Privacy Policy
Rhetorik Privacy Policy & Information
1. Introduction
Rhetorik Limited, a United Kingdom company (Rhetorik), helps businesses by providing secure, compliant access to global data related to organisations, the enterprise technologies they employ, and people at those organisations.
Rhetorik and our customers operate in multiple jurisdictions worldwide. We lead the way with compliant data across the world and are committed to respecting everyone’s privacy. Our services are compliant-by-design and we meet the requirements of the California Consumer Privacy Act (CCPA), the EU General Data Protection Regulations 2016 (GDPR), and other applicable data protection laws.
Rhetorik monitors developments in relevant legislation to ensure we continue to meet the high expectations of our customers and to ensure the respect of data subjects’ rights.
This privacy notice tells you what to expect from us with regard to your personal information. If you have any questions, contact us at: [email protected]
2. What information we collect
When you are on our website
Our website uses cookies to track your usage, such as which pages you visit and how long you look at them (“visitor data”). This information may include, but is not limited to, IP address, geolocation information, browser type, and a history of the pages you view. Click here for more information about the cookies we use on our website.
If you submit a form, we ask for information including, but not limited to, your email, your name, or what company you work for. All this information is used to provide the information you requested, personalize your experience or send you marketing emails.
If you sign up for a trial or become a customer, we ask for information including, but not limited to, your email, your name, or what company you work for. This information is used to provide the service you have requested, personalize your experience, send you onboarding emails and invoices.
When you contact our commercial team
If you submit a form, we ask for information including, but not limited to, your email, your name, or what company you work for. All this information is used to provide the information you requested, personalize your experience or send you marketing emails.
If you reach out via email or chat, we keep conversations and other data you might send during those exchanges.
When you use our services
If you sign up for a trial or become a customer, we ask for information including, but not limited to, your email, your name, or what company you work for. This information is used to provide the service you have requested, personalize your experience, send you onboarding emails and invoices.
Whether it is through the API, the website, or other services we provide, we monitor your usage and log requests that you make (“user data”). Those logs can include IP address, geolocation information, browser type, etc.
If you reach out for support, whether via email, chat or other means, we keep conversations and other data you might provide during those exchanges.
Rhetorik database – professional profile data
Rhetorik collects personal information about the decision makers, influencers and users of business products and services and similar information related to individuals when they are acting in their professional or employment capacity.
Rhetorik then uses this information to create professional profiles of individuals and of businesses. We provide this information to our clients, who are businesses trying to reach business professionals for their own business-to-business sales, marketing, and recruiting activities.
To this end, we collect typical business card information, as well as information you have made publicly-available through online websites or social media and other professional information about you (Personal Information), which may contain some or all of these categories of personal data: First Name, Last Name, Company, Office Address, Business Phone Numbers (switchboard, direct dial, mobile), Email Addresses, Job Title, Job Function, Education, Skills, current and previous Employment-related information and Social Media URLs.
To ensure a high level of accuracy of our data, Rhetorik targets updates for personal information every six months.
Sources of Personal Information
Rhetorik collects Personal Information from multiple sources, which may include websites, government records and other publicly available sources, third party data providers, telephone-based research interviews, or modelled or inferred from this data.
When we capture public web data
We acquire data from various public sources, which may not be accurate or complete, to combine into our aggregated public data set. We use our own servers and some third-party suppliers to look at publicly available online pages, just as a search engine (such as Google and others) might do, and process business data we identify on them.
We are not responsible or liable for the accuracy of any such publicly available data, or the results of any analysis based on such data.
Public Data Only: Only public pages are looked at and only publicly available online data that can be found by a search engine are indexed by our servers. We do not use login access to collect data, and data collected is always visible to a visitor without login to the site. Data is public if it can be seen in a browser while there is no logged in user.
Professional Data Only: On those public pages, we only look for professional profile information that might be used in one’s business or professional capacity – including name, gender, email addresses used to log into business-related sites, email addresses used to send and receive business-related communications, company name, company address, mobile and landline telephone numbers, job title, job function, social media links, education, skills, employment history, memberships, certifications, patents and other data that are directly related to employment, careers, skills and other professional attributes.
