R3 HoldCo LLC Website Privacy Statement — Full Statement
R3 HoldCo LLC (together with its subsidiaries, “R3,” “we,” or “us”) respects your concerns about privacy and values the relationship we have with you. This Privacy Statement describes the types of information we collect about you, how we collect, use and retain your information, with whom we share it, how we protect your information, the choices available to you regarding our use of the information, and how you can contact us about our privacy practices.
It is important that you read this Privacy Statement together with any other fair processing policies or notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other policies and notices and is not intended to override them.
- What Information Does This Privacy Statement Apply to?
This Privacy Statement applies to the collection, use, disclosure and retention of information from and about you by R3 on http://www.r3.com and www.corda.net (collectively “the Website”), through email communications, and through other sources. This Privacy Statement does not apply to other websites which may be accessible through hyperlinks on the Website.
While this website may include links to third-party websites, plug-ins and applications, linking to a third-party site does not necessarily mean that we endorse the site, any products or services described on the site, or any other material contained in a third-party site. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites. 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, so please review the privacy statement on those other websites to see how they handle your information.
If you choose to use our Website in any way, such as browsing or interacting, you agree with the terms of our current Privacy Statement as posted here. If you do not agree with this Privacy Statement, you should not use our Website. We may update or modify this Privacy Statement from time to time at our sole discretion, and will note the date of last update on the top of this page. We encourage you to visit this area frequently to stay informed, as your continued use of our Website following the posting of changes to these terms means that you consent to such changes. It is also important that the information we hold about you is accurate and current. Please therefore keep us informed if your information changes during your relationship with us.
- What Information Does R3 Collect?
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 collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, company, title,
- Contact Data includes email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, Media Access Control address, time zone setting and location, browser plug-in types and versions, operating system and platform, device information, domain, webpage address that linked you to our Website, pages visited, and whether you have visited us before or are new to the Website
- Usage Data includes [information about how you use our website, products 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 Statement.
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.
- How is your Information Collected?
We may obtain information about you from various sources. We may collect this information when you provide it on our website, in telephone or email communication, through third parties (such as when you provide employment application information to a third party), or at one of our events. When you visit the Website, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs, and web beacons, as described below.
Information that You or Others Provide
You may choose to provide information (such as Identity Data or Contact Data) to us when you correspond with us by filling in forms, post, phone, email or otherwise.
If you provide us with information regarding another individual, we will assume that you have that person’s consent to give us his or her information.
Information Collected Automatically
When you visit this Website or open an email that we send you, we may collect Technical Data and Usage Data about your equipment, browsing actions and patterns by automated means or by using technologies such as cookies, web server logs, and web beacons, as well as other web-based technologies.
- Web server logs: In conjunction with obtaining information through cookies, our web servers may log details regarding your device, operating system, or information about your Website usage.
- Web beacons & pixels: To control which web servers collect information described above, we may place tags on our Website or in emails called “web beacons” or “pixels.” These are computer instructions that link web pages to particular web servers and their cookies. Web beacons and pixels can be used to track the pages you view, links that you click, or other online behavior. These tools may also be used to measure the effectiveness of our email campaigns by identifying the individuals who open or act upon an email message, when an email message is opened, how many times an email message is forwarded, the type of software, device, operating system and browser used to deliver the email, and any URL accessed through our email message.
- Other: we may use other technology to collect information for the purposes described in this Privacy Statement.
At this time, we do not honor “do not track” signals from website browsers. However, you may refuse or delete cookies. If you refuse or delete cookies, some of the functionality of our Websites may be impaired. If you turn off cookies, Web beacon and other technologies will still detect visits to our Websites, but the information they generate cannot be associated with other non-identifiable cookie information and are disregarded. Please refer to your browser Help instructions to learn more about how to manage cookies and the use of similar technologies.
- How Does R3 Process My Information?
We collect, maintain, and use your information for the following purposes:
- responding to your inquiries or feedback;
- analyzing and improving our Website (including developing new services; improving safety; managing our communications; performing market research; performing data analytics; and performing accounting, auditing and other internal functions);
- making employment decisions if you apply for a position;
- maintaining the security and integrity of our systems, including maintaining internal records;
- conforming to legal requirements or industry standards, complying with legal process, detecting and preventing fraud or misuse, defending our legal rights, or protecting others; or
- as part of a merger, acquisition, bankruptcy, transfer, sale, corporate change, or any other transaction involving all or a portion of R3’s assets.
All information we collect may be aggregated and merged or enhanced with data from other sources, such as third parties. We may also collect and store information locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
The below table describes our use of your personal data, and the legal bases relied on, as well as our legitimate interests where appropriate.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To manage our relationship with you which will include:
· Maintaining your information to notify you about upcoming R3 events
· Sharing R3 updates, newsletters and research material
|(a) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal 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.
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 identified.
- How Does R3 Share My Information?
We may disclose your information to third parties who help us maintain our website or sales and marketing efforts. Examples of these service providers include entities that provide web hosting or analytics services. These service providers may be located around the world and in countries where privacy rules are different or less stringent than rules in the country where you reside.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In addition, we may share your information if necessary to protect the safety, property, or other rights of us, our customers, or employees, or when otherwise required by law. We may also share your information with your consent in certain circumstances.
We reserve the right to transfer information we have about you in the event we sell, transfer, or engage in another transaction involving all or a portion of our business or assets, or undertake another form of corporate change, including bankruptcy. Following such a sale, transfer, or transaction, or corporate change, you may contact the entity to which we transferred your information with any inquiries concerning the processing of that information.
Your information may be stored in databases maintained by R3 (including local storage) or third parties, and may be disclosed to third parties for the purposes stated in this Privacy Statement, that are located within and outside the United States, including countries where privacy rules differ and may be less stringent than those of the country in which you reside. If you visit our Websites from a country other than the United States, you consent to such cross-border transfers of personal data to the United States and to other countries around the world.
Whenever we transfer your personal data out of the EEA, we ensure that 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 by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
- Is My Information Secure?
R3 will take reasonable precautions and put in place appropriate security measures to protect your information from loss and unauthorized access, misuse, alteration or disclosure. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your information on our instructions and they are subject to a duty of confidentiality. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Does R3 Collect Information from Children?
R3 does not intentionally collect information from children under 13 years of age, and children under age 13 should not submit any information to us. If we become aware that a child has provided us with information without parental consent, or a parent or guardian of a child contacts us through the contact information provided below, we will use reasonable efforts to delete the child’s information from our databases.
- What Choices Do I Have?
We only store data for as long as it is 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.
9. I Live in California – What About My California Privacy Rights?
If you are a California resident, you have the right to request information from R3 regarding the manner in which R3 shares certain categories of your personal information with third parties, for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to R3 at its designated email address and receive the following information:
- The categories of information R3 disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and
- The names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
- I Live in the EU – What About my Rights under the GDPR?
As an EU Citizen, the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and you therefore have the following rights:
- Right of access – you have the right to request a copy of the data that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – you can ask for us to restrict the way we process your data.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to our processing your data where we are relying on a legitimate interest in order to process it.
- Right to withdraw your consent – you have the right to withdraw your consent at any time.
Please note that these rights are not absolute and certain exemptions apply. If you wish to exercise any of the rights set out above, please contact us.
- How Can I Contact R3?
R3 is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have submitted information to R3 and you would like to have it deleted from our databases or corrected, or if you have any other questions or comments regarding our privacy practices, please email us at email@example.com for more information.
If you are a resident in the UK, 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Effective Date: 1 May 2019