Privacy Policy

1 INTRODUCTION 

1.1 Important information and who we are

Welcome to Respired Group’s Privacy and Data Protection Notice (‘Privacy Notice‘).

At Respired Group (‘we‘, ‘us‘, or ‘our‘, or the “Company“) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the UK and EU General Data Protection Regulation (‘EU and UK GDPR‘).

This Privacy Notice will inform you as to how we collect, process and keep your personal data safe, either as customer (whether a consumer or business trader), a supplier of goods and services to Respired Group, an investor or potential investor, or a visitor to or user of our websites (regardless of where you visit them from). The Privacy Notice will also tell you about your privacy rights and how the law protects you.

Whenever dealing with one of the Respired Group companies, the controller of your data will be the Company that decides how and why your Data is processed. If in doubt, please contact us using the details in section 1.2 below.

The individuals from which we may gather and use data can include:

  • customers
  • suppliers
  • business contacts

and any other people that the organisation has a relationship with or may need to contact.

We maintain a separate staff privacy notice which explains how we collect, process and keep their data safe and informs them of their obligations and protocols when processing data. Please contact us for further information or a copy of that notice.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice 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 notice supplements other notices and privacy notices and is not intended to override them.

1.2 Who is Your Data Controller

Respired Limited (company registration number 12586496), the registered office of which is Lincoln House 296-302 High Holborn, Floor 6, London, England, WC1V 7JH, is your Data Controller and responsible for your Personal Data with respect to this website. ‘Respired‘ is committed to protecting the privacy and security of your personal information. We are not obliged by the
UK GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at contact@rensair.com.

This privacy notice is issued on behalf of the Respired Group so when we mention Respired or Rensair, ‘we’, ‘us’ or ‘our’ in this privacy notice, we are referring to the relevant company in the Respired Group responsible for processing your data. Group companies include Rensair Limited, which covers the UK and rest of world, Rensair LLC which covers the US and Canada, and Rensair BV which covers the EU. We will let you know which entity will be the controller for your data when you purchase a product or service with us.

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), or other relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.

1.3 Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees or suppliers who will deal with your data on our behalf (known as ‘Processors‘). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

  • ensure that all processing of Personal Data is governed by one of the legal bases laid out in
    the GDPR (see 3.3 below for more information on those bases);
  • ensure that Processors authorised to process Personal Data have committed themselves to
    confidentiality or are under an appropriate statutory obligation of confidentiality;
  • implement appropriate technical and organisational measures to ensure a level of security
    appropriate to the risk associated with the processing of Personal Data;
  • obtain the prior specific or general authorisation of the Controller before engaging another
    Processor;
  • assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for
    exercising the data subject’s rights;
  • make available to the Controller all information necessary to demonstrate compliance with
    the obligations laid down in the GDPR and allow for and contribute to audits, including
    inspections, conducted by the Controller or another auditor mandated by the Controller;
  • maintain a record of all categories of processing activities carried out on behalf of a Controller;
  • cooperate, on request, with the supervisory authority in the performance of its tasks;
  • ensure that any person acting under the authority of the Processor who has access to
    Personal Data does not process Personal Data except on instructions from the Controller;
    and
  • notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 How is your Personal Data collected? 

We use different methods to collect data from and about you including through:

  • Direct interactions
    You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • This includes personal date you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • invest in our Company or enquire about the same;
    • enter into a contract with us;
    • 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 Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies. Please see our cookie policy below for further details.

  • Third parties or publicly available sources

We will receive personal data about you from various third parties as set out below:

  • Technical Data from the following parties:
    • (a) analytics providers such as Google based outside the UK;
    • (b) advertising and marketing networks such as Google Tag Manager based outside the UK; and
    • (c) Customer messaging services such Tidio based outside the UK;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe, Google, Shopify, LinkedIn, Microsoft Ads and Amazon, based both in and outside the UK;

