Privacy Policy

Our policy on the collection and use of Personal Data and other information is outlined below:

1. The Reliance MindBridge service ("MB"), related products, websites and mobile applications (e.g. the Reliance Global Call mobile application) are provided by RC UK and by RCOM. See Section X (Other Information) for more information on RCUK, RCOM and the scope of this Privacy Policy.
2. RCUK is a Controller in respect of your Personal Data.
3. We respect the privacy of everyone who uses our services, products, websites and mobile applications and are committed to maintaining the privacy, confidentiality and security of your personal information. This Privacy Policy is designed to assist you in understanding how we use and safeguard the information provided to us in relation to our communications services, products, websites and mobile applications, including, without limitation, ‘RGC’ branded products, services and mobile applications.
4. The scope of this Privacy Policy is set out in further detail in Section XII (Other Information). Enterprise customers should note that this Privacy Policy applies to all users of the RGC services and products when they are supplied to Enterprise customers where such users are private individuals. Where we supply our products and services to Enterprise customers we expect such Enterprise customers to make this Privacy Policy available to and to obtain the agreement of any of their employees or other users that they allow access to our products and services. References in this Privacy Policy to “you”, “your” and similar expressions in this Privacy Policy should be construed to only include natural persons in respect of whom we hold Personal Data and for the avoidance of doubt excludes any Enterprise customers who are not natural persons.

1. WHAT PERSONAL INFORMATION DO WE COLLECT?

   1. Categories of Personal Data that we collect: We may gather and use certain information about you. The information that we may collect includes the following categories of information:
   1. Identification data (e.g. name, username, address, telephone number, mobile number, email address);
   2. Profile information (e.g. age, gender, image, testimonial, country of residence, language preference and any information that you choose to make available to others as part of any public user profile relating to any of our services or products);
   3. Electronic identification data (e.g. IP addresses, cookies);
   4. Payment related information;
   5. Information about your usage of and interaction with our software, services, products, mobile applications and websites (including computer, platform, hand-held device and connection information, client performance information, error reports, device capability, bandwidth, statistics on page views, traffic to and from our websites, browser type and MB Wi-Fi enabled hotspot detection and usage statistics);
   6. Products or services ordered, subscribed, availed and delivered;
   7. Lists of your contacts and related data (we will ask you to confirm if you want us to use contact lists from other services/sources to populate the contacts lists in your account for any of our products and services);
   8. Our correspondence with you (and vice versa);
   9. Your usage data (data processed for the purpose of the conveyance of communications or the billing thereof, including, but not limited to, the duration, time and charge of the call, the number calling from and the number called to and other related data processed by us or provided by you in connection with our provision of products/services to you);
   10. Content of your instant messaging communications, chat and social network interactions carried out on our products, services, websites and mobile applications;
   11. Your location information, derived from your mobile carrier or from the mobile device that you use to access our products/services. Your location is displayed and shared with other MB users only in accordance with the privacy settings you have selected within the relevant product/service. You also may create location information by "geo-tagging" your submitted content with location information. Please manage your privacy settings for location information carefully; and
   12. l. Your mobile device information, such as manufacturer’s name, device model number, operating system, carrier network.
   2. The provision of the categories of your data as listed above will be necessary to allow us to provide you with our products and services.

