Effective Date: 9 March 2022
R3 HoldCo LLC (together with its subsidiaries, “R3,” “we,” or “us”) respects your concerns about privacy and values the relationship we have with you. R3 will collect, process and use your personal data in compliance with all data protection and privacy laws applicable to the processing of personal data in all R3 operating jurisdictions (“Applicable Laws”).
2. 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 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.
3. 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 behaviour. 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.
At this time, we do not honour “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.
4. How Does R3 Process My Information?
- responding to your inquiries or feedback; or
- analysing 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); or
- making employment decisions if you apply for a position; or
- entering into or performance of contractual obligations; or
- to safeguard legitimate interests; or
- maintaining the security and integrity of our systems, including maintaining internal records; or
- 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
- on the basis of your consent; 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.
|Purpose/Activity||Type of Data||Lawful Basis for Processing|
|To manage our relationship with you which will include: Maintaining your information to notify you about updates and events related to R3 or the Corda Network||(a)Identity (b)Contact||(a) Necessary for our legitimate interests (to manage our relationship with you)|
|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 grounds we are relying on to process your personal data where more than one ground has been identified.
5. How Does R3 Share My Information?
We may disclose your information to third parties performing required services on our behalf or 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.
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.
Whenever we transfer your personal data out of the EEA and UK, 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 and the UK’s Information Commissioner’s Office (ICO). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and European Commission: Adequacy of the protection of personal data in the UK.
- 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 and the UK International Data Transfer Agreement (IDTA) and the International Data Transfer Addendum to the new European Commission SSCs (Addendum).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. 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.
7. 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.
8. 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.
10. I live in the EU – What About my Rights under 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 click here.
11. 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.