Rungway Privacy Policy

Rungway Limited ("we", “us” or “Rungway”) are committed to protecting and respecting your privacy. This policy (together with our Terms of Use) and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us on behalf of other organisations as set out below. This will include data collected or provided when you visit www.rungway.com or the Rungway mobile application (the “Platform”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who We Are

We are Rungway Limited of 71-75 Shelton Street, London WC2H 9JQ.

We have entered into an agreement with the following organisation:

CLIENT NAME whose registered office is CLIENT ADDRESS (the “Company”). The Company is the Controller of your personal data for the purposes of the applicable data protection legislation and we are providing the information in this policy on behalf of the Company.

The Basis On Which Your Data is Processed

The Company instructs Rungway to process your personal data in accordance with this policy on the following basis:

• where it is necessary for compliance with a legal obligation to which the Company or Rungway is subject; or
• where it is necessary for the purposes of the legitimate interests pursued by the Company or by Rungway, and the Company has assessed that these interests are not overridden by your interests or fundamental rights and freedoms.

The legitimate interests referred to above are:

• to identify and make any improvements to the Company’s workplace environment, its communication, culture, and to the support of its employees;
• to assist the Company in complying with its statutory and contractual obligations with respect to employees; and
• to enable Rungway to provide a service to the Company.

Why We Collect Information About You

We collect data about you on behalf of the Company for the following purposes:

• to enable the Company to identify any workplace challenges, or developmental needs within its organisation and build up a content bank of how to respond to these challenges or development needs in the future;
• to assist the Company in maintaining its records in the event of employment or other legal disputes;
• to provide the Platform to you and give you the best possible experience of using our services.
• to provide anonymised, aggregated, non-identifiable reporting of themes and topics being raised by employees and provide anonymised insights to the Company so they can better support all employees.
• If you are using the Rungway Pulse platform: to send you company survey questions,
• If you are using the Rungway Advice platform: to match your own questions with other colleagues to answer, to notify both parties of subsequent messages, to notify all users of new questions, and in providing summaries of new content on a regular basis (e.g. weekly summary of popular questions and answers) 

Information We May Collect From You

We may collect and process the following data about you:

Registration: To register on the Platform, you must provide us with your name, email address, and a password. You may provide additional information during the registration process (for example, your job title) to help us understand more about you.

If you are using the Rungway Advice platform: You understand that, by creating an account, we and other users from within your Company will be able to identify you by your public profile (though you may choose to post anonymously on the Platform where the “Anonymity” feature will be shown to you as available. Any “pulses” that you respond to on Rungway are automatically anonymous). After or during the time you create an account, you may choose to provide additional information on your profile such as descriptions of your skills and professional experience, and update these details from time to time. As you use the Platform you may choose to answer questions that get posted from time to time, or to ask questions - either publicly or anonymously. Providing additional information enables you to derive more benefit from the Platform. Please note that the personal information that you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender or ethnicity). The information you provide may also reveal and/or result in Rungway processing your special category data (please see paragraph (e) for further information about this).

If you are using the Rungway Pulse platform: Any pulse questions that you respond to on Rungway are automatically anonymous. 

You may also be invited to provide optional sensitive information such as details relating to your ethnicity (“special category data”) as part of the registration process. This is entirely optional and the data is collected solely for the purposes of providing fully anonymised and aggregated workplace insights to your organisation. This data will never be shown on your profile. You can withdraw your consent to our use of your data in this way at any time by emailing compliance@rungway.com and telling us that you no longer wish your special category data to be processed. Please note that this does not affect any processing that we may have already undertaken before you withdraw your consent.

Interacting with us: You may give us information about you by corresponding with us by e-mail or otherwise, for example where you contact our customer services department.

We may receive the following information about you from the Company:

• information on which department you belong to in the Company;
• the country in which you are located;
• your email address, so that we can invite you on to the Platform
• further information relevant to your role within the Company

With regard to each of your visits to our Platform we may automatically collect the following information:

• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); people you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
• Content that you upload. We will have access to the content which you provide on the Platform, including your profile data. 

Special Category Data

You are in complete control as to what information you place in your profile.

As set out in paragraph (d) above, you may decide to input “special category data” in your profile or otherwise disclose special category data when you submit content into the Platform. 

Please note that it is your choice whether to disclose special category data on Rungway. You are responsible for any content you choose to publish. If you choose to share any personal data or special category data, you understand that data may be viewed by others across your organisation. By choosing to publish such personal data, you are giving us your explicit consent to process it by storing the post within the Platform, and to provide insights to your organisation on trending topics in an anonymised and aggregated manner.

You can withdraw your consent at any time by emailing compliance@rungway.com and telling us that you no longer wish your special category data to be processed. 

