How Rept collects, uses and protects personal data, and the rights you have over it under UK GDPR and PECR.
We are Rept, a signal-triggered, AI-driven outbound marketing service. We provide marketing services to a global client base. The majority of our data processing involves publicly available business contact details that we use to identify relevant sales prospects for our clients.
This privacy policy explains how Rept collects and processes your personal data through your use of this website, including any data you may provide through it.
This website is not intended for children and we do not knowingly collect data relating to children.
Imperial Outreach Limited t/a Rept is the controller and responsible for your personal data (collectively referred to as “Rept”, “we”, “us” or “our” in this policy).
We take privacy very seriously and are always available to address privacy concerns via the contact details below.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Personal data, or personal information, 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 as follows:
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 it will not directly or indirectly reveal your identity. For example, we may aggregate 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, used in accordance with this privacy policy.
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.
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 services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you, including:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Please refer to the glossary below to find out more about the types of lawful basis we rely on to process your personal data.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
For example, if you opt out of receiving email communications from Rept, we may keep a record of your email address indefinitely to ensure you are not contacted again.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to request access to, correction of, or erasure of the personal data we hold about you (see Your legal rights in the glossary). This does not include any data we are obliged to keep for administrative, legal or security purposes.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You can ask us or third parties to stop sending you marketing messages 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 as a result of a service purchase, service experience or other transaction.
Several of our external third parties are based outside the UK, 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, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us by email if you require any further information.
The General Data Protection Regulation (UK/EU) (GDPR) is a regulation on data protection and privacy. It also addresses the transfer of personal data outside the UK, EU and EEA. The GDPR’s primary aim is to enhance individuals’ control and rights over their personal data and to simplify the regulatory environment for international business. The regulation applies to any enterprise, regardless of its location and the data subject’s citizenship or residence, that processes the personal information of individuals inside the relevant territory.
We observe GDPR best practices wherever possible, at all times, and oversee our adherence to the rules internally. This allows us to assure clients that data is handled responsibly throughout every campaign.
It is important to note that both Rept and the client (you) have responsibility at all times to adhere to GDPR guidelines. Even though Rept is the service provider, we are both responsible for choosing who to target, what data to use and collect, and the messages we send out. We outline some of our data practices in our service agreement.
Because Rept conducts strictly B2B (business-to-business) email marketing, prior explicit consent is not required from recipients, provided certain conditions are met.
In the UK, the ICO classes employees of legally-registered businesses as ‘Corporate Subscribers’. Because of this, the PECR rules on electronic marketing to individual subscribers do not apply in the same way. Rept includes a valid, free-of-charge opt-out mechanism in line with PECR guidelines for any prospect who wishes not to be contacted further.
GDPR includes several provisions regarding the collection and storage of data, and we take great operational care to ensure that data is collected and stored properly. We also conduct an assessment of a client’s product, service or offering to ensure that, when paired with our outreach, all GDPR and PECR guidelines are met. A crucial part of this assessment is the Legitimate Interest Assessment (LIA), which determines three main points:
If Rept determines that a planned campaign would not meet these criteria for an LIA within the scope of GDPR, we cannot support the activity subject to GDPR guidelines.
In the UK, GDPR controls the storage and processing of personal data, while the sending of messages is regulated under the Privacy and Electronic Communications Regulations (PECR). PECR sets the requirements for business communication: you can email or text any corporate body (a company, Scottish partnership, limited liability partnership or government body). Rept includes opt-out options in our outreach so that recipients can block further contact should they be unhappy with being contacted.
Everyone who works on Rept’s campaigns understands the importance of compliance for both Rept and our clients, and is aware of the consequences associated with failure to comply.
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.
Rept takes detailed care to ensure all regulatory guidelines and rules are adhered to. However, as a client, you have the responsibility to follow the relevant regulatory frameworks in your country and to alert Rept if you see changes that need to be made. It is not possible for Rept to constantly monitor all such frameworks in all countries at the same time, which is why you, as the client, are crucial in ensuring compliance.
Rept has worked to develop an operational framework that supports good practice and data-privacy compliance for our clients. Our hyper-personalisation, specific to each prospect, is further evidence that the emails are relevant, specific, and respect the rights and expectations of the recipient.
The interest of our business in conducting and managing it to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Under certain circumstances, you have the right to: