Privacy policy

Welcome to the RSL Revolutionary Labs Ltd’s privacy policy.

RSL Revolutionary Labs Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Purpose of this privacy policy

This privacy policy aims to give you information on how RSL Revolutionary Labs Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product.

We do not knowingly collect data relating to children (under 18 years old).

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

Controller

RSL Revolutionary Labs Ltd is the controller and responsible for your personal data (collectively referred to as “RSL Revolutionary Labs Ltd”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy, our privacy practices, the date we hold on you, or you would like to exercise your legal rights, please do not hesitate to contact our DPO in the following ways:
Email address: info@rsl-labs.com
Postal address: 1 Alkidamou Street, High-tech Cluster, 4101, Agios Athanasios, Limassol, Cyprus

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 01/10/2023. 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.

Third-party links

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.

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:

  • Identity Data includes first name, last name, username or similar identifier.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.

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.

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.

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:
    • apply for our products
    • create an account on our website;
    • request marketing to be sent to you;
    • 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 and other similar technologies. Please see our Cookie Policy 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:

    • analytics providers (Google, based outside Cyprus);
    • search information providers (such as Google based outside Cyprus)
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services (such as JCC Smart based inside Cyprus).
  • Identity and Contact Data from publicly available sources.

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:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

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. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

Our Company collects your personal data so that we can:

(a) register you as a new customer;
(b) process and deliver your order including, manage payments, fees and charges, and collect and recover money owed to us;
(c) manage our relationship with you which will include, notifying you about changes to our terms or privacy policy, or asking you to leave a review or take a survey;
(d) enable you to partake in a prize draw, competition or complete a survey;
(e) administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
(f) deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
(g) use data analytics to improve our website, products/services, marketing, customer relationships and experiences;
(h) make suggestions and recommendations to you about goods or services that may be of interest to you.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide 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 information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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

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. For more information about the cookies we use, please see our policy.

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, where this is required or permitted by law.

We disclose your information to various categories of entities, which is integral to our ability to deliver our services to you. These include:

  1. RSL Revolutionary Labs Ltd Group: We share data within our group as different entities within the group handle various aspects of our operations.
  2. Service Providers: This encompasses entities that facilitate the delivery of your purchases, including payment service providers, warehouses, order packers, and delivery companies.
  3. Brand Partners: In cases where these partners directly dispatch your orders, we will inform you during the ordering process.
  4. Professional Service Providers: We collaborate with professional service providers like marketing agencies, advertising partners, and website hosts who assist in the management of our business.
  5. Affiliates: We engage with affiliates who support us in reaching potential new customers and promoting our products on their websites.
  6. Credit Reference Agencies, Law Enforcement, and Fraud Prevention Agencies: We collaborate with these entities to combat fraud effectively.

In addition to these disclosures, when you opt for certain additional services, we may share your data with specific categories of companies to fulfill your requested services, including:

  1. Product Advisors: These advisors assist you in selecting the most suitable products.
  2. Third-Party Payment Providers: If you choose to utilize their payment services, your data may be shared accordingly.

We do not and will not sell any personally identifiable information to third parties. However, we may provide information about our customers and their purchases to third parties, such as our brand partners, after ensuring that this data is anonymized, aggregated, or stripped of personal identifiers to prevent the identification of individual customers. If you wish to learn more about the third parties with whom we may share personal data or understand their data usage practices, please contact us at info@rsl-labs.com.

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.

How long will you use my personal data for?

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 to our relationship with you. Your personal data will not be retained for a longer period than permitted under applicable law.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Our Company would like to make sure that you are fully aware of all your data protection rights. Every user is entitled to the following rights:

  • (a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • (b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • (c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • (d) 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • (e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • (f) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • (g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you believe that our Company is processing your data illegally, you have the right to lodge a complaint with the competent supervisory authority. In Cyprus, this is the Commissioner for the Protection of Personal Data: http://www.dataprotection.gov.cy/dataprotection/dataprotection.nsf/All/2FBD2ACD407DEFE8C22582B9002E7019.

No fee usually required

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.

What we may need from 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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month 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.