Current Data Only: We make every effort to collect data as frequently as various source sites and technical limits allow to keep our data as current as possible.
Compliance with Source Site Terms: If a website, via a robots.txt file, asks crawlers not to look at the content, we respect this indication. Our robots systematically view the robots.txt file before exploring and indexing the public data available on the website, and we do not circumvent restrictions in robots.txt files. We do not create real or fake user accounts for the purpose of gathering data, and we never automatically generate user accounts. We are not responsible for the privacy policies and practices of other websites.
All Data Sources Optional/Configurable: We allow our customers to choose to “switch off” particular datasets from our public data (e.g., Facebook) as an extra level of control.
Third-Party Suppliers: Where we use third-party suppliers to gather data for us, we require that they adhere to our principles on professional, public, and current data, particularly that all data must be available without logging in to the site concerned. We do not require that our suppliers disclose their trade secrets to us, but we do regularly audit the provided data to ensure that it complies to those three key principles.
Data that we normalise from public data: When we analyse the publicly available data, we find some records contain similar information, but the information is expressed differently in each record.
Normalising is a way of presenting the data in the same way for each record without fundamentally changing the meaning of the data. For example:
Data that we infer or model from available data: When we analyse the available data, we can infer or model information that does not appear explicitly in the public data. For example, we might look at a profile whose job title is given as “java developer” and infer that “java” is a skill that can be associated with that profile.
3. How we use your data – purpose of processing
To provide our services
When creating an account, you agree to our Terms of Service which allows us to process your data to give you access to Rhetorik. This way, you can have an account on our website, access the API, invite other team members, etc.
To improve the User Experience
We look at usage patterns and various statistics to understand what and how to improve Rhetorik services.
To license data to our customers to support their business purposes
Rhetorik processes data so that it may be licenced on a subscription basis to organisations for their sales, marketing, analytical, or recruiting purposes, or to other organisations who may license it to their customers for the same purposes (“partners”). This means that such organisations may use this information to contact data subjects about products or services that are relevant to their professional interests. It is important for our users and the organisations they work for to have access to this data to discover people they want to engage with relevant to their business objectives.
License agreements are in place between Rhetorik and its customers to ensure the use of the information is restricted to specified purposes and to prohibit the unauthorised use or transfer of the information. Customers access the information via password protected account-based access to our database or services. Our customers, or those of our partners, may use the information to market their services to the employers of data subjects or to the data subjects about professional opportunities. In the course of this activity, data may be transferred outside the EU and UK.
We are not liable for the onward transfer to third parties of any data which is publicly available.
The profile data that we collect may be transferred, stored, or processed at a destination outside the country where the data subject resides. It may also be transferred to customers, or processed by third parties, operating outside the territory where Rhetorik is based. Such third parties who work for us or for one of our suppliers maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and/or the provision of support services.
We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and all relevant legislation. We will retain your information for as long as your account is active or as needed to provide our Services to you. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
To offer customer support
We provide customer support via email or chat, to help you take full advantage of our service or fix any problem you encounter. Please use [email protected].
To market new services
Regularly, we launch new services. We’ll let users know about those releases if they have asked us to keep them up to date.
4. Legal grounds for processing personal data
When you are on our website
Our lawful basis for collecting or using personal information when you are on our website is Consent. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn.
When you contact our commercial team
Our lawful basis for collecting or using personal information when you contact our commercial team is Consent. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn.
When you use our services
Our lawful basis for collecting or using personal information when you use our services is Contract. We will use personal data relating to you where necessary for the performance of that contract.
Rhetorik database – professional profile data
Our lawful basis for collecting or using personal information that appears in the Rhetorik database is Legitimate Interest. Rhetorik processes your personal data when it is in our or our clients’ legitimate interest to do so and when these interests are not overridden by your rights. Our and our clients’ legitimate interests include: having information about potential business customers organised in one up-to-date and password-protected database; being able to identify individuals that occupy certain roles within a business or organisation; enabling clients to engage with relevant professional contacts for sales, marketing and recruiting purposes; having access to analytical insights for the purpose of understanding patterns and trends.
In addition, Rhetorik may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
5. Who we share information with
We will share your information with the following:
Rhetorik companies
Access to personal data within Rhetorik and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
Rhetorik customers
We may share personal data with our customers or their customers as part of the provision of our services. Rhetorik provides limited and protected access to its database. Rhetorik customers or their customers may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail or through targeted display ads on social networks in order to market products and/or services and for recruitment purposes.
If your data is included in our database, you may be contacted by our customers for the purpose of their B2B sales, marketing, and recruiting activities. Communications you receive from our clients may be relevant to your profession or role at your organisation, although there is no guarantee that you will find such communications to be relevant or of interest to you.
When they contact you, customers will be acting as data controllers and will have their own privacy policies and opt-out options, which we recommend you review.
Suppliers, subcontractors, service providers
We may disclose your information to suppliers or subcontractors only if they have agreed to safeguard this information and it is reasonably necessary for the purposes set out in this privacy policy.
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Government authorities
We may by law be required to disclose your information (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Potential business partners or investors
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
6. Duration of the processing
Rhetorik Ltd only retains personal information for as long as is necessary for the purpose. 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 requirements.
If you have been a customer of Rhetorik, we will keep information regarding your company for as long as is necessary to comply with our legal obligations.
Where you have consented to us to use your details for direct marketing, we will keep this data until you notify us or otherwise withdraw your consent.
For further details on our data retention periods please contact us at [email protected].
7. Securing your data
We secure your Personal Data using commercially reasonable, industry-standard measures to prevent unauthorized access or disclosure, or accidental loss, disclosure or destruction thereof. However, even very good security measures may fail to prevent computer hacking or other breaches of security, and we can provide no guarantees that the same will not occur.
Additionally, other communications you may have with us via email or regular mail may not be secure unless we advise you that security measures are in place prior to your sending information. Therefore, if you choose to communicate with us through these means, you are assuming the risk of doing so and we request that you do not send or post sensitive information through those means.
8. International data transfers
Where we transfer personal data outside the UK, Switzerland and the European Economic Area (together, the “EEA”) to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses or other appropriate safeguard or we will identify an appropriate exemption.
9. Your data protection rights
Depending on where you are located and/or live, you may exercise certain data privacy rights, and we will facilitate the exercise of those rights.
To submit a data protection rights request, please fill out the form on this page. The information you provide will only be used to fulfil your request.
For data subjects resident in EU, EEA, Switzerland and the UK, please click here to find out more about your rights under the GDPR 2016 and the Data Protection Act 2018.
For data subjects resident in California, please click here to find out more about your additional rights under the California Consumer Privacy Act of 2018 (CCPA).
For data subjects resident in Virginia, please click here to find out more about your additional rights under the Virginia Consumer Data Protection Act (VCDPA).
For data subjects resident elsewhere in the United States of America, please click here to find out more about your rights.
For data subjects resident in Canada, please click here to find out more about your additional rights under the Personal Information Protection & Electronic Documents Act 2000 (PIPEDA).
For data subjects resident in other jurisdictions, please click here to find out more about your additional rights under your local legislation.
European data protection rights
If you are a resident or are otherwise located in the European Union (EU), the European Economic Area (EEA) or the United Kingdom (UK), this section provides additional details about the personal data we collect about you, and your rights granted by the EU and UK General Data Protection Regulations, as applicable (GDPR).
Your Rights
- Right of Access: You have the right to ask us for copies of your personal data.
- Right of Rectification: You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. In addition, we may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
- Right of Erasure: You have the right to ask us to erase your personal data in certain circumstances.
- Right of Restriction of Processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances.
- Right to Object to Processing: You have the right to object to the processing of your personal data in certain circumstances.
- Right to Withdraw Consent: When we use consent as our lawful basis you have the right to withdraw your consent.
- Right to Data Portability: You have the right to ask that we transfer your personal data to another organisation, or to you, in certain circumstances.
- Right to be Informed: You have the right to obtain confirmation as to whether we are processing your Personal Data and, where that is the case, access to that Personal Data and the following information:
a) The purposes of the processing
b) How long the data will be kept
c) The source of that information
d) All other information as mentioned in article 15 of the GDPR
You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.
To make a data protection rights request, please fill out the form on this page or contact us at [email protected].