3 Legal basis for data collection

3.1 Types of data/Privacy Notice scope

‘Personal Data‘ 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
    • Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth, username and password, as well as your interests, preferences, feedback and survey responses;
    • Contact Data: This is data relating to your addresses (billing and delivery), email addresses, phone numbers;
    • Marketing and Communications Data: This is your personal contact data and consent preferences in receiving marketing information and other information from us via the ‘newsletter’ and ‘contact us’ web forms;
    • Billing Data: This is information relating to your debit, credit card and bank information such as the name attached to your payment details and your billing address;
    • Transactional Data: This is information of details and records of all payments to and from you and other details of products and services you have purchased from us;
    • Shareholder/Investor Data: This includes information relating to your shareholding or investments in the Company.
    • Technical Data: This includes internet protocol (IP) address, browser information such as type and version, time zone setting and location, previous search information collected for Google Analytics (Universal and GA4), Google Tag Manager (GTM) and Tidio messaging service. For more information on those services, please refer to the privacy notices on their websites.
  • We also collect, use and share Aggregated Data such as our lead data. 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. 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 Notice.
  • We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
  • 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.

3.2 If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3.3 The legal basis for collecting that data

  • There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
    • ‘Consent‘: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service;
    • ‘Contractual Obligations‘: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service;
    • ‘Legal Compliance‘: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions;
    • ‘Legitimate Interest‘: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

4 How we use your Personal Data 

4.1 Our uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 3.3 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

ActivityType of DataLegal justification/lawful basis
for processing data
Customer purchasesTransactional data, including
identity, contact, financial and
marketing and \communications		(a) Performance of a contract
with you;
(b) necessary for our
legitimate interests (to
recover debts due to us,
to charge and chip the
products you have
purchased from us).
To manage our
relationship with you
which will include:
(a) notifying you about
changes to our
terms or privacy
notice;
(b) communicating with
you regarding your
potential or existing
shareholdings or
investments in the
Company;
(c) asking you to leave
a review or take a
survey.		Identity
Contact
Profile
Investor/Shareholder
Marketing and Communications		(a) Performance of a contract
with you;
(b) necessary to comply with
a legal obligation;
(c) necessary for our
legitimate interests (to
keep our records updated
and to study how
customers use our
products/services).
To administer and protect
our business and this
website (including
troubleshooting, data
analysis, testing, system
maintenance, support,
reporting and hosting of
data)		Identity
Contact
Technical		(a) Necessary for our
legitimate interests (for
running our business,
provision of administration
and IT services, network
security, to prevent fraud
and in the context of a
business reorganisation
or group restructuring
exercise);
(b) 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		Identity
Contact
Profile
Usage
Marketing and Communications
Technical		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,
products/services,
marketing, customer
relationships and
experiences		Technical
Usage		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).
To make suggestions and
recommendations to you
about goods or services
that may be of interest to
you		Identity
Contact
Technical
Usage
Profile
Marketing and Communications		Necessary for our legitimate
interests (to develop our
products/services and grow our
business).
Marketing
communications		Marketing and Communications
data		Consent.

4.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

4.3 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

  • We use the following types of cookies:
    • Essential – Essential cookies enable basic functions and are necessary for the proper function of the website.
    • Statistics – Statistics cookies collect information anonymously. This information helps us to understand how our visitors use our website. We set two cookies in this category, one for Google Tag Manager and the other for TIDIO, the chat functionality available on our websites.
      • Google privacy policy – https://policies.google.com/privacy?hl=en
      • TIDIO privacy policy – https://www.tidio.com/privacy-policy/
    • eCommerce – Our websites use the Shopify eCommerce platform to take personal details of the shopper, including name, email, phone number, shipping and billing addresses.
      • Shopify privacy policy – https://www.shopify.com/legal/privacy
    • Marketing – Marketing cookies are used by third-party advertisers or publishers to display personalised ads. They do this by tracking visitors across websites. We set two marketing cookies, the first one is for Webgains which analyses the website visitor behaviour.
      • Webgains privacy policy-cookies – https://www.webgains.com/public/en/privacy-2/#cookies
      • The second cookie is for Salesforce Pardot which is an email sending platform; it is an extension of the CRM Salesforce where data is processed and is used for marketing purposes. Every marketing email sent out allows the subscriber to either unsubscribe or manage their preferences.
      • Salesforce Pardot Data protection and privacy – https://help.salesforce.com/s/articleView?id=sf.consent_management_pardot.htm&type=5
      • hCaptcha – We also use the GDPR compliant CAPTCHA tool to prove the visitor’s human identity.
      • Privacy policy – https://www.hcaptcha.com/privacy
    • External Media – Content from video platforms and social media platforms is blocked by default. If external media cookies are accepted, access to those contents no longer requires manual consent.

