Privacy Policy

V2 Last Updated: 3^rd July 2023

Data Protection General Statement:

This Data Protection Policy outlines B2’s commitment to its customers, suppliers and other individuals to operate its business activities in a manner that meets the compliance obligations of the Data Protection (Jersey) 2018 Law (“DPJL”), the Data Protection (Bailiwick of Guernsey) Law 2017, Data Protection Act 2018, (UK) and the General Data Protection Regulation (EU) 2016/679.

B2 understands and respects your right to privacy and we are committed to ensuring the confidentiality and security of your personal data and the personal data processing activities within our organisation by applying the appropriate technical and organisational measures required to achieve this objective.

This document covers the policies and procedures for processing personal data in a compliant manner and outlines the rights of the data subjects in respect of that data. The Privacy Notice below explains how we may use, process, and store your personal data.

When you create an Account with us or use our Services, you enter into an agreement with us and are directed to this Privacy Policy and the Terms and Conditions which form part of that agreement.

Each time you use your Account or our Services, or provide us with information, the processing of your Personal Data will be governed by the current version of this Privacy Policy and Terms and Conditions.

If you do not agree with the terms of this Privacy Policy or the Terms and Conditions, please refrain from creating an Account or using our Services.

Data Controller:

B2 is a trading name of Revoke Limited who is the data controller of all personal data and data processing activities of its website analytics and advertising business. The company runs the B2 website, portal associated services. It also operates the www.revoke.com website. The company’s head office and Registered Office is located at Ground Floor, 5 Bond Street, St Helier, Jersey, JE2 3NP.

Revoke Limited is registered as a data controller with the Jersey Office of the Information Commissioner and its number is 61116.

Reference documents:

Data Protection (Jersey) Law 2018
Data Protection (Registration and Charges)(Jersey) Regulations 2018
Data Protection (Bailiwick of Guernsey) Law 2017
Data Protection Act 2018, (UK)
EU General Data Protection Regulation 2016/679

Special notice regarding children:

Our Services are not directed to people under 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with Personal Data without the proper consent, please contact us at dpo@revoke.com and we will take steps to remove such information and terminate the account as necessary.

Privacy Policy:

Scope of application:

This policy applies to our business activities and the personal data processing of the data subjects within the European Economic Area (EEA), UK, Jersey, and Guernsey in the Channel Islands.

Personal data:

Personal data means any information relating to an identified or identifiable natural person. B2 collects the following categories of personal information for users of our analytics platform:

From Customers:

Contact details: e.g. name, email address, telephone and mobile number plus other relevant contact information
IP address, connection information, browser type and version, operating system, device identifier

Note 2: Please note that the list above is not exhaustive and B2 may also collect and process personal data to the extent that it is necessary for the provision of our products and services performed under contract.

Purposes of data processing;
B2 uses the personal data noted above for the following range of activities;                 

Purpose	Lawful bases for processing
The provision of B2 services  and sale of related services	Processing is undertaken in the performance of a Contract -i.e. the services and sales transactions
To manage the operation of your subscription and services contract, and subscription payments	Processing is undertaken in the performance of a Contract i.e. the app services and sales transactions.
Managing security and access controls to the B2 portal, website and vendor related applications	Legitimate interest basis for B2 to protect its business app, computer systems, platforms and website and vendor related applications. You have the right to object to such processing by contacting our data protection manager.
Establishment and exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.	Legitimate interest basis for B2 to protect and assert its legal rights and the legal rights of others. You have the right to object to such processing by contacting our data protection manager.
Obtaining or maintaining insurance cover, managing risks, or obtaining professional advice.	Legitimate interest basis for B2 to protect and assert its legal rights and the legal rights of others. You have the right to object to such processing by contacting our data protection manager.
Comply with legal, tax and regulatory obligations.	In the performance of a task carried out in compliance with a Legal obligation.

Special category data
B2 does not capture any Special category data.