If you are using the Rungway Advice platform, you can remove any special category data that is viewable on your public profile by updating your profile accordingly. Please note that this does not affect any processing that we may have already undertaken before you withdraw your consent. You are responsible for not posting any further content that discloses this information.

You understand that your special category data is subject to the same level of security as other personal information you upload to the Platform.

Cookies

Our website uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Platform.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. 
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. 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).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our Platform.

Except for essential cookies, all cookies will expire after a period appropriate to their use.

Uses made of the information

We use information held about you in the following ways:

We may use this information:

• to inform and refine the Platform;
• to carry out our obligations arising from any contracts entered into between the Company and us and to provide you with the information, products and services that you request from us;
• to notify you about changes to the Platform;
• to ensure that content from the Platform is presented in the most effective manner for you and for your computer or device;
• to monitor the use of the Platform from time to time to eliminate infringing, defamatory, immoral, illegal, abusive and/or inappropriate use.
• If you are using the Rungway Advice Platform: to connect you with other users of the Platform from within your Company and to prompt you or them to respond to questions by sending a reply. Your public profile may be viewable by any other users of the Platform from within your Company.

We will use this information:

• to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to provide completely anonymized and aggregated reports to the Company 
• to improve our Platform to ensure that content is presented in the most effective manner for you and for your computer or device;
• to allow you to participate in interactive features of the Platform, when you choose to do so;
• as part of our efforts to keep the Platform safe and secure;
• if you are using the Rungway Advice platform: to best match you with other users from within your Company whose questions you may be suited to answer, or who may be best able to answer your questions;

We will only use this information:

• to invite you to join the Platform;
• to give you the best service on the Platform; 
• to provide completely anonymised and aggregated reports to the Company.

We guarantee not to use your information for any other purpose.

The Company will use your information:

• to enable the Company to identify any workplace or business challenges, or employee support and developmental needs within its organisation; and
• to assist the Company in maintaining its records in the event of employment or other legal disputes.

Your information will be available to the Company except where you are posting using Rungway’s “Anonymous” features. The Company and its employees may read any posts published by you under name for the above purposes.

We will not pass to any other third parties any personal information that would identify you as an individual or be directly linked to you as an individual (including your contact information) except in the limited circumstances explained in this section.

We may need to share your information with our business partners, suppliers and sub-contractors for the performance of any contract we enter into with the Company. We may also share non-identifiable personal information with selected third parties for the following purposes:

• Analytics and search engine providers that assist us in the improvement and optimisation of our Platform.

We may disclose your personal information to third parties:

• If Rungway or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers may be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with a legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Rungway, our customers, or others.

Storage and security

Rungway is a company located in the UK. If you are located outside of the UK, your data will be transferred into the UK and into the European Union where our cloud servers are hosted.

We may also share your personal data outside of Rungway with our third party service providers, agents and contractors (for example, the providers of our electronic data storage services and user support service providers) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

• the country that we send the data to might be approved by the European Commission;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
• ensuring your personal data is always protected and transferred in accordance with the relevant data protection laws.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.”

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have implemented appropriate security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on the Platform is password-protected and we use appropriate authentication and encryption. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please note that emails, instant messaging, and similar means of communication with other users are not encrypted, and we strongly advise you not to communicate any confidential or financial information through these means.

Data retention

We retain the personal information you provide no longer than is necessary for the purposes for which it was collected. Our right to retain your personal information is subject to the exercise of your rights to request erasure in accordance with applicable data protection legislation.

Any public content posted by you during your use of the Platform will remain on the Platform even after you have left employment with the Company so that other users can view this content to help them with similar issues they may be facing.

Third Party Sites

The Platform may, from time to time, contain replies posted by others in your Company who refer to third party websites. 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 these policies. Please check these policies before you submit any personal data to these websites.

Your Rights

You have the following rights:

• The right to request access to the personal data that we hold about you;
• The right to request rectification of the personal data that we hold about you;
• The right to request erasure of the personal data that we hold about you (although please note that this right is limited by certain circumstances, for example: where the information is still required for the purposes set out in this privacy policy, there are overriding legitimate grounds for the processing, or where it is required for compliance with a legal obligation of the Company);
• The right to request restriction of processing about you;
• The right to object to processing; and
• The right to data portability.

If you wish to invoke any of the above rights, please notify us using the contact details set out in the contact section below.

You have the right to lodge a complaint with a supervisory authority. In the United Kingdom, the supervisory authority is the Office of the Information Commissioner, full contact details for which can be found at https://ico.org.uk/global/contact-us/

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below: “Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Chief Compliance Officer, Rungway, 71-75 Shelton Street, London WC2H 9JQ. Or emailed to compliance@rungway.com