1. Introduction

Welcome to the Resonance Labs Holding Company, LLC (‘Resonance Labs’) privacy policy. Resonance Labs is committed to safeguarding the privacy and accuracy of the personal data of our website visitors.

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

2. Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). It does not include data where the identity has been removed (anonymous data).

Usage Data

Usage Data is data collected automatically by the use of the website (for example, the duration of a page visit, information about how you use our website, products and services, internet protocol (IP) address, your login Identifier, browser type and version, time zone setting and location)

Cookies

Cookies are small file(s) stored on your device (computer, mobile device, or virtual reality headset) when browsing a website.

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes and manner personal information is processed.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

General Data Protection regulation (GDPR)

Data protection legislation that governs the use, process, and storage of personal data (information about an identifiable, living person). Any reference to the GDPR applies to both the UK GDPR and EU GDPR. This will remain the case so long as the UK is subject to an adequacy decision by the EU. Should there be a conflict between the two, the version that grants data subjects the greatest protection will apply.

Contact Data includes name, email address and telephone numbers.

Usage Data includes information about how you use our website, products and services, for example, internet protocol (IP) address, your login Identifier, browser type and version, time zone setting and location.

Aggregate Data is collection of multiple data types as part of statistical analysis.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3. Why do we process your personal data

We will only use your personal data when the law allows us and generally in the following circumstances.

1. In the performance of a contract with you
2. The processing is in our legitimate interests, and it is not overridden by your rights
3. To comply with the law

For the purpose of this Privacy Policy, Resonance Labs is the Data Controller of your Personal Data.

If you fail to provide personal data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service.

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.

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.

4. How Is data collected?

We collect data using the following methods,

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

• apply for our products or services.
• enter a competition, promotion, or survey; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect usage data about your equipment, browsing actions and patterns.

• We collect this data by using cookies and other similar technologies.
• The information is used for the sole purpose of remembering your device and your interactions with our website

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• analytics providers
• advertising networks
• search information providers

5. What data is collected?

5.1. Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”).

We do not collect any special categories of Personal Data (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 data). Nor do we collect any information about criminal convictions and offences. We may, however, process some biometric information when using Resonance Labs products, this information is stated before use.

5.2. Usage Data

Tracking technologies are used such as beacons, tags, and scripts to collect and track information on how the website is accessed and used (“Usage Data”). This may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

5.3. Aggregated Data

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.

5.4. Cookies & Tracking

We provide the ability to decline the usage of these cookies except were deemed necessary for the functionality of the website to remain operational. Most browsers allow you to refuse to accept cookies and to delete cookies.

• Blocking all cookies will have a negative impact upon the usability of many websites.
• If you block cookies, you will not be able to use all the features on our website.

Below is a table of the cookies used on Resonance Labs websites, by accepting the use of cookies all of them remain operational.

Cookies

For website performance monitoring and user location tracking, we use Azure Application Insights .

6. Marketing

If you opt-in to receive newsletters, marketing or promotional materials, and other information that may be of interest to you, we will use your Personal Data to contact you or send you the information you requested.

You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send or at any time by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product/service purchase or other transactions.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

6.1. Promotional offers

We may use your usage data to evaluate which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested them when you purchased goods or services from us. You may opt-out of marketing communication but may still receive administrative communications relevant to your purchase.

6.2. Third Party Marketing

We have appointed digital marketing agents to conduct marketing activity on our behalf, our current provider is detailed below, such activity may result in the compliant processing of personal information. Our appointed data processors include:

Edmonds Elder Limited
09633728
ZA581003
contact@edmondselder.com

6.3. Links to other websites

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.

7. Data Sharing

We may share your personal data with the third-party service providers to process data as per the purposes set out in this policy. 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. Examples Include:

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Personal data may be shared as part of business transactions, for example, during a merger or company asset sale. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Under certain circumstances we may be required to disclose your Personal Data if required to do so in response to valid requests by public authorities to comply with a legal obligation and we reserve the right to disclose personal data to protect against legal liability.

Our website uses third party analytics services, data collected is anonymized prior to any transfer to third party.

8. International Data Transfers

We may use external third parties as part of our data processing that are based outside the EEA, this includes personal data transfer outside the EEA.

Whenever we transfer your personal data out of the EEA, we will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

No transfer of your Personal Data will take place to an organization or country without adequate data security & privacy controls.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

9. Data Retention

We will retain your personal data for as long as necessary for the purposes set out in this Privacy Policy and to the extent of compliance with legal obligations.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes.

10. Data Protection Rights

You have the following data protection rights under GDPR. These are summarised as,

• Request access to your personal data.
• Request correction of your personal data.Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data
• Request transfer of your personal data.
• Right to withdraw consent. Please note. If you withdraw your consent, we may not be able to provide certain products or services to 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.

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 https://ico.org.uk/make-a-complaint/ Or call them on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11. Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer (DPO):

Adéle Tredoux
privacy@resolabs.com
(+44) 0794 798 5266
(+44) 0330 175 7645

Resonance Labs
Circus House
21 Great Titchfield Street
London W1W 8BX

If you’re based in the EU/EEA, or Switzerland, and wish to contact us via our GDPR Representative, DataRep, you may do so at:

• datarequest@datarep.com
• www.datarep.com/datarequest
• Contact Locations – EU-EAA

12. Policy review

We may update this policy from time to time by publishing a new version on our website.