Privacy Policy and Customer Terms
Effective date: 6th October 2025
1. Parties and Scope
1.1 This Privacy Policy and Customer Terms (“Policy”) is issued by Right Pace Tech Media operating as RPTech Media (“RPTech Media”, “we”, “us”, or “our”). We provide technology-enabled business-to-business marketing solutions, including audience profiling, multi-channel campaigns, and the sale and delivery of contact and lead data (“Services”).
1.2 This Policy applies to: (a) visitors to our websites and portals that link to this Policy; (b) individuals acting for, or on behalf of, our business customers, suppliers, and partners; and (c) persons whose details appear in or are used to generate our B2B marketing outputs. It governs how we collect, use, disclose, transfer, secure, and retain Personal Information and sets out the terms governing orders placed through our website, including cancellation, refunds, and digital delivery.
1.3 For the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018 (together, the “UK GDPR”), RPTech Media acts as controller in respect of customer, prospect and site-visitor data we determine the purposes and means of processing for. We may also act as processor when we handle data strictly on our client’s documented instructions. Where roles differ by processing activity, we identify them below.
2. Definitions
2.1 “Personal Information” means information relating to an identified or identifiable natural person, including business contact details when such details identify a person.
2.2 “Process/Processing” includes any operation performed on Personal Information, such as collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure, or destruction.
2.3 “Customer” means the business on whose behalf an order is placed; “Authorised User” means the individual acting for that Customer.
2.4 Capitalised terms used but not defined shall have the meanings given by applicable data protection law.
3. Lawful Bases and Purposes of Processing
3.1 We process Personal Information only where we have a lawful basis. Depending on context, the lawful bases are: performance of a contract (including steps taken at your request prior to entering into a contract); legitimate interests pursued by us or a third party (such as securing our systems, preventing fraud, tailoring B2B communications, and improving Services), legal obligation, and consent where required for specific marketing communications.
3.2 We process Personal Information to: verify identity and eligibility to purchase; accept and fulfil orders; configure and deploy campaigns; generate, validate and deliver lead files; provide portals, dashboards and reports; bill and collect payments; provide service notices and support; monitor, audit and improve our Services; perform analytics and measurement; enforce our rights; comply with record-keeping, financial and regulatory duties; and protect against fraud, misuse or unlawful activity.
3.3 Where we act as processor on behalf of a Customer, we process Personal Information strictly in accordance with the Customer’s documented instructions and our data processing addendum (if agreed), and in such cases the Customer is responsible for providing all required notices to, and obtaining all required permissions from, relevant data subjects.
4. Categories of Personal Information
4.1 We may process the following categories: identity and contact data (name, role, employer, business email, business phone, work address); account credentials and preferences; payment-related identifiers (transaction IDs and masked references; we do not store full card numbers or CVV codes); usage, log and device data (IP address, user agent, timestamps, pages viewed); campaign configuration and performance data; communications, help-desk records, and consent records.
4.2 In limited circumstances, we may incidentally process special category data (for example, accessibility needs for an in-person event). We will only do so where strictly necessary, lawful and, where required, with your explicit consent. We do not intentionally collect data relating to children and our Services are directed to business users aged 18+.
5. Sources of Personal Information
5.1 Personal Information is obtained: directly from you when you browse our sites, create an account, place an order, correspond with us or participate in a campaign; from our Customers and partners who lawfully provide data for campaign execution; from publicly available business sources and reputable data providers; and automatically via cookies, pixels and similar technologies operating on our sites and emails.
5.2 Where third parties provide Personal Information to us, they are required to confirm they have a lawful basis to do so and to provide any required notices to data subjects.
6. Cookies and Similar Technologies
6.1 We use strictly necessary cookies to operate our sites and authenticated areas; functional and analytical cookies to understand usage and improve performance; and, where permitted, marketing pixels to measure campaign reach. Browser settings permit you to refuse some cookies; however, blocking strictly necessary cookies may impair site functionality. A detailed cookie schedule is available in our Cookie Notice referenced on the site.
7. Disclosures and International Transfers
7.1 We disclose Personal Information to: payment service providers and banks for transaction processing; cloud hosting, email, analytics, and security vendors; campaign execution partners (including but not limited to email, tele, and enrichment providers); professional advisers; prospective buyers or merger counterparties; and competent authorities where lawfully required. We do not sell Personal Information.
7.2 Given the global nature of our operations, Personal Information may be transferred to, and processed in, jurisdictions whose laws may not be equivalent to those in your home country. Where required, we implement appropriate safeguards, including UK GDPR-approved Standard Contractual Clauses, to ensure an adequate level of protection. Copies of relevant safeguards may be requested using the contact details in Clause 18.
8. Security
8.1 We maintain administrative, technical and physical measures designed to protect Personal Information against unlawful or unauthorised access, disclosure, alteration or destruction, including access controls, encryption in transit, network segmentation, logging and monitoring, secure development practices, staff confidentiality undertakings and periodic testing.
8.2 No method of transmission over the Internet or method of electronic storage is entirely secure. While we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee absolute security.
9. Retention
9.1 Personal Information is retained for the longer of: (a) the period necessary to fulfil the purposes described in this Policy; (b) any period required by applicable law, audit or regulatory guidance; and (c) the limitation period during which claims may be made, plus a reasonable administrative buffer.