2. HOW DO WE USE THIS INFORMATION AND FOR WHAT PURPOSES?

   1. Processing your data:Our primary purpose in collecting information is to provide you with the products and services of RCUK and the RCOM group.
   2. Purposes: We collect and use your Personal Data, usage data and billing data for the below business purposes (the "Purposes)and may also transfer your data in accordance with the Purposes to the categories of third parties described below. We collect and use your data for the following purposes:
   1. so that you may download product information, order products and take advantage of certain other features of our products, services, websites or mobile applications;
   2. to provide communication, instant messaging and other products and services in particular to convey the communications and messages you and other contacts make by means of our websites, software, services, products and mobile applications;
   3. to provide information or interactive services you have requested through our websites or mobile applications, to your e-mail address;
   4. to provide other related services as described on our websites and mobile applications;
   5. to resolve disputes (and to anticipate and resolve problems with any of our products and services that are supplied to you);
   6. to verify your identity;
   7. to improve our search functionality and help you find and contact other users of our services and products and Friends more easily and accurately;
   8. to organize and carry out marketing or promotional operations/offers, contests, games and similar events;
   9. to seek your feedback or to contact you in relation to products and services offered via our websites or mobile applications;
   10. to administer or otherwise carry out our obligations in relation to any contract or agreement that you have in place with us (or any contract or agreement that we have in place with an Enterprise customer that allows you to use our services and products);
   11. to process and respond to requests, improve our operations, and communicate with you about our products, services and businesses;
   12. to allow you to subscribe to our newsletter;
   13. to protect your and our interests, including in particular to enforce any agreements and terms of service we may have in place with you and to prevent fraud;
   14. for direct marketing purposes but only when carried out by us or by any of our affiliates concerning other products and services offered by the RCOM group (and unless you have agreed otherwise we will not use or share with a third party any information collected from you for direct marketing purposes);
   15. to share information within our corporate group and with selected third parties including our agents, affiliates or contractors (for purposes other than direct marketing) such as for storage or with third party developers for further technological development or delivery of our services (including, for example, third party mobile application developers such as StarTele Logic (RGC mobile application developer), Freshdesk (MB Live Chat service provider)), or with third party data processors (such as Google Analytics) carrying out market/customer analysis for us, or for carrying out the other types of processing described in this Section, or because of where relevant IT systems, computer servers and storage units are located). This may involve the transfer of Personal Data to non-EEA countries (such as India), and will only be undertaken subject to appropriate and adequate safeguards (see paragraph 3 below);
   16. to share your information with companies within the RCOM group or other entities under our direct or indirect control and in the event that we undergo re-organization or are sold to a third party, your information may be transferred to any successor re-organized entity or entities or other third party for the purposes of providing any of our services and products that we have agreed to provide to you in accordance with any contract or agreement that is in place between you and us (or any contract or agreement that we have in place with an Enterprise customer that allows you to use our services and products);
   17. if you e-mail us (for example to make an enquiry about our products and services or to raise a service issue), we will use that e-mail address to respond to you and you voluntarily provide any information contained in your e-mail correspondence to us. Unless you have agreed otherwise, we will not use information that can identify you, such as your e-mail address, for direct marketing purposes;
   18. we will access your contact details on your hand-held device to reflect your contact information in any MB user’s hand-held device or the contacts list of any MB product or services of that MB user if that MB user has your contact details in his or her hand-held device or your contact details are in any contacts list that the other MB user has in relation to any of our products or services that that MB user is a member of and such data or contacts will also be subject to this Privacy Policy;
   19. we may from time to time ask you to provide information on your experiences with us. Where we have asked you for such information we may use this to measure and improve the quality of our products and services. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the website or any survey that you take part in is used for the purposes of reviewing this feedback and improving our software, services, products, websites and mobile applications;
   20. we may use your contact information to contact you to send you messages for the purposes of validation of your mobile number after signup and before use of our products and services or for faults and service issues;
   21. we may also use your phone contact details, email address, the MBsoftware, RGC mobile applications or SMS to notify you of any eventual claims related to your use of our software, services, products, websites and mobile applications, including without limitation claims of violation of third party rights;
   22. we may also use your email, SMS, MBsoftware or RGC mobile applications to keep you up to date with news about the MB software, services and products that you have purchased and to inform you about other MB software, services, products or other MB related information;
   23. we may contact you by email, phone, address and other contact information to contact you by letter, SMS, notification or any other similar means (including via the MB software or mobile application) for the purposes set out above;
   24. we may contact you by email, phone, address and other contact information to contact you by letter, SMS, notification or any other similar means (including via the MB software or mobile application) for the purposes set out above; and
   25. if requested by any Enterprise customer (and subject to the terms any agreement or contract that we have in place with an Enterprise customer) to share your information with the Enterprise customer that has allowed you to have access to our products and services (subject to applicable law and if necessary subject to appropriate and adequate safeguards, see paragraph 3 below).

   You can opt-out of the receipt of alerts and promotional emails: (a) by clicking the ‘unsubscribe’ link on emails that you receive or by changing your notification settings on your account; and (b) calling our customer care number on 0800 911 677 OR 156 721 557. Users may also adjust their general communication preferences via the relevant settings on our websites and mobile applications.

