Action Rocket - Privacy Policy

1. Action Rocket's approach to privacy 

1.1 We appreciate your interest in our website (www.actionrocket.co) (the "Service"). Privacy protection is very important to us. This Privacy Policy sets out information about how we collect, store, process, transfer and use Personal Data relating to you ("Personal Data"). 

1.2 For the purposes of EU data protection laws ("Data Protection Legislation"), Action Rocket is the data controller of personal information we hold about you (i.e., the company which is responsible for, and controls the processing of your Personal Data). 

1.3 You should also be aware that we use cookies and similar technologies to store and access information whilst providing access to our Website.

1.4 Our data protection officer can be contacted by writing to leadership@actionrocket.co.

2. Personal Data we COLLECT about you AND HOW WE USE IT 

2.1 We collect Personal Data about you when you voluntarily submit information directly to us when you access and use the Service. This can include information you provide to us when you e-mail us using the links on the Service, fill in a form, correspond with us via the Service, phone, email or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, respond to surveys or use some other feature of the Service as available from time to time.

2.2 If you choose not to provide Personal Data, we may not be able to provide the Service to you or respond to your other requests.

2.3 The table at Annex 1 sets out the categories of Personal Data we collect about you, how we use such information and how it is disclosed. The table also lists the legal basis which we rely on to process the Personal Data.

2.4 We also automatically collect Personal Data about you indirectly, including about how you access and use the Service and information about the device you use to access the Service.

2.5 The table at Annex 2 sets out the categories of Personal Data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the Personal Data.

2.6 We may link or combine the Personal Data we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us. 

2.7 We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you). We may use anonymised information for our business purposes including testing our IT systems, research, data analysis, improving the Service and developing new products and features. We may also share such anonymised information with others.

3. Personal Data we share with third parties 

3.1 We may share your Personal Data with the following parties for the purposes set out as follows, as further detailed in Annex 1 and Annex 2: 

(a) Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries it owns. These companies will only use your Personal Data in the same way as we can under this Privacy Policy. 

(b) Service providers and advisors: Personal Data may be disclosed to third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements (for example, on Facebook and X), providing payment, mailing or email services, tax and accounting services, data enhancement services, fraud prevention services, web hosting, and/or analytic services. 

(c) Purchasers of our business: Personal Data may be disclosed or transferred to buyers or perspective buyers of our business or any of our assets as part of the sale. 

(d) Law enforcement, regulators and other parties for legal reasons: Third parties who we are under a legal obligation to disclose your Personal Data to or to whom we need to disclose your Personal Data to protect our rights, property or safety or the rights, property or safety of others, detect and investigate illegal activities and breaches of any agreement we have with you.

3.2 We do not disclose information about identifiable individuals to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of the Service but we will make sure no one can be identified from this information before we disclose it. 

4. Marketing and Advertising 

4.1 Email Marketing: From time to time, we may contact you by email with information about the Service. If you do not want us to send you email marketing, you can tick certain boxes on forms we use to collect your Personal Data or you can let us know that you do not wish to receive marketing by sending an email to us at hello@actionrocket.co. You may also be able unsubscribe from our marketing emails by clicking on the unsubscribe link (where available) in the emails we send to you. 

4.2 Advertising on other websites: We, or our advertising partners, may show advertisements to you on other websites or through apps. To do this we, or our advertising partners, may collect information about how you use the Service or the types of other web pages, content and ads you, or others who are using the device you connect to the Service with, interact with, visit or view. The information collected might also include the IP address of the device you connect to the Service. 

We, or our advertising partners, use the information that is collected to make sure adverts you see either on other websites or apps (where our partners have advertising space) are more relevant to you. The techniques our advertising partners use recognise the device you are using but are not aimed at you as a named individual. Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our Cookies Policy.   

5. Storing and transferring your Personal Data 

5.1 Security. We implement appropriate technical and organisational measures to protect your Personal Data against accidental or unlawful destruction, loss, change or damage. All Personal Data we collect will be stored on secure servers. All electronic transaction entered into via our Service will be protected by SSL encryption technology.

