1 Who is in charge of processing your personal data?

This Privacy Policy sets out the rules for processing the personal data that you as customer, user, potential customer, or candidate share with us through our website, returns portal and platform, mobile application, and social profiles.

The controller for your personal data in your interactions with us or one of our subsidiaries is Reveni SL, with registered office at Calle Ferrocarril 37, 28045, Madrid, Spain and tax identification number B-09662453. In the UK, our main subsidiary is Reveni Ltd, a limited company, registered in England. Our registered company number is 14618820, and our registered office is 5 New Street Square, London, United Kingdom, EC4A 3TW.

2 What types and categories of personal data do we process?

The categories of data that we will need from you fall into the following categories:

• Identification and professional contact details.
• Billing and payment details.
• Connection and browsing data.

Information that you give to us

Identification and contact details. To enable us to provide you with our services, we will ask you for your name and surname(s), postal address, shipping address, telephone number, and email address.  We may also collect your mobile phone number and date of birth among other details.

Account details. You can choose to create an account with REVENI to see all your returns history across different merchants in one place. 

Bank account details. If you choose for your refund to be deposited into your bank account, you will provide us with your bank account number and sort code, IBAN, and/or any other details needed to process the refund. 

If you choose to have your original card refunded then we do not collect your payment or card data but instead the refund will be sent directly to the payment service provider over the payment gateway.

Call recordings. We may record our calls with you so will process any personal information that you provide in those calls with us. 

Please ensure that the data you provide are real and up to date. We reserve the right to terminate the services contracted if the data you provide are incorrect, incomplete, inaccurate, or not up to date.

Information that we receive from other sources

Connection and browsing data. We can access your device's IP address, device identifier, and metadata when you use our website, mobile application, social profiles or returns portal and platform.

Order details. We will obtain details about your orders from the relevant merchant, such as the products you bought, the price you paid, the date of purchase and the last digits of the card you used to make the purchase.

Personal asset and credit history data. We will obtain information about your personal asset and credit history from third parties.

3 Why do we process your personal data?

Your personal data are processed for the following purposes:

Providing REVENI's Services. We will use the data you provide on our form for registering for REVENI's services:

To take whatever steps are necessary for REVENI to manage your return with the merchants using REVENI for their return procedure and/or to complete your refund request. This includes:

• To contact you via any media used by REVENI (e.g., telephone, email, WhatsApp) in connection with the service you have requested.
• Using your bank account details or other contact details to manage payment of the services.
• To handle queries concerning our services via any media used by REVENI (e.g., telephone, email, WhatsApp).
• To prepare and send invoices.
• If you have a profile or account on REVENI's website, we use your account information to view the summary of your refunds and your tickets in your customer area.

Internal analytics and studies. We may use your personal data internally for analytics and studies, reports, and statistics to adjust REVENI's activities and commercial information to improve the products and services we offer.

To send out customer satisfaction surveys. To carry out and send you quality surveys about our services.

To check and verify your financial status. We may check on your financial situation or that of whoever is acting on your behalf by accessing automated files containing personal asset and credit history data obtained in compliance with the laws in force, and we may also check to see whether the data furnished by customers are accurate. We use this information to check whether we can offer you all our services.

To obtain payment. If you do not return an item as agreed, we will receive information about your order from the merchant and use your contact information to contact you to obtain payment for the missing or damaged item. We may also use this information to report you to relevant fraud agencies or to use a debt recovery agency to obtain payment from you on our behalf.

To enter data into credit history databases. Subject to compliance with applicable legal obligations and requirements, we may enter your data into credit history databases.

To evaluate and prevent risk and fraud. We may run automated checks on your information and purchase history across merchants to be able to evaluate risks and potential fraud in the pre-contractual and contractual phases, and decide whether you are eligible to use all the REVENI services.

To send out marketing information. We may also process your data to send you marketing information electronically based on your activity and habits. All commercial messages contain an opt-out mechanism enabling you to stop receiving them. 

Customer service or means of contacting REVENI. When you contact our Customer Service department or use other means that have been put in place to enable you to contact us, and in so doing you furnish your data, we process that data (even if you are not a REVENI customer) so that we can manage your request, enquiry, question, or claim and answer the enquiries that you have made. We may record customer service calls for reasons of quality control and security.

Social networks. When you interact or communicate with us via our our social media profiles, we may process your data.

Contests, prize draws, and/or activities organised by REVENI. We may process your data to confirm your attendance, send you a reminder of the date and time arrangements, or contact you should you win a contest or a prize draw.

4 Legal basis for the processing of personal data

The legal bases for our processing of your data according to the stated purposes are as follows:

Customer relationship. The legal basis for processing is performance of the agreement that binds us.

Internal analytics and studies. We process your data on grounds of our legitimate interest, being the running and improvement of our services. 