   3. Adequate safeguards:We will ensure that our affiliates, agents, contractors, partners and any other third parties to whom we make your Personal Data available will protect your personal information in a manner that is consistent with this Privacy Policy and applicable laws and regulations. Where we transfer your information to any of our affiliates, agents, contractors, partners or other third parties we will take the necessary steps to ensure that such persons agree that appropriate and adequate safeguards are applied to your Personal Data in accordance with applicable laws and regulations (which may include applying appropriate contractual or other requirements to relevant affiliates or third parties).
   4. To the extent required or permitted by any applicable laws and regulations, we may also collect, use and disclose personal information in connection with security related or law enforcement investigations or in the course of cooperating with authorities (including, without limitation, government entities, police or prosecution authorities, the U.K. Information Commissioner’s Office, relevant competent authorities, courts and other similar bodies in the UK, US, EEA, India or elsewhere) or complying with legal requirements that are applicable to us.
   5. Except as provided above, we will not sell, rent, trade or otherwise transfer any of your Personal Data, traffic data or communications content outside of RCOM and its affiliates without obtaining further specific consent from you, unless we are obliged to do so under applicable laws and regulations or by order of any competent authorities in the UK, EEA, India or elsewhere.
   6. Please note that information that you voluntarily make public in your user profile, or which you disclose on forums, discussions boards or by posting comments will be publicly available and viewable by others.

3. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

   1. Security: We will take appropriate organizational and technical measures to protect the Personal Data, traffic data and communications content provided to us or collected by us with due observance of the applicable obligations and exceptions under the relevant legislation.
   2. Access:Your Personal Data, traffic data and communications content can only be accessed by our authorized employees or our affiliates, subsidiaries, business partners or service providers who need to have access to this data in order to be able to fulfil their given duties and, where relevant, only in accordance with relevant safeguards and requirements that we apply to such persons.

4. WEBSITE INFORMATION AND COOKIES

   1. Automatically collected data: When you access our websites, mobile applications, products or services, information sent by your web browser, mobile application or hand-held device, may be automatically collected. This information typically includes your domain name (the site after the @ in your e-mail address). It may also contain your user name (the name before the @ in your e-mail address). Other examples of information collected by your server include the Internet protocol (IP) address used to connect you to the internet, operating system and platform, the average time spent on our website, pages viewed, information searched for, access time, websites visited before and other relevant statistics. The amount of information sent depends on the settings you have on your web browser, mobile application or hand-held device; please refer to the settings on your browser, mobile application or hand-held device if you want to learn what information it sends.
   2. All such information will be used only to assist us in providing an effective service on our websites. We may from time to time supply the owners or operators of third party websites from which it is possible to link to our website with anonymised information relating to the number of users linking to our website from such third party website. No Personal Data would be included and you cannot be identified from this information.
   3. We use the information that we automatically receive from your web browser, mobile application or hand-held device to see which pages you visit within our websites, which website you visited before coming to ours, and where you go after you leave. We can then develop statistics that are helpful to understanding how our visitors use our websites. We use this information in the aggregate to measure the use of our websites and to administer and improve our websites. Once aggregated for statistical purposes, you cannot be identified from this information. No Personal Data would be included and you cannot be identified from this information. This statistical data is interpreted by us in our continuing effort to present the website content that visitors are seeking in a format they find most helpful.
   4. Use of Cookies: We may store some information such as "cookies" on your computer, mobile application or hand-held device when you access our websites. Cookies are pieces of information that a website transfers to the device a visitor uses to access the website for record-keeping purposes. This information facilitates your use of our websites and ensures that you do not need to re-enter personal information every time you use our websites. You can erase or choose to block this information from your computer, mobile application or hand-held device if you want to; please refer to the relevant settings on your computer, mobile application or hand-held device to do so. Erasing or blocking such information may limit the range of features available on our websites. We also use such information to provide visitors with a personalized experience on our websites. We may use such information to allow visitors to use our websites without logging on upon returning, to auto-populate forms, to make improvements and to better tailor our website to your needs. We may also use this information to verify that visitors meet the criteria required to process their requests.
   5. Consent to cookies:Our websites may display a notification requesting your consent to place a cookie on your browser for the purposes set out in paragraph 4 above. By accepting our cookies request you are confirming your consent for us to place a cookie on your browser and to access it for the purposes identified in paragraph 4 above.

