Updated 9 October 2019
ROLI Ltd. ("ROLI") is committed to protecting and respecting your privacy. This privacy policy provides information about the personal and technical data that ROLI may collect through the website https://www.soul.dev and associated pages (“Website”), your use of the SOUL code, and how that personal and technical data is used. By using these above mentioned services, you are accepting and consenting to the practices described in this policy.
"Personal data" means any information relating to you that can identify you, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, or an online identifier.
For the purpose of the EU General Data Protection Regulation 2016/679 (GDPR), the data controller is ROLI Ltd., a company registered in England and Wales under company number 07044888, whose registered office is at 2 Glebe Road, London E8 4BD.
We have appointed a data protection team, responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy including any requests to exercise your legal rights, you can contact us at info@soul.dev stating in the subject heading that your query is about “data protection”.
All your data will be held and used in accordance with the GDPR and any relevant national laws which implement the GDPR and any legislation that replaces it in whole or in part.
When you visit our Website, ROLI may collect and use the following kind of information:
- information that you provide to us for the purpose of registering with the Website and subscribing to its services;
- information that you provide when purchasing a SOUL license , such as your name, e-mail address, address and phone number;
- Internet protocol (IP) address used to connect your computer to the Internet;
- technical information, including your login information, browser type and version, time zone setting, session length, browser plug-in types and versions, operating system,platform, and computer specifications;
- other technical information about your use of this Website, such as your scrolling, clicking, and mouse-over behavior; and +any other information that you share on the Website or send to ROLI.
The SOUL code and the Website are not directed towards children 16 years of age or under, and we do not knowingly collect any information from children. You may not develop an application using SOUL that is “directed toward children” as is defined under the Children’s Online Privacy Protection Act (“COPPA”), or as is defined by other applicable laws, unless you fully comply with COPPA and any other applicable laws relating to the collection of personal information from children.
Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our services. For detailed information on the cookies we use, the purposes for which we use them and how to change your Cookie settings please review our Cookie Policy.
ROLI may use your information to:
- improve our services;
- administer this Website;
- process anonymous analytics for statistical information;
- personalize our Website and our services for you;
- enable your access to and use of certain Website services;
- supply you with the services and products that you purchase;
- send to you statements and invoices;
- send you marketing communications (in accordance with section 6 (Marketing).
In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:
- Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
- Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
- Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not contrary to your rights and freedoms, including your rights to privacy, and to have your information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our Website and user experience, informing you about our services or the products you own, and ensuring that our operations are conducted in an appropriate and efficient manner.
- Consent. In all other circumstances, we will ask for your consent to process your information, or to communicate regularly with you.
We may share your personal information with any member of our group, which means ROLI Ltd., as the ultimate holding company, and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may share your personal information with our trusted businesses or persons to process it for us based on our instructions, and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures, so that we can provide you with and improve our products and services.
In addition to the disclosures reasonably necessary for the purposes identified elsewhere above, ROLI may disclose your personal information to the extent that it is required to do so by law, in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights.
ROLI may share non-personally identifying information publicly and with third parties, for example, anonymous, aggregated data to show trends about the general use of our products and services.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Union, the European Economic Area and Switzerland (“the Territory”), and in particular the United States. It may also be processed by staff operating outside the Territory who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
To the extent that any of your data is provided to third parties outside the EEA, or accessed by third parties from outside the EEA, we will ensure that appropriate safeguards are in place in accordance with the GDPR (such as the European Commission’s standard contractual clauses, or the EU/US Privacy Shield).
We take all steps reasonably necessary to ensure that your data is treated securely, with adequate protections, and in accordance with this privacy policy.
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal data, meet our obligation to employ best practices, and avoid unnecessary storage or transfer of your data. However, we cannot guarantee the absolute security of your data transmitted to our Platform. We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information, but may still be responsible for a breach of personal information and potentially will be required to report this to the Information Commissioner's Office. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Except as otherwise set out in this Privacy Policy, we will ask for your permission if we intend to use your data for marketing purposes.
Where you have previously bought from us, it is in our legitimate interest to send you communications regarding other similar products and services that may be of interest to you. It is also in our legitimate interest to send you communications regarding information about our services, the products you own, and learning and support content that will help you make the most of your ROLI products and services. See ‘Opting out’ below for details of how you can adjust your marketing preferences.
Except as provided above, where you have not previously bought from us, but have registered your details with us (for example by entering a competition), we will send you marketing communications only if you opted into receiving marketing at the time. You may withdraw this consent at any time. You may opt-out of such marketing as provided below under “Opting out”.
Our Cookies Policy also explains how you can adjust your cookies preferences.
In case you decide that you no longer want to give us permission to send you marketing messages, you may do so by unsubscribing from these emails via the unsubscribe link in the footer in each email or by emailing info@soul.dev.
Where you opt out of receiving these marketing messages, we may still contact you as a result of a product/service purchase, including information about our services, the products you own, and learning and support content that will help you make the most of your ROLI products, or related correspondence, and we will continue to process such data in accordance with this Privacy Policy, and only ever as permitted by law.
This Website contains links to other websites. ROLI is not responsible for the privacy policies or practices of any third party.
We will only retain your information for as long as is necessary to fulfil our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data and the potential risk of harm from unauthorised use or disclosure.
You have certain rights in relation to the personal data that we hold about you. Details of these rights and how to exercise them are set out below. Please note we will require evidence of your identity before we are able to respond to your request. Please contact us, if you have such or similar requests at info@soul.dev.
Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR permits, we reserve the right to decline such a request, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
In such circumstances, you can ask us to transmit that information to you or directly to a third party organisation.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.
You can exercise any of these rights at any time by contacting us using the details in the 'Contact’ section below.
Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed. This can usually be done by interacting with our platform.
Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information e.g. if we are processing your information on the basis of our legitimate interests, but there are no compelling legitimate grounds for our processing which override your rights and interests.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right to Withdraw Consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. This can usually be done by interacting with our platform. Alternatively, you can do this by contacting us using the details in the 'Contact' section below.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
We regularly review our compliance with our Privacy Policy and our statutory duties. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We are willing to work with the appropriate regulatory authorities, including data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.
If you are unhappy about our use of your information, you can contact our data protection team or contact us at info@soul.dev. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:
Telephone: 0303 123 11113
Website: https://ico.org.uk/concerns/
Post: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
If you live or work outside of the UK or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different supervisory authority. A list of relevant authorities in the EEA can be accessed here.
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, we will provide you with notification via email and obtain any necessary consents, as required by law. Please check back frequently to see any updates or changes to our Privacy Policy. We will also keep prior versions of this Privacy Policy in an archive for your review.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@soul.dev