Services provided:
The main services we offer are as follows;

Website Analytics (B2 Analytics)
Advertising Services (B2 Stealth & B2 Stealth Plus)

Data collection methods:
We collect personal data in the following ways:

When you register for B2 Analytics at https://portal.b2.ai
When you email us using one or all of our dedicated customer support, data protection and/or business email addresses
When you visit our B2 website (www.b2.ai), we use only essential and analytical cookie features which may track your usage of our website and uploading of information to the website to help us improve our services to you
When you contact us by telephone and/or leave a voicemail message or text messages or use of the online chat facility or posting messages on our social media platforms
When you transfer to us from another service provider upon the exercise of your “data portability” rights and B2 has agreed the terms and transfer details prior to commencing B2 Services
From third party channels such as public registers, social media and any other public open forums
Directly from you as a member of the public, staff member, business partner, supplier or intermediary when engaging with us directly

Information collected:
Personal data will only be used by us where you are using our B2 Analytics portal and associated services.

The personal data collected is used to;

Meet our obligations in the performance of a contract for the provision of B2 products and services which you have purchased from us

Provide uninterrupted access to your B2 account and maintain the service level expected and outlined in our Terms of Business
To meet our obligations to you as data controller under the respective data protection laws
Assist us in the delivery and operation of secure business communications via email, our website and other relevant means
Meet legal obligations from relevant local laws in relation to the sale of product and services transactions e.g. GST/VAT
Assist B2 in compiling relevant aggregated statistical data for statistical or public relation purposes. This aggregated information is not tied to personal information,
Meet any legal obligations in relation to the establishment, exercise or defence of a legal claim or where we received a court order for the disclosure of personal data
Meet any other legal obligations from relevant local laws

Personal data may be used for the legitimate business interest of B2 as indicated in this Privacy Policy.

Only personal data that is necessary for the purposes of assisting our customers with the provision of products or services as outlined above are actively collected.

Recipients of data:
Personal data collected may be disclosed or transferred to;

Our email manager provider to manage and deliver our email communications (Mailjet)
Law Enforcement and Competent Authorities as required by the respective laws where such disclosure is necessary for compliance with a legal obligation
Other third parties when requested by you and when relevant consent has been obtained from you
Any new owner of B2 should it be acquired or merged with another company or as part of the re-organisation of the company

Third-party service providers are bound by the requirements of the Data Processor Agreement obligations, where your personal data is to be processed to high standards of confidentially and with the required security standards and arrangements to be in place.

Social media platforms:

When we use social media platforms e.g. Facebook, Twitter, Instagram, we only operate it so as to promote our own business and we would not knowingly engage in activities that go beyond this scope. Customers (and other data subjects) are advised to refer to the respective privacy notices of these social media platforms to check their data protection and privacy rights. B2 cannot be held responsible for third-party social media platforms or website activities.

Storage of data:

Customer data is stored in the European Union in either the Netherlands or in Ireland.

Transfer and access to personal data:

B2 will only transfer data outside of the EEA, UK, Jersey, and Guernsey where it is necessary for the performance of the contract agreed by you.

Where the destination of the data transfer is outside the EEA, UK, Jersey, and Guernsey and does not include a third country that has an “adequacy/equivalence” status, as recognised by the EU Commission, we would always ensure that appropriate safeguards are in place.

B2 engages the services of those vendors who are operating under the respective data protection compliant agreements and where they are using Standard Contractual Clauses or other approved data transfer mechanisms, where appropriate.

Where we cannot guarantee these safeguards, we would always request your consent before the data is transferred.

Any transfer of data is done in a secure way and in compliance with Data Protection Laws.

Retention of data:

B2 will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected.