5. LINKED WEBSITES AND THIRD PARTY APPLICATIONS

   1. External, third party websites:Our websites and mobile applications may contain links that will let you leave our websites and mobile applications and access another website. Linked websites are not under our control and these websites may have different privacy policies. This Privacy Policy applies solely to personal information that you have provided to us through your use of our websites, software, products, services, mobile applications and your relationship with us. We urge you to be careful when you enter any personal information online. We accept no responsibility or liability for these other websites.
   2. Applications:If you use any extras, plug-ins or third party applications together with our software, products, services, websites or mobile applications or use any third party applications or products that incorporate or embed the same (“Applications”), the provider of such Applications may obtain access to certain personal information about you. We do not and cannot control how the provider of Applications may use any personal information connected in connection with such Applications. Please ensure that you review any privacy policies or other terms applicable to the use of such Applications before using them. We can make no promises or guarantees regarding data collection on hyper-linked pages and on websites that are not owned by us. We recommend that you check the policy of each website you visit, or link from, and contact the owners or operators of such websites if you have any concerns or questions.
   3. We may include links, “share” buttons or similar features on our websites and mobile applications to such third party email, instant messaging, and social network service providers (including Facebook, Twitter, Google Plus, LinkedIn, YouTube, Pinterest). We do not share your Personal Data with such third party partners and platforms. However your interactions with such persons may result in them holding your personal data. Our Privacy Policy does not apply to the use of any Personal Data you provide to them. We are not responsible for what they do with Personal Data and we recommend that you check the privacy policies of such third parties and your privacy settings in their systems.

6. PERSONAL DATA OF FRIENDS

   1. Friends' Personal Data:You can invite your contacts who are not registered as users of our products and services ("Friends") to register for the same. If you invite a Friend to join or subscribe to any of our services or products, we will collect and store the information associated with such invitations (e.g. names and email addresses), link such information to our data about your account and use such information provided, to contact that person. We will send that Friend a message on your behalf using your name, email address and telephone number in such invitation. We will also remind that Friend that his or her contact details have been provided by you and that he or she has been invited to join our services and products by you. All such invitees shall have an option to accept or reject the same.
   2. All Friends who have received such an invitation should note that the contact information that we use to send invitations to them has been provided to us by MB users. Friends will be given an option not to receive further invitations from us. This Privacy Policy will be made available to Friends who have been sent such an invitation. Friends’ Personal Data will also be subject to the protections described in this Privacy Policy to the extent applicable to their Personal Data that we have in our possession and Friends may also contact us to exercise any rights specified in this Privacy Policy in relation to their Personal Data.

7. YOUR RIGHTS

   1. Data subject rights: You have the right to:
      1. request access to your Personal Data;
      2. request a copy of your Personal Data (in a commonly used interoperable format);
      3. request a rectification be made to correct any errors or inaccuracies in your Personal Data;
      4. object to the processing of your Personal Data;
      5. restrict the processing of your Personal Data; and
      6. request the deletion of your Personal Data.
      Some of your information may be viewed or edited online by signing into your account page on our websites or mobile applications.
   2. We will respond to your requests within a reasonable period of time and upon verification of your identity.
   3. You may also request a copy of safeguards that we have put in place in respect of your Personal Data with our affiliates, agents, contractors, business partners and other third parties to whom we have made your Personal Data available to be made available to you (subject to any redactions for commercially sensitive or confidential information).
   4. Withdrawal of consent:You may also notify us at any time in writing or by email to withdraw your consent to the use of your Personal Data (however this shall not affect the lawfulness of any processing of your Personal Data prior to notification).
   5. Maximum retention period and deletion of data: Our general policy is to retain your data for a maximum of 10 years from the date that we received it unless any other time period for retention applies under paragraphs a. or b. below:
      1. for as long as necessary to fulfil any of the Purposes; or
      2. if you have lawfully exercised your right to request deletion of your Personal Data.
      We will use all reasonable endeavours to accommodate a request to delete your Personal Data unless the Personal Data (or any part of it) is required to be retained by law (including, without limitation, any applicable tax, limitation periods, regulatory or anti-money laundering laws, rules, requirements or requests by competent authorities or courts) or where there is a legitimate basis for the retention of that Personal Data. Your details may still appear in the search directory of our products and services during this time.
   6. Complaints: You have the right to lodge a complaint against us with any competent authority (including, for example, the UK Information Commissioner’s office (https://ico.org.uk/concerns/ ).
   7. For the avoidance of doubt, references to "you" in the paragraphs above only includes natural persons in respect of whom we hold Personal Data (e.g. users of our products and services) and excludes any Enterprise customer that is not a natural person.

