Website Privacy Policy

www.rapport-app.com 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 aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to a trial or purchase a service.

1. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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).

Performance of Contract means 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

2. External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Payment processing: we currently invoice customers directly and accept payment by bank transfer. Where we introduce third-party payment processing in future, we will update this policy and notify affected customers accordingly.
• The following technology and service providers: Supabase (database hosting, UK-based), Vercel (application deployment, UK-based), Resend (email services, Ireland-based), Deno (edge functions), OpenAI (voice transcription via Whisper API), Anthropic (AI inference and analysis), Perplexity (AI inference and services), Google and Microsoft (for OAuth integration with Gmail, Google Calendar, Outlook, and Microsoft 365 Calendar). We also use tools to analyse how users interact with our site and services for the purpose of providing the best service and performance improvements to all our subscribers. We enrich contact data from public sources using our proprietary technology. We do not sell or provide personal data to third parties for their marketing purposes.
• We will notify business customers of any material changes to the sub-processors listed above where those changes affect the processing of their Customer Data, in accordance with our contractual commitments.

3. Our Identity

Depending on the context, Rappor Ltd (trading as Rapport-app.com) (collectively referred to as "we", "us" or "our" in this privacy policy) may act in different capacities with respect to personal data:

1. As a data controller — where we collect and process personal data through this website, or in connection with our own marketing and prospect activity. In these cases we determine the purposes and means of processing and this policy applies in full.
2. As a data processor — where we process personal data within a customer's workspace under a subscription agreement, including where we enrich contact records on a customer's behalf as part of our Services. In those cases the customer is the data controller, they determine who is added to their workspace, and they are responsible for their own compliance obligations to those individuals. Our processing in that capacity is governed by the terms of the applicable subscription agreement.

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager:

Rappor Ltd (trading as Rapport-app.com)
Email: info@rapport-app.com

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.

4. Changes to the Privacy Policy

We keep our privacy policy under regular review. 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.

5. 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.

6. The Data We Collect About You

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, title.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and 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, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 this data will not directly or indirectly reveal your identity.

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.

7. 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. 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.

8. How Is Your Personal Data Collected

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.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.

9. How We Use Your Personal Data

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.
• Contact enrichment within customer workspaces — as part of our Services, we enrich contact records within customer workspaces using our proprietary research and processing pipeline, drawing on publicly available sources.

Generally, we do not rely on consent as a legal basis for processing your personal data as we do not sell data to third parties for any marketing activities.

10. Promotional Offers from Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

11. Cookies

Our website uses cookies and similar tracking technologies to distinguish you from other users and to improve your experience. We use the following categories of cookies:

1. Strictly necessary cookies — required for the website to function and cannot be switched off.
2. Analytical/performance cookies — allow us to recognise and count visitors and see how they move around the site.
3. Functional cookies — used to recognise you when you return to the website and personalise content.

You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.

12. Disclosures of Your Personal Data

We will ensure that your personal information is not disclosed to unauthorised third parties. We will not sell, rent or trade your personal data. Data protection legislation does however permit certain disclosures without consent when the information is requested for purposes such as safeguarding national security, prevention or detection of crime, assessment or collection of tax duty, or to protect the vital interests of the individual.

13. International Transfers

Our primary infrastructure is currently hosted in the UK (Supabase, Vercel) and Ireland (Resend). Some of our AI service providers (OpenAI, Anthropic, Perplexity) may process data outside the UK/EEA. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are in place.

14. Data Security

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. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

15. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes. Where we hold personal data about individuals who have expressed an interest but have not become customers, we will retain that data for two (2) years from the date of last meaningful engagement.

When a customer cancels their subscription and their workspace is deleted, we fully delete all personal notes and interaction details associated with that workspace. Voice recordings submitted through our voice note feature are transcribed to text using third-party AI services and are not stored in audio format.

16. Your Legal Rights

You have the right to:

• Request access to your personal data.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

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.

We try to respond to all legitimate requests within one month.