Summary of the important data retention periods are as follows;

If you create an Account with us, we will retain your Personal Data for as long as you have that Account
If your account becomes inactive for 12 months, your account will be treated as expired. If we do not hear from you after sending you a reminder, we will delete your account within 30 days
Should you delete or request deletion of your Account, we will only retain and use your Personal Data to the extent necessary to comply with our legal obligations (if we are required to retain your data to comply with applicable laws), detect and prevent fraud, resolve disputes and enforce our legal agreements and policies. All requests for deletion of accounts will be actioned after 48 hours of the request

This is subject to the exception where the data cannot be deleted for legal or regulatory reasons.

Data subject rights:

Where a data subject in the European Union (or any “adequate/equivalent” status country) wishes to exercise their rights under applicable data protection laws, they should contact B2’s data protection manager at dpo@revoke.com.

Data subjects have a number of rights available to them;

Access to your personal data

You can assert this right by contacting us directly via our website www.revoke.com or email dpo@revoke.com. We would request that any request to access personal data must be made to Revoke in writing and provide sufficient detail to identify the Personal Data that you are seeking.

Rectification of any inaccuracies

If you are a registered user of our Services, we provide you with the tools to access or modify the personal data you provided to us and associated with your Account.

Restriction on the processing of their data

This right applies in certain specific circumstances; where the accuracy of personal data is contested and the data controller needs time to verify details; where processing is deemed unlawful but the data subject opposes erasure and requests restriction instead; where there is an objection to data processing under legitimate interest legal bases and pending verification that the legitimate interest overrides the data subjects rights; the purpose of processing is no longer valid but it is required by the data subject for the establishment, exercise or defence of legal claims.

To object to the processing of their data

This right is available to data subjects to request exclusion from any direct marketing activities or communications, including profiling to the extent that it is related to such direct marketing activities, and to any automated means using technical specifications in the context of information services

To be forgotten (erasure of your data)

You can delete or request deletion of your Account at any time. Revoke will not however be able to delete all our personal data to the extent that it is necessary to meet its legal obligations

Right to data portability

This right only applies to those processing activities that are conducted under the legal basis of Consent or on Contract and the processing is carried out by automated means. Your data can be transferred to another data controller or to you directly where technically feasible

Right to object to automated decision making and profiling

The data subject can object to automated decision-making and profiling in certain circumstances and request human intervention in the decision-making process. B2 does not make any decisions based on purely automated means, but if we do, you have a right to object

Right to withdraw consent for those data processing activities based on consent

Where the processing of personal data is conducted with Consent as the legal basis, the data subject can withdraw consent at any time.

Each data subject request to exercise the rights noted above will be reviewed against the requirements of the Data Protection (Jersey) Law 2018 and other relevant data protection laws, and in certain circumstances (e.g. restriction, erasure, objection, data portability) these rights may not be exercisable by the company. Full explanations will be given in such cases.

Making a complaint:

The Jersey Office of the Information Commissioner (“JOIC”), Channel Islands, is an independent statutory authority where you can make a complaint or learn more about data protection in Jersey. Their office is located at 2nd Floor, 5 Castle Street, St. Helier, Jersey, JE2 3BT. Their website is www.jerseyoic.org and their telephone number is 01534 716530.

Change to this notice:

B2 may update this Privacy Notice at any time. The updated notice will appear on our website www.b2.ai and in our Terms of Business.

This Privacy Policy was last updated on 3^rd July 2023.

Contact details:

EU Representative:

Revoke has appointed Formiti Data International, 6 Fern Road, Dublin, D18 FP98, Ireland, as its EU Representative. They can be contacted on +353 1 485 3752 or by email using info@formiti.com.

UK Representative:

Revoke has appointed Formiti Data International, Grosvenor House, 11 St Pauls Square, Birmingham B3 1RB, United Kingdom, as its UK Representative. They can be contacted on +44 121 582 0192 or by email using info@formiti.com.

Revoke:

If you have any questions, concerns, or complaints with respect to this Privacy Policy or the handling of your privacy or personal information, please contact our data protection manager at dpo@revoke.com.