Sending out customer satisfaction surveys. We process your data on the basis of our legitimate interest in obtaining feedback on our services.

Checking and verifying your financial status. We process your data on grounds of our legitimate interest in ensuring that you are able to meet any financial commitments.

To obtain payment. If you do not return the item as agreed, we use your personal data to contact you to obtain payment for the purpose of performing the contract.

Entering data in credit history files. We process your data on grounds of our legitimate interest in preventing fraudulent activity.

Evaluating and preventing risk and fraud. We process your data on the basis of our legitimate interest in analysing risk when offering our services.

Sending out marketing information. The legal basis for the processing of your data is the express consent you have given, and in those cases in which a relationship with REVENI exists, our legitimate interest in sending out information related to our services.

REVENI's Customer Service. The legal basis for processing is the pre-contractual relationship with REVENI, for REVENI customers performance of the agreement that binds us and any legal obligations we may have based on enquiries you make or questions you raise, and our legitimate interest in providing you with the customer service you have requested, including the possibility of recording conversations for reasons of quality control and security.

Social networks. The legal basis for processing this data is REVENI's legitimate interest in improving the quality of its services through multi-communication channels.

Contests, prize draws, and/or activities organised by REVENI. We process the data you provide when taking part in contests, prize draws, and/or activities or events we organise based on the contractual relationship binding you to us as a REVENI customer or on the specific legal terms applicable.

Recruitment: work with us. The data are processed on the basis of the pre-contractual relationship and our legitimate interests in hiring the right people for our business.

5 Third-party personal data

If you provide us with data on third parties to which you are in any way linked, we will process those data on the understanding that you will have notified those third parties and referred them to this Privacy Policy to learn how we process their data. Nevertheless, we will inform them of this Privacy Policy when we have the opportunity.

6 Data recipients

To be able to provide our services, we will allow third parties who act as agents or service providers for REVENI to access your personal data. They may process your personal data only to help us provide the corresponding services. This means they will not use the data for their own purposes or disclose them to third parties. The following categories of third parties may have access to your data, where necessary:

• Companies that provide support for our telephone and online customer service.
• Payment providers and banks.
• Postal workers and courier or delivery companies.
• Email processors.
• Printing service providers.
• Companies that manage REVENI's website and company profiles.
• Auditors, consultants, and similar companies that provide consultancy and audit services.
• Companies that provide advertising and marketing services.
• Other companies that provide services for REVENI that need to access the data to provide the service concerned.
• Debt collection agencies.

To be able to provide our services, we may have to verify your data with the merchant from which you purchased the goods or service for which you have requested a refund, which will involve sharing personal data with that merchant.  

We may also be required by law to report your data to public bodies, public authorities, and government agencies. In that case we will disclose only what is strictly necessary.

We will share aggregated data and analytics with our customers to help improve the services, but you cannot be identified from this data.

Furthermore, your personal data may be processed and disclosed to the parties involved in preliminary and review measures and steps preparatory to business operations of all kinds and/or to takeover of the activities, including, but not limited to, merger, divestment, assignment of all assets and liabilities in toto, contribution or assignment of the business or a line of business, or any similar type of business and/or corporate restructuring operation permissible under company law and regulations or in the course of business dealings. The data may also be disclosed to the providers of services to those parties.

We may share your personal data with any member of our group, which means any subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy.

We do not transmit your data to third parties for marketing purposes. We will send you marketing information about our products and services and about the products and services of third parties with which we partner in such sectors as sports, food, clothing, lifestyle, well-being, nutrition. We may offer you discounts and benefits provided by companies with which REVENI has entered into commercial arrangements, but we will not transmit your data to them. We will simply send you information about their goods or services.

7 International data transfers

REVENI stores its data in the EU. If any of the suppliers or service providers we partner with are located outside the European Economic Area and there is an international data transfer, REVENI will take all requisite legal measures to safeguard transfer of the data. In those cases, REVENI usually employs the corresponding standard clauses by way of a safeguard. For more information on where we transfer your personal data, please contact privacy@reveni.com.

8 Storage periods

Generally speaking, your personal data will be stored for as long as necessary to carry out the purpose for which they were collected and to ensure performance of the various legal obligations incumbent on REVENI. REVENI determines the appropriate storage period for the personal data based on its data storage policy, taking into account the quantity, nature, and level of sensitivity of the data; the purposes for which the personal data are processed; and, lastly, applicable legal, regulatory, or other requirements. The data storage periods that we generally use when processing the data of our customers, potential customers, or contacts during our relationship with them or after it has ended are explained below.

In any case, the data may be stored for time periods different from those mentioned to safeguard and/or defend our rights and interests or to comply with the law.