9.2 On expiry of the applicable retention period, Personal Information is securely deleted or irreversibly anonymised.
10. Your Rights
10.1 Subject to applicable law, individuals may have the right to request access to, rectification or erasure of Personal Information, to restrict or object to processing, and to portability of data provided to us. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
10.2 Requests should be addressed using the contact details in Clause 18. We may need to verify your identity and authority before acting. We will respond within the time limits prescribed by law.
10.3 Residents of the UK may lodge complaints with the Information Commissioner’s Office (ICO). We invite you to contact us first so we may seek to resolve any concern promptly.
11. Marketing Communications
11.1 We send B2B marketing communications about our Services where permitted by law. You may opt out at any time by using the unsubscribe facility in the message or by contacting us. Where consent is required, we will obtain it in advance and record your preference.
12. Special Notice on Payment Processing (Razorpay)
12.1 Payments made through our website are processed by third-party payment service providers, which may include Razorpay. Card details are submitted directly to the payment processor over an encrypted connection; RPTech Media does not store full card numbers, security codes or magnetic-stripe data.
12.2 The processor acts as independent controller of certain Personal Information necessary to process the transaction, perform fraud screening and comply with legal obligations. Your use of the payment form is also subject to the processor’s own privacy notice and terms, which we encourage you to review.
13. Terms Governing Orders, Cancellations, Refunds and Delivery
13.1 Formation of Contract. When an Authorised User places an order through our website and payment is confirmed, a binding contract arises between RPTech Media and the Customer for the supply of the Services specified at checkout, subject to this Policy and any statement of work or order confirmation we issue.
13.2 Service Nature; No Right to Cancel. Our Services consist of work that begins promptly on order (including allocation of internal resources, dataset reservation, validation and campaign set-up). Accordingly, once an order is placed, cancellations are not permitted.
13.3 Refunds. Because Services are initiated and value begins to be created immediately upon order, refunds are not available by default. Any exception may only be granted in writing by RPTech Media at its sole discretion and without prejudice, for example where an objective technical failure on our systems prevents delivery and cannot reasonably be remedied.
13.4 Delivery/“Shipping”. We do not ship physical goods. Deliverables, such as lead files, campaign outputs and reports, are delivered electronically to the designated email address(es) or via secure portals or file-transfer links. Delivery timelines depend on the scope purchased and will be communicated during onboarding or in the order confirmation.
13.5 Customer Dependencies. The Customer is responsible for providing correct specifications, lawful instructions and authorised recipient details. RPTech Media is not responsible for delay or non-performance caused by inaccurate inputs, failed recipient systems, or the Customer’s breach of applicable law (including marketing, e-privacy and anti-spam rules).
13.6 Use of Deliverables. Unless expressly stated otherwise, deliverables are licensed to the Customer for internal business use only and may not be resold, sublicensed or combined with third-party datasets for onward sale. The Customer is responsible for ensuring its use complies with all applicable laws and self-regulatory codes.
13.7 Governing Law and Venue. These order terms, and any non-contractual obligations arising out of or in connection with them, are governed by the laws of England and Wales. The courts of England shall have exclusive jurisdiction, without prejudice to any mandatory rights of consumers (which do not apply here as our Services are B2B).
14. Children
14.1 Our websites and Services are not directed to persons under 18. We do not knowingly collect Personal Information from children. If we learn that a child has provided Personal Information, we will delete it promptly.
15. Processor/Controller Role Clarifications
15.1 Controller Activities. We are controller when we: operate our websites; manage customer accounts; decide what prospect segments to build into our proprietary datasets; measure and improve platform performance; and market our own Services.
15.2 Processor Activities. We are processor when a Customer supplies data or documented instructions for execution of that Customer’s campaigns. In those cases, our obligations are as set out in the applicable services agreement and any data processing addendum. Customers, as controllers, are responsible for their own transparency notices and for ensuring a lawful basis for their instructions.
16. Automated Decision-Making
16.1 We do not make decisions producing legal or similarly significant effects solely by automated means. We may use scoring, validation and deduplication tools to improve data quality and campaign performance; such tools are reviewed by our personnel before material actions are taken.
17. Changes to this Policy
17.1 We may amend this Policy from time to time to reflect operational, legal or regulatory developments. The “Effective date” will be updated on publication. Where changes are material, we will take reasonable steps to notify Customers or obtain consent where required by law.
18. Contact Details; Requests and Complaints
18.1 All enquiries, requests to exercise rights, complaints, and notices should be directed to:
Right Pace Tech Media
2 Frederick Street, Kings Cross, London, WC1X 0ND
Email:
info@rptechmedia.com
Tel:
+44 020 3129 7779
18.2 For UK residents, the supervisory authority is the Information Commissioner’s Office (ICO) (ico.org.uk). We would welcome the opportunity to address your concerns before you approach the ICO.
19. Third-Party Sites and Social Features
19.1 Our websites may contain links to third-party sites or enable interactions with social media platforms. Those sites and platforms are governed by their own privacy notices and terms; RPTech Media is not responsible for their practices.
20. Do-Not-Track
20.1 At present, our websites do not respond to browser “Do-Not-Track” signals. You may manage cookie preferences through your browser or our cookie controls.