EU Representative: Rhetorik has appointed IT Governance Europe Limited to act as our EU representative. If you are an EU resident and wish to exercise your rights under the EU General Data Protection Regulation (EU GDPR), or have any queries in relation to your rights or general privacy matters, you can email Rhetorik at [email protected] or email our Representative at [email protected]. Please ensure to include our company name (Rhetorik) in any correspondence you send to our Representative.
How to complain: If you have any concerns about our use of your personal data, you can make a complaint to us at [email protected].
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO using the address below:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
California Privacy Rights
If you are a resident of California, USA, this section provides additional details about the personal information we collect about you, and your rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
Subject to certain limitations, the CCPA and CPRA provide you the following rights:
- Right to Know and Right to Access
- Right to Deletion
- Right to Opt Out
- Right to Correction
- Right Not to be Discriminated Against
If you would like to exercise any of your rights, please click on the link below and complete the form.
Virginia Privacy Rights
If you are a resident of Virginia, USA, this section provides additional details about the personal information we collect about you, and your rights under the Virginia Consumer Data Protection Act (VCDPA).
Subject to certain limitations, the VCDPA provide you the following rights:
- To confirm whether we are processing your personal information, and to access that personal information;
- To receive your personal information in a portable and readily usable format;
- To correct inaccuracies in your personal information;
- To delete your personal information;
- To opt out of the processing of your personal information for targeted advertising, sale to third parties, or profiling where there is a legal or similarly significant effect on you.
Fill out the form on this page to submit your rights request. The information you provide will only be used to fulfil your request.
Other USA Privacy Rights
New data privacy legislation has been enacted or is currently in progress in a number of States and we will ensure compliance with such legislation. In the meantime, if you are a resident of any State of the USA, we will as a minimum extend to you similar rights as are provided for residents of California and Virginia. That is:
- Right to Know and Right to Access
- Right to Deletion
- Right to Opt Out
- Right to Correction
- Right Not to be Discriminated Against
Fill out the form on this page to submit your rights request. The information you provide will only be used to fulfil your request.
Canada Privacy Rights
If you are a resident of Canada, this section provides additional details about the personal information we collect about you, and your rights under the Personal Information Protection & Electronic Documents Act 2000 (PIPEDA).
Subject to certain limitations, the PIPEDA provides you the following rights. That is:
- Right to Access – You can request to access your personal information we hold about you.
- Right to Correction – You can request us to correct your information.
- Right to Deletion – You can request us to delete your information.
- Right to Opt Out
- Right to be Forgotten – Your information will be kept with us for as long as it is required for the fulfillment of the purposes for which we process your personal information.
- Data Breach Notification – We will send a notification to you as soon as feasible regarding any breach that creates a “real risk of significant harm” to you
Canadian Privacy Officer
Canadian Privacy Officer. We have appointed a Canadian Privacy and Data Protection Officer, Katie Allen, [email protected], to make sure the privacy rights of our Canadian users are protected in compliance with PIPEDA.
Other Jurisdictions’ Privacy Rights
For residents of other countries, please click on the relevant link below:
10. Children
We do not knowingly collect or use any personal data relating to children.
11. Links to Other Web Sites
Our services may contain links to other websites not controlled or operated by Rhetorik Ltd. These links do not imply that we endorse these third-party sites. We recommend reviewing those sites directly for information on their privacy policies.
12. Updates & contact
We reserve the right to change or remove this Privacy Policy at our discretion and will post any new Privacy Policy here and encourage you to visit this area frequently to stay informed. You will be responsible for reviewing and becoming familiar with any such modifications.
Your use of the Site and/or the Service following such modifications constitutes your acceptance of the terms and conditions of this Privacy Policy as modified.
Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your account.
Privacy Commitment Changes
We reserve the right to change or remove this Privacy Policy at our discretion and will post any new Privacy Policy here and encourage you to visit this area frequently to stay informed.
Contacting the Web Site
If you have any questions about this privacy statement, or the security practices of the Site, you can contact: Contact Us
Or telephone or write to us at:
Tel: +44(0)118 989 8580
Address: Indigo House, Fishponds Road, Wokingham, Berkshire, RG41 2GY. Registered no. 2958622