4.4 Change of purpose

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, here this is required or permitted by law.

5 Your rights and how you are protected by us

5.1 How does Rensair Limited protect customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Rensair Limited to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us.

Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

5.2 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • request access to your personal data – commonly known as a data subject access request. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • request correction of the personal data we hold about you. This enables you to have any incomplete or incomplete or inaccurate information we hold about you corrected;
  • request erasure of your personal data. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
  • object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • request restriction of processing your personal data. This enables you to ask us to suspend the processing of personal information about you;
  • request the transfer of your personal data to another party;
  • right to withdraw consent. You can ask us to stop sending you marketing messages at
    any time by contacting us at any time. Where you opt out of receiving these marketing
    messages, we will continue to retain other Personal Data provided to us as a result of
    interactions with us not related to your marketing preferences.

5.3 How to request your data and the process for obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

6 Your data and third parties

6.1 Will we share your data with third parties?

We may also share Personal Data with interested parties in the event that Rensair Limited anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If Rensair Limited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Notice of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Notice (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Notice.

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.

6.2 Third-party links

This Site may include links to third-party websites, plug-ins and applications such as to sites liked LinkedIn, Twitter, Instagram, Facebook and YouTube. 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 Site, we encourage you to read the privacy notice of every website you visit.

7 How long will we retain your data? 

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

8 Age limit for our users

You must not use the Rensair Limited website, or affiliated websites, unless you are aged 18 or older. If you are under 18 and you access our website by lying about your age, you must immediately stop using it.

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

9 International transfer of data

We share your personal data within the Rensair Group. This will involve transferring your data outside the UK. Many of our external third parties are based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK or EEA, we ensure 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.
  • where we use certain service providers, we may use specific contracts approved for use in the UK or EEA which give personal data the same protection it has in the UK or EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

10 Use of Google reCAPTCHA

Description and Scope of Data Processing

We utilize Google reCAPTCHA to protect our website from excessive spam and abuse. This service is designed to verify that the requestor is a human and not an automated program. For users in the European Economic Area and Switzerland, data processing is carried out by:

Google Ireland Limited Gordon House Barrow Street Dublin 4 Ireland

Google automatically collects the IP address, access location, and time of access. Additionally, the behavior of the website visitor is analyzed based on various characteristics (e.g., time spent on the website, mouse movements, cookies stored in the browser history). This analysis by Google begins automatically as soon as you access a page that uses Google reCAPTCHA, provided you have previously consented to its use. Further information on the handling of personal data can be found in Google’s privacy policy:

Google Privacy Policy
Google Partner Sites
Google reCAPTCHA

Legal Basis for Data Processing

The legal basis for this data processing is your consent, in accordance with Art. 6 para. 1 S.1. lit.a) DSGVO.

Purpose of Data Processing

By using Google reCAPTCHA, we ensure that there are natural persons with potential interest behind the requests. This measure allows us to respond to individual requests more efficiently and secure our website against automatically spreading malware.

Duration of Data Storage

Your personal data will be processed only as long as necessary. Once the purpose of the data processing has been fulfilled, blocking and deletion will occur in accordance with our data retention policies, unless legal regulations prevent deletion.

Right to Withdraw Consent

You have the right to withdraw your consent to data processing at any time, in accordance with Art. 7 DSGVO. A withdrawal takes effect from the time it is expressed and has effect for the future. You can revoke your consent by contacting us via telephone, mail, or email.

11 Data security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have 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.

12 Notification of changes and acceptance of Notice

We keep our Privacy Notice under review and will place any updates on this webpage. This version is dated 16 December 2022.

13 Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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