Customer relationship: We will store your data for as long as you have an account with us and for six (6) years after that to identify any issues and resolve any legal proceedings.

Internal analytics and studies. We will store any data linked to your status as a customer or to any relationship you may have with REVENI for up to six (6) years from your last interaction with us.

Sending out customer satisfaction surveys. We will store any data linked to your status as a customer or to any relationship you may have with REVENI for up to ten (10) years from your last interaction with us.

Checking and verifying your financial status. The data will be stored for as long as necessary to be able to defend REVENI's rights and interests for up to six (6) years from your last interaction with us.

Entering data in credit history files. The data will be stored for as long as necessary to be able to defend REVENI's rights and interests for up to six (6) years from your last interaction with us.

Evaluating and preventing risk and fraud. The data will be stored for as long as necessary to be able to defend REVENI's rights and interests for up to six (6) years from your last interaction with us.

Sending out commercial information. We will store any data linked to your status as a customer or to any relationship you may have with REVENI for up to six (6) years from your last interaction with us.

REVENI's Customer Service. We will store the information concerning any matter handled by our Customer Service for up to five (5) years from your last interaction with us.

Social networks. We will store your data for up to five (5) years from your last interaction with us.

Contests, prize draws, and/or activities organised by REVENI. We store your personal data for up to five (5) years from the date on which the contest, prize draw, and/or activity organised by REVENI was held.

9 Automated decision making 

Automated decisions with legal effect, or automated decisions that similarly significantly affect you, means that certain decisions in our services are completely automated, without our employees being involved. These decisions have a significant effect on you as a customer, comparable to legal effects. By making such decisions automatically, REVENI increases its objectivity and transparency in the decision to offer you these services. At the same time, you have the right to object to these decisions at all times. You can read about how to object to these decisions at the end of this section.

Automated decisions that significantly affect you also mean that profiling is performed based on your data before the decision is made. This profiling is made to assess your financial situation (before the decision to grant access to our Services) or to identify whether your use of our services involves a risk of fraud or money laundering. We profile your user behaviour and financial standing and compare this data with behaviours and conditions that indicate different risk levels for us.

When does REVENI take automated decisions that significantly affect you?

We make this kind of automated decision when we:

• decide to approve your application to use one of our Services.
• decide not to approve your application to use one of our Services. These automated risk decisions are based on the data you provide to us, data from external sources such as credit bureaus and REVENI’s own internal information. In addition to information about you, REVENI’s underwriting model includes a large number of other factors, such as REVENI’s internal risk levels and our customers’ general behaviour (based on, for example, the current product category).
• decide whether you pose a risk of fraud, if our processing shows that your behaviour indicates possible fraudulent conduct, that your behaviour is not consistent with previous use of our services, or that you have attempted to conceal your true identity. Automated decisions whereby we assess whether you constitute a fraud risk are based on information you have provided yourself, data from fraud prevention agencies and providers, and REVENI’s own internal information.
• decide whether there is a risk of money laundering, if our processing shows that your behaviour indicates money laundering. In relevant cases, REVENI also investigates whether specific customers are listed on sanction lists.

The personal data types used in each decision are described in section 2. See section 6 for more information about whom we share information with as regards profiling during automated decisions.

If you are not approved under the automated decisions described above, you will not have access to REVENI’s services, such as our instant refunds or exchanges products. REVENI has several safety mechanisms to ensure the decisions are appropriate. These mechanisms include ongoing overviews of our decision models and random sampling in individual cases. If you have any concern about the outcome, you can contact us, and we will determine whether the procedure was performed appropriately. You can also object in accordance with the following instructions.

Your right to object to these automated decisions

You always have the right to object to an automated decision with legal consequences or decisions which can otherwise significantly affect you (together with the relevant profiling) by sending an e-mail message to privacy@reveni.com. A REVENI employee will then review the decision, taking into account any additional information and circumstances that you provide to us.

10 Rights

Pursuant to the data protection legislation and regulations in force from time to time, you may exercise both your rights to access, rectification, erasure, objection, portability, the right to withdraw any consent without detriment (where we are relying on it as a lawful basis), the restriction of processing of your personal data and your right to lodge a complaint with your local data protection authority (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html or if you are in the UK https://ico.org.uk/) in the manner provided by law. You may contact REVENI for that exercise your rights, attaching proof of your identity, by email addressed to privacy@reveni.com.

11 Changes to this Privacy Policy

We are committed to complying with the fundamental principles of data privacy and data protection. To that end we regularly review our Privacy Policy to ensure that it is always up to date and compliant with data protection principles. This Privacy Policy may be changed as appropriate to be brought into conformity with the latest advances and to always comply with the legislation in force. Future changes to our Privacy Policy will be made available to you by publication on this page. Where required, you will be notified by email.

‍

Last update: August 2024