Privacy Policy

Introduction

This privacy policy provides information on how Relative Insight looks after your personal data and your end customers’ personal data, when:

• You visit our website at relativeinsight.com (regardless of where you visit it from) (“Site”);
• We provide you with our language analysis services through our dashboard (“Services”); and
• The Services include processing personal data from third parties such as the Customers’ end customers, users, survey participants, reviewers etc (referred to as “End Customers”).

This policy is intended to apply to our Customers (any business or organization, including their employees, agents or contractors, using our Services) and any User (any person accessing our Site).

This website is not intended for children, and we do not knowingly collect data relating to children.

We reserve the right to change this policy from time to time. We will post any adjustments to the policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Site or Services, we will notify you through the Site or Services, by email, or other communication.

 

Important information, who we are and how to contact us

Relative Insight is made up of the parent company, Relative Insight Limited and its subsidiary Relative Insight Inc. We set out the processing undertaken by each company in the next section.

We have appointed a Data Protection Officer who is responsible for overseeing questions regarding this privacy notice. If you have any questions, including requests to exercise your legal rights, you may contact our data manager using the information below.

Relative Insight Limited: UK Company Number: 06236082
Data Protection Officer

Email address: privacy@relativeinsight.com
Postal address: Fraser House, White Cross Business Park, Lancaster, UK, LA1 4XQ
Telephone number: 01524 928190

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would appreciate the chance to discuss your concerns before you approach the ICO, so please contact us in the first instance.

If you have any questions, concerns or complaints about our Site, please contact us at the email or postal address above or call us on the telephone number provided above.

Is Relative Insight a controller or processor?

We are both, depending on the situation.

This policy distinguishes between:

• the personal data we take from our Customers and Users to enable them to use the Services and Site (referred to as “Processing to enable use of the Services”) – in this situation we are the controller; and
• the personal data that our Customers and Users have collected from their End Customers which is uploaded onto our language analysis software (“Software”) and analysed as part of the Services (referred to as “Processing your End Customers’ personal data”) – in this situation we are a processor.

The processing of the End Customers’ personal data is performed by Relative Insight Limited. The processing to enable use of the Services may be performed by Relative Insight Limited and/or Relative Insight Inc.

 

What data do we collect about you?

1. Processing to enable use of the Services

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may check the details you provide with fraud prevention agencies and share your information with them if we suspect fraud. So, it is important that you do not provide false, inaccurate information, or impersonate someone.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity data includes first name, last name, email address or similar identifier.
• Contact data includes billing address, residential or registered company address, email address and telephone numbers.
• Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Site and Services.
• Usage data includes information about how you use our Site and Services.
• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

In our processing to enable use of the Services, we do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2. Processing your End Customers’ personal data

We potentially process all types of personal data without limitation as part of the End Customer personal data that our Customer or User uploads to the Software.  The type of personal data that we process in each case will be determined by our Customers and Users.

Typical examples are name, gender, date of birth/age, location and contact details. The personal data may include “Special Category data” such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

 

How do we collect your personal data?

1. Processing to enable use of the Services

We use different methods to collect data from and about you including through:

Direct interactions:

You may give us your personal data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• Purchase our Services or use our Site;
• Create an account on our Site or otherwise;
• Contact us to report a problem with the Site or Services, or for any other purpose;
• Request marketing to be sent to you; or
• Give us feedback or contact us.

Automated technologies or interactions:

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources:

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data from analytics providers based outside the EU, such as Google Analytics
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services

2. Processing your End Customers’ personal data

End Customer personal data is collected when either it is uploaded to the Software by our Customer or User or alternatively by Relative Insight.

 

How do we use your personal data?

1. Processing to enable use of the Services

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a lawful basis for processing your personal data although where required by law, we will get your consent before sending direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

We go into this in more detail for each type of processing in the table below.

Purposes for which we will use your personal data:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Necessary for the legitimate interests of others (preventing fraud)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c)Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services and Platform, and to improve the Services and Platform in the future)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical	Necessary for our legitimate interests (to study how Customers and Users use the Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, Platform, Services marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of Customers and Users for our Services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact(c) Technical (d) Usage (e) Marketing and Communications	Necessary for our legitimate interests (to develop our Services and grow our business)

Marketing:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us only if you have requested information from us using our customer query form on our Site and you have not opted out of receiving that marketing. We will also send communications to users who have an account on the dashboard which we feel may be of interest, or help you maximise our services. If you want to change your marketing preferences, contact your account manager or use the unsubscribe option in each such email.

By submitting a telephone number to us you agree that a representative of Relative Insight can contact you at the number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message.  Your consent is not an obligation to receive any of our products and/or services.

Opting out:

You can ask us or third parties to stop sending you marketing messages at any time by contacting us or unsubscribing from our marketing list.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing our Services, logging into our Platform, or other transactions.

