Privacy Policy

V1.2.1 Last Updated: 26 October 2021 – Data Breach Claims 

Data Protection General Statement: 

This Data Protection Policy outlines Revoke’s commitment to its customers, 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. 

Revoke 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: 

Revoke Limited trading as Data Breach Claims is the data controller of all personal data and data processing activities of its app and website. The company runs the “Revoke” Data Breach Claims app and associated services. It also operates the www.revoke.com and www.databreachclaims.com websites.  

The company’s head office and Registered Office is located at 2nd Floor, Conway House, 7-9 Conway Street, St Helier, Jersey, JE2 3NTD.

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 at 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. Revoke collects the following categories of personal information: 

From Customers: 

  • Contact details: e.g., name, email address, telephone number  
  • Country of Residence 
  • Your consent confirmation(s), when required for our services 
  • IP address, and browser request header data.  

Note 1: 

 Please note that the list above is not exhaustive, and Revoke may also collect and process personal data to the extent that it is necessary for the provision of our products and services which you have requested of us, and which may be performed under contract. 

Purposes of data processing: 

Revoke uses the personal data noted above for the following range of activities: 

Purpose  Lawful bases for processing 
The provision of Data Breach Claims website and app services    

Processing is undertaken using the lawful basis of Consent  –you are free to withdraw your consent at anytime 

 

The provision of customer guidance and support services   

Processing is undertaken using the lawful basis of Legitimate Interest  –you are free to object to such data processing activities by contacting our data protection representative 
 

 

To assist you in registering a data breach compensation claim(s) or joining a class /representative action(s)  

 

Processing is undertaken using the lawful basis of Consent  –you are free to withdraw your consent at anytime  

 

 

 

 

 

 

 

To send you notifications through the Data Breach Claims app or customer portal or SMS messaging communications or email, to keep you updated on the responses we have received in relation to the services you have requested from us 

 

 

Processing is undertaken using the lawful basis of Legitimate Interest  –you are free to object to such data processing activities by contacting our data protection representative 
 

 

 

To conduct a dark web search of your email address(es) to identify if you have been involved in a data breach and to send you direct marketing communications 

 

 

 

Processing is undertaken using the lawful basis of Consent, when you agreed to or “opted-in” to us collecting and using your data for direct marketing purposes. You can “opt-out” at any time by unsubscribing via email or app communications.  

 

To advertise and market our Revoke app services and features, and keep you updated on any new or existing customer services which may be available to you   

Legitimate interest basis for Revoke to promote its business products and services.
 

You have the right to object to such processing by contacting our data protection representative. 

Managing security and access controls to the Data Breach Claims website, app, Revoke’s computer systems, computer platforms, website and vendor related applications   

Legitimate interest basis for Revoke to protect its business website, app, computer systems, platforms and website and vendor related applications.
 

You have the right to object to such processing by contacting 

 our data protection representative. 

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 Revoke 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 representative. 

Obtaining or maintaining insurance cover, managing risks, or obtaining professional advice.   

Legitimate interest basis for  

Revoke 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 representative. 

Comply with legal, tax and regulatory obligations.  In the performance of a task carried out in compliance with a Legal obligation.  

Please note that this list is not exhaustive, and Revoke may also collect and process personal data to the extent that it is necessary for the provision of our services which you have requested of us, and which may be performed under contract. 

Services provided to our customers: 

Revoke Limited (“Revoke”) provides services to its customers through a number of privacy and security apps. To see Revoke’s Privacy Policy, please click here. This Privacy Policy is for the Data Breach Claims app.  

We have designed our app services to comply with the requirements of the new data protection law in the areas of Privacy by Design and Default. 

  1. Data Breach Claims website and app  

The website and app provides the customer with the ability to register their interest in making a claim against a data controller for a breach of their personal data.  

The website and app records the customer’s claim information directly from the customer when they input their details and other information into the claim form(s). . The information is then used to transfer the claim to a selected law firm or claims management company or other relevant service channel, so that the claim can be assessed and processed according to the agreed procedures for that party.     

For more details on these services, please see our Terms and Conditions. 

Direct Marketing Activities: 

Before a customer uses the dark web search service, they are notified at that point, that their email address will be used for direct marketing communications, if the customer submits their email address for the dark web search. The customer is free to “opt-out” at any time by unsubscribing from the email or app communications. 

Revoke may use a number of marketing activities to help promote its business services and the various features within the range of privacy and security app services on offer to customers. 

Data collection methods: 

We collect personal data in the following ways: 

  • When you download the Data Breach Claims app from Apple or Google Play app stores and agree to the terms and conditions for its use 
  • When you access the Data Breach Claims website, use the search service and engage with us by completing any online forms relating to compensation claims 
  • When you enter an email address to search for breaches against that email address  
  • When you email us using one or all of our dedicated customer support, data protection and business email addresses 
  • When you contact our customer service partner or our in-house team who can support and guide you with your data protection queries, cyber security queries and queries in relation to our Revoke services 
  • When you visit our Revoke (www.revoke.com) and Data Breach Claims website (www.databreachclaims.com) which 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 
  • 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: 

Customer personal data will only be used by us where you are using our Data Breach Claims website, app and associated services. 

