purpose when collecting the data, unless with the data subject’s express and voluntary consent. You can withdraw your consent previously given by written notice.

  4. Accuracy and Duration of Retention

    1. East river will retain your Personal Data for 6 years or longer where necessary for legal or business purposes.
    2. East river will take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted if it is no longer required for those purposes.

  5. Data Security

    1. East river will take all practicable steps to protect the Personal Data against unauthorised or accidental access, processing, erasure, loss or use.
    2. Keeping Your Account Secure. You are responsible for keeping your device and your East river account safe and secure, and you must notify us promptly of any unauthorized use or security breach of your account or our East river Application.
    3. Third-party authorization. Our East river application may allow you to invite new users into your chats and company profile to have access, use, or interact with our staff. Users will also be able to view some of your personal information, business data, content, and other products and services. For example, you may invite a new director to your company profile. Please note that when you invite new users into your company profile, we will need to conduct our diligence exercise as per applicable law. Please note East river will not bear any responsibility if your Personal Data is used by unauthorized people that you invited into the East river Application.
    4. We have servers around the world and your information may be processed on servers located outside of the country where you live. Regardless of where your information is processed, we apply the same protections described in this policy.

  6. Contact Us

    1. To contact us regarding:

      • your Personal Data or our Privacy Policy,
      • making a subject access/correction request,
      • requesting to withdraw your consent to any use of your Personal Data as set out in this Policy; or
      • requesting to obtain access and make corrections to your Personal Data records, please use the following email address (for the attention of the Data Protection Officer): dpo@osome.com.
    2. If you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, East river may not be able to continue to provide our services or provide access to East river Application. Such withdrawal may also result in the termination of our services.

This privacy policy was last updated on 19 April 2021.