Third-party links:

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

All data transferred in and out of Relative Insight is encrypted using hardened TLS. We are also protected by HTTP Strict Transport Security which is pre-loaded in major browsers.

Cookies:

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose:

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Where required under applicable law, if we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

2. Processing your End Customers’ personal data

As the controller, the Customer determines the purpose/s for which we process the End Customers’ personal data which should be set out in the Customer’s privacy policy.

Either the Customer will upload the data (including any End Customer personal data) into the Software themselves (manually or via an automated stream) or alternatively the Customer will provide the data to our Data Ops team who will manipulate it (if necessary) to allow it to be uploaded into the Software.  We will work with the Customer to understand their requirements and inform them when the data has been uploaded into the platform.

Once the data has been uploaded, the Software carries out text analysis in order to generate statistical language models of the data. These statistical models reflect the words, topics and grammar that are used within the data. The Software then compares these generated models with those from another data set. Typically Customers provide more than one data set such as in the example below where data sets for 20 year-olds and for 50 year-olds are uploaded.  Alternatively, we can provide standardised models for the comparison. The Software is able to highlight the statistically significant differences and similarities. The Customer can explore these within the Software and in turn derive insights from the data such as in the example below. These can reflect what is being discussed within the data (e.g. topics, words) and how it is being discussed (i.e. language style – positive, negative, formal, informal, etc.) facilitating actionable insights that can inform the Customer’s business decisions. The Customer is able to export these insights from the Software.

Example

The Software is being used to examine how two different demographics (20 year-olds and 50 year-olds) talk about skin care. The Customer uploads data sets for each group that are compiled from the results of a consumer survey they ran. The Software analyses each data set and builds language models. The Customer then uses the Software to compare the 20 year-old language model and the 50 year-old language model together. The Software identifies that the word “wear” is used more frequently by 20 year-olds, whereas 50 year-olds say “apply” more. The Customer explores this further and identifies that these words are being mentioned in the context of using makeup. The Customer therefore concludes that for marketing to 20 year-olds it is best to use language around “wear makeup” and for 50 year-olds “apply makeup” should be used.

 

Who do we share your personal data with?

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers who provide payment, marketing, IT and system administration services.
• Regulators and other authorities in the United Kingdom who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
• We use analytics services such as Google Analytics to collect and process certain analytics data relating to use of the website. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Hub Spot is our CRM provider, a copy of its privacy notice is available at HubSpot Privacy Policy.
• ChurnZero assesses usage of our Software by our Customers and links with our CRM, a copy of its privacy notice is available at Global Privacy Policy – ChurnZero.
• Our hosting partner is Amazon Web Services, a copy of its privacy notice is available at AWS Privacy (amazon.com).
• Our database infrastructure partner is Mongo DB, a copy of its privacy notice is available at Privacy Policy | MongoDB.
• Our document storage partner is Dropbox, a copy of its privacy notice is available at https://www.dropbox.com/en_GB/privacy
• We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

 

Where do we transfer your data?

Customers and/or their End Customers may be based anywhere in the world. We may share your data with our U.S. based company, Relative Insight Inc. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK to one of these parties, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use service providers, we may use specific contractual provisions required under English, European, California or other law to ensure that our service providers give your data the same degree of protection that Relative Insight has specified in its Terms & Conditions and Privacy Policy.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

 

How long will you keep my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Any data files uploaded by Customers are deleted after seven days.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

End Customer personal data will be retained in accordance with the Customer’s instructions and for no longer than 6 months following the termination or expiry of the Customer’s subscription. Following the initial upload onto the Software, the original source data will automatically be deleted after 7 days.

 

What are my legal rights?

In some jurisdictions, under certain circumstances, you may have rights under data protection laws in relation to your personal data for example.

• Access to information: You may have the right to request a copy of the information we hold about you.
• Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may have the right to ask us to correct or complete information that is inaccurate or incomplete.
• Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.
• Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.
• Right to data portability: You may have the right to receive personal we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).
• Review by an independent authority: You may have the right to lodge a complaint with a supervisory body, including the ICO as listed above.
• Preventing direct marketing: From time to time, we may send emails containing information about new features and other news about us. You may opt out of those emails as described above in the Marketing section of this notice.
• Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time.

If you would like further information on how you can exercise these rights, please email us at privacy@relativeinsight.com.

 

California residents:

California law affords California residents certain additional rights regarding our collection and use of your personal information. To learn more about your California privacy rights, please visit our Privacy Notice for California Residents

No fee usually required:

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you:

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond:

We try to respond to all legitimate requests within one month or for data subjects outside the UK and EU, the period required by applicable law.

It is important that the personal data we hold about you is accurate and current.

Please keep us informed if your personal data changes during your relationship with us.

If you fail to provide personal data:

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Accessibility Statement

We are committed to making sure that our Site is accessible to everyone. To access this Privacy Policy in an alternative form, please email us at privacy@relativeinsight.com. For more information, please see our Accessibility Statement.

 

This privacy policy was last updated in January 2023