The personal data collected is used to: 

  • Meet our obligations which may be in the performance of a contract or using the lawful basis of obtaining you consent, for the provision of Revoke products and services which you have purchased from us 
  • To mitigate fraud and verify your identity  
  • To meet our obligations to you as data controller under the respective data protection laws 
  • To communicate with you in relation to promoting our data protection, privacy, security services and related matters which may be of interest  
  • 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 Revoke 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 Revoke 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. 

Any other personal information that is collected will only be processed in accordance with this Privacy Policy, and only when required, or it may be collected and processed as required by law. 

Recipients of data: 

Personal data collected may be disclosed or transferred to; 

  • Our data processors who provide services in relation to the provision of website, app products and services, computer systems used for the maintenance of customer accounts (e.g. Apple, Apple Store In-App Payments, Google Play In-App Payments, Microsoft, Smartlook, Google Analytics) 
  • Our data processors who provide the dark web search service to check if your email address and related personal data have been breached. Revoke uses a number of companies to provide this specific service (HaveIbeenpwned, Dehashed). Such data processing activities may take place outside of EEA, UK, Jersey, Guernsey. 
  • Our legal claims management agents for the assessment of your claim for data breach, for the case management and progression of your compensation claim against data controllers responsible for the breach of your personal data (e.g legal firm Keller Lenkner) 
  • Our SMS service providers to send notifications to you regarding your requests (Textlocal, Amazon, Mailjet) 
  • Our email manager provider to manage and deliver our email communications (Mailjet, Sendinblue,) 
  • Our service provider who manages the generation and reporting of statistical tracking data of our services (Smartlook, Google Analytics) 
  • Third-party organisations you have requested us to contact on your behalf to communicate compensation claims for breach of your personal data 
  • Revoke’s business partners who may provide professional services in relation to additional expert services 
  • Revoke’s data processors who provide services in relation to the secure and safe running of its business systems and processes 
  • Professional agents in the provision of required services (e.g., lawyers, claims management companies, bankers, accountants, auditors) 
  • 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 Revoke 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. Revoke 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: 

Revoke 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 or where you have given your consent for this data processing activity to happen. 

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. 

Revoke 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: 

Revoke 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. 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 
  • If you have signed up to raise a data breach claim or have joined a representative or group litigation order (“GLO”) action, your claim will continue to be processed by either a law firm or claim management company or another qualified agent, for as long as there is either a successful outcome or the claim process has terminated as it was unsuccessful or unviable or as instructed by you. Your data will only be kept for as long as required by law.    
  • Revoke will retain personal data in relation to customer, supplier, other data subjects’ transactions for 10 years from the date of the transaction where they are deemed to be part of the financial records of the business 
  • Where you have registered an interest in raising a compensation claim or where you have joined a data breach claim action, your data will be held by our claim management agents for a long as is required by law, to establish if your claim is viable, to secure a final legal judgement /determination and to meet the legal obligations imposed on these agents for the retention of client data.      

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 Revoke’s data protection manager at dpo@revoke.com. 

Data subjects have a number of rights available to them: 

  • Access to their personal data 

You can assert this right by accessing your personal Account on your selected Revoke app or 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 via each Revoke app services. 

  • 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 society services. 

  • To be forgotten (erasure of your data) 

You can delete or request deletion of your Account and uninstall the Revoke app 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 is a new right and 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. Revoke 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. 

Security features: 

Revoke is committed to ensuring the security of your personal data and has implemented appropriate commercially reasonable technical, physical, and organisational measures to prevent unauthorised or unlawful processing of your personal data or accidental loss or destruction of your personal data. 

Our Security Policy is available on our website here. 

Our website is encrypted using HTTPS (Hypertext Transfer Protocol Secure). In HTTPS the communication protocol is encrypted using Transport Layer Security (TLS). This provides a secure method of communication with us, and any personal data uploaded onto our website is securely managed by our website data processor services. 

Email communications are scanned using the latest version of anti-virus and malware software deployed by our business. Personal data held by Revoke is only available to authorised members of staff. No member of Revoke staff can access decrypted Photo ID or biometric data (Selfie). 

Our computer systems have secure audit trails, and we have robust backup capabilities in place to ensure that our services can continue uninterrupted for our customers. 

Management and employees are trained in their data protection responsibilities and obligation to handle personal data in a confidential manner. 

Change to this notice: 

Revoke may update this Privacy Notice at any time. The updated notice will appear on our website www.revoke.com and
www.databreachclaims.com in our Terms of Business. 

This Privacy Policy was last updated on 26 October 2021. 

Contact details:  

EU Representative: 

Revoke has appointed Formiti Data International, The Black Church, St. Mary’s Place, Dublin, Ireland 7, 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, Suite 2a, Blackthorn House, St. Paul’s Square, Birmingham, Warwickshire, England, 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.