5.2 International Transfers of your Personal Data. Your personal data may be transferred to, and processed and stored in, countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal data may be processed outside of the EEA (an "International Transfer"). Any International Transfers of your personal data are made either: 

(a) to a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission; 

(b) to a third party that is a member of a compliance scheme recognised as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission, such as the EU-U.S. Privacy Shield; or 

(c) pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy. 

6. Your rights in respect of your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your Personal Data that we hold:

6.1 Right of access. You have the right to obtain:

• confirmation of whether, and where, we are processing your Personal Data;

• information about the categories of Personal Data that we are processing, the purposes for which we process your personal information, and information as to how we determine applicable retention periods;  

• information about the categories of recipients with whom we may share your Personal Data; and

• a copy of the Personal Data we hold about you.

6.2 Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person.

6.3 Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete Personal Data that we hold about you without undue delay.   

6.4 Right to erasure. You have the right, in some circumstances, to require use to erase your Personal Data without undue delay, if the continued processing of that Personal Data is not justified. 

6.5 Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of that Personal Data.  

6.6 Right of objection. You have a right to object to processing of your Personal Data, based on legitimate interests and direct marketing.

6.7 If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

6.8 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. 

7. Retention Periods

7.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for (as set out in paragraph 2.1 above, and in Annex 1 and Annex 2 below), including for the purpose of satisfying and legal, accounting, or reporting requirements. 

7.2 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 requirements. 

7.3 In some circumstances we may 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.

8. Cookies and similar technologies

8.1 The Service uses cookies and similar technologies to distinguish you from other users of the Service. This helps us to provide you with a good experience when you browse the Service and also allows us to improve the Service.

8.2 Cookies are pieces of code that allow for personalisation of the Service experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device's hard disk (such as your computer or smartphone) for record-keeping purposes. 

8.3 We use the following types of cookies:

8.3.1 Strictly necessary cookies. These are cookies that are required for the essential operation of the Service such as to authenticate users and prevent fraudulent use.

8.3.2 Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Service when they are using it. This helps us to improve the way the Service works, for example, by ensuring that users are finding what they are looking for easily.

8.3.3 Functionality cookies. These are used to recognise you when you return to the Service. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).



8.3.4 Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it, and the marketing messages we send to you more relevant to your interests. We may also share this information with third parties who provide a service to us for this purpose.

8.3.5 Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.

8.4 The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of the Service. These settings will typically be found in the “options” or “preferences” menu of your browser. 

8.5 We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Service, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Service. Typically, this information is collected through cookies and similar tracking technologies.

8.6 If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links (please bear in mind that there are many more companies listed on these sites than those that drop cookies via our website):

8.6.1 Your Online Choices (http://www.youronlinechoices.com/)

8.6.2 Network Advertising Initiative (http://www.networkadvertising.org/)

8.6.3 Digital Advertising Alliance (http://www.aboutads.info/consumers)

8.7 We also use clear gifs in HTML-based emails sent to our Customers to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of our Service. You can set your email options to prevent the automatic downloading of images that may contain these technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

8.8 If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.

9. Links to third party sites 

The Service may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites. 

10. Incorporation of services and contents from third parties into our Service

Contents of third parties, such as videos from YouTube, maps of Google Maps, RSS feeds or graphics from other websites, are or will be integrated into our Service. This always requires that the providers of the contents ("Third Party Provider") will process the IP address or other personal information about you. Without this information they could not send the content for you to view or use. Where an IP address or other personal information is necessary for showing the Third Party Provider content, we try to use content only from those providers that use the IP address or other personal information only for the delivery of such content. However, we have no influence on whether or not the Third Party Provider will save the IP address or other personal information for their own use, e.g. for statistical purposes. 

11. Changes to this Privacy Policy 

We may update this Privacy Policy from time to time and so you should review this Privacy Policy periodically. When we change this Privacy Policy in a material way, we will update the “last modified” date at the bottom of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page. 

12. Notice to you 

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy. 

13. Contact us 

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to: hello@actionrocket.co. 

This Privacy Policy was last modified on 18th May 2018.

Annex 1 and 2 can be found here.