8. HOW CAN YOU CONTACT US?

   For all data protection matters, requests and queries please contact our Data Manager atsupport@reliancemindbridge.com with the subject line, "Privacy".

9. CAN THIS PRIVACY POLICY BE MODIFIED?

   We may update this Privacy Policy and post revised versions on our websites from time to time to reflect changes in relevant applicable law, regulation and guidance, our software, products, services and customer feedback. If there are material changes to this Privacy Policy or in how we use your Personal Data, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to be informed of how we are collecting, using, and protecting your Personal Data.

10. OTHER INFORMATION:

    1. In the EEA, the Reliance MindBridge services (and related websites, products and mobile applications) are provided by RCUK. Elsewhere, the Reliance MindBridge services (and related websites, products or mobile applications) are provided by different group entities.
    2. EEA Representative:To the extent that RCOM is a Data Controller (and excluding data held by it under Controller to Processor transfers of Personal Data), RCUK is designated as RCOM’s representative in the EEA for the purposes of Article 27 of the GDPR.
    3. Sensitive Personal Data:It is our policy and intention not to request, collect or process Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of identifying natural persons, data concerning health or data concerning a person’s sex life or sexual orientation.
    4. Scope of Application: This Privacy Policy applies to any Personal Data that is collected and processed by us (and the affiliates and third parties described in Section II (How do we use this information and for what purposes?)) in relation to natural persons (such as any employees or other users that Enterprise customers have permitted to have access to the products and services that we supply to our Enterprise customers) accessing the Reliance MindBridge service (and any other MB-branded services or products) via our websites and mobile applications. This Privacy Policy also applies to: (i) any Personal Data of natural persons that is provided to us or that we collect in other circumstances (e.g. prospective users of our services and products, visitors to our websites); and (ii) Friends that you have invited who are not registered as MB users to register for our services (see, in particular, Section VI (Personal Data of Friends)).
    5. The information, products and services offered by us via our websites and mobile applications are not directed at and not intended for or designed to attract any person who is under the age of 18 years. We do not intentionally or knowingly collect personal information from anyone under the age of 18 years (or older where there is an older age of majority).
    6. Interpretation:The rights that you are provided with in this Privacy Policy shall be interpreted and construed in accordance with English law.

11. GLOSSARY

    The following defined terms used in this Privacy Policy have the meanings set out below:

    1. "Controller":has the meaning given to that term in the GDPR. Under the GDPR "controller" means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
    2. "EEA": means the European Economic Area.
    3. "Friends": are defined in Section VI (Personal Data of Friends).
    4. "GDPR": means EU General Data Protection Regulation 2016/697.
    5. "Personal Data": has the meaning given to that term in the GDPR. Under the GDPR “personal data” means any information relating to an identified or identifiable natural person.
    6. "Processor": has the meaning given to that term in the GDPR. Under the GDPR “processor” means a natural or legal person, public authority, agency or other body which processes (as that term is defined in the GDPR) Personal Data on behalf of the Controller.
    7. "RCUK": means Reliance Communications (U.K.) Limited, a company incorporated and headquartered in England and Wales with Companies House registration number 04616804 and its registered office at: Sovereign Court 635 Sipson Road, Sipson, West Drayton, Middlesex, England, UB7 0JE.
    8. "RCOM": means Reliance Communications Ltd. a company incorporated and headquartered in India with company registration number L45309MH2004PLC147531 and its registered office at: H Block, 1st Floor, Dhirubhai Ambani Knowledge City, Navi Mumbai, 400 710, India.
    9. "We", "Our", "Us" (and other similar expressions): means both of RCOM and RCUK.
    10. "You", "Your" (and other similar expressions): means you, the natural person whose Personal Data is protected and governed by this Privacy Policy.

12. BASIS FOR PROCESSING OF YOUR PERSONAL DATA

    1. We use your Personal Data for the Purposes stated in Section II (How do we use this information and for what purposes?) in order to provide our services and products in accordance with any contract or agreement that we have in place with you and on the basis of our legitimate interests (subject to applicable laws).