1. About us and this privacy policy

Realworld Systems is made up of member firms (each a “member”) operating around the world. Our members are separately constituted and regulated software development and software consulting firms that provide software products and services in accordance with the relevant laws of the jurisdictions in which they respectively operate. Our website (www.reaworld-systems.com) (“our Website”) is operated by Realworld Holding BV (“we”, “our” or “us”) on behalf of our members. Each of our members comes across and collects various personal information (also referred to as personal data) about individuals in the course of their business activities, for example information about business contacts, individuals working for, or investing in, clients, and other individuals connected with the transactions in which our members are involved, or who interact with our members in the course of their business. Each of our members is a separate data controller in respect of any such personal information and is separately responsible for holding and using such personal information, in accordance with the relevant data protection laws applicable to such member. As such, the privacy practices of our members may vary among the countries in which they operate. This privacy policy gives you an overview of what information our members may collect and for what purposes. In respect of personal data held by our members, where there is any conflict between this privacy policy and the privacy policies of our members, the policies of our members will prevail. Please contact the relevant members for more details about how they collect and process personal information, and about the rights you may have in respect of your personal data under the relevant local laws. We are not responsible for, and disclaim all liability in respect of, compliance by our members with any applicable data protection laws. Our Website collects certain limited information about visitors to our Website, or those that interact with us through our Website, for example by contacting us or booking an event. If you are one of such individuals, this privacy notice will inform you as to how we look after your personal data and will tell you about your privacy rights and how the law protects you. Realworld Holding BV is a data controller in respect of any personal data collected via our Website. This privacy policy also applies to those who apply to work with Realworld Holding BV, whether as an employee, worker or contractor, but it does not apply to any individuals working for our members. This privacy policy has been written in accordance with the data protection legislation applicable in the European Union, namely the General Data Protection Regulation (GDPR).

2. What information do we and/or our members collect and for what purposes?

If you are a visitor to our Website, we may collect certain technical information about your visit, such as your internet protocol (IP) address, 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 the Website. We collect such data for administrative and statistical purposes and to help us operate and improve our Website. If you make an enquiry by email or telephone, we or the relevant member (if you make an enquiry directly with a member) will collect your name and contact information, which will be used to respond to your enquiry. We or our members (as applicable) may also keep records of such communications and/or add your contact details to our business database, if we (or the relevant member) believe that we may have a good reason to contact you in the future. If you register (or are invited by a member) to attend an event organised by us, we will use your name, contact details and the name of the organisation you work in connection with organising the event. We will store such information in our database and our members will be able to access it. If you are applying to work with Realworld Holding BV, for example as a contractor or consultant, we will collect, store and use the information you provide to us in your application and any information you provide to us during your interview to assess your suitability for the role, to communicate with you about the engagement process, to make a decision as to whether to enter into a contract with you and to keep records of our hiring process. We may also carry out background and reference checks, if applicable. Similarly, if you are an individual working for a client or business contact of our member, the relevant member will keep your contact details and the name of the organisation you work for, and any other information about you that our members may come across in the course of their business. This information will be used by such member in order to manage and maintain their relationship with you and/or the organisation you work for, provide their services, comply with such member’s regulatory and reporting obligations, liaise with you and other parties involved in a transaction, and generally to manage their business, including for accounting and audit purposes. Our members may share certain information relating to their clients with other members, if it is necessary in the context of a transaction or in connection with a business opportunity. As regulated professional services firms, our members may be required to conduct “know your customer” and anti-money laundering checks. As a result of such checks our members may collect detailed information about certain senior individuals involved in the businesses concerned. Some of this information may be collected directly from the individuals and/or organisations involved, whilst some of it may be collected from publically available sources and/or credit reference or ID checking agencies. Our members will also come across and process various documents that contain personal data in the course of the provision of their services. Our members may share this information with other members who may be involved in the same transaction, but they will not share it with us.

3. Lawful basis of processing of your personal information

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

• perform our contractual obligations towards you and/or the business you work for;
• comply with our legal and regulatory obligations;
• pursue our legitimate interests (e.g. conducting our business in an efficient, compliant and profitable manner), and your interests and fundamental rights do not override these interests. It may also become necessary to process your personal data for legitimate interests of a third party, for example, another member firm, or other financial adviser involved in the same transaction.

Please refer to our members’ privacy notices/policies for information about the lawful grounds on which our members rely to process personal data.

4. Marketing

We and/or our members may use your contact details to send you news about Realworld Systems’ services or events. Your contact details will only be used for such direct marketing purposes when the law allows us and/or our members to, for example, if you have specifically requested to receive such information. You can always opt-out from receiving further communications by clicking the unsubscribe link at the bottom of the relevant email. We will not pass your contact details to any third party for direct marketing purposes.

5. Will we disclose your personal information to anyone?

We and/or our members may share your personal information with third parties such as agents and service providers (for example our IT systems suppliers and maintenance services providers). Our members may share your personal information with:

• other members (mainly in the context of the same transaction or business opportunity);
• credit reference agents;
• regulatory authorities;
• law enforcement agencies in connection with any investigation to help prevent unlawful activity; and/or
• in the context of the possible sale or restructuring of our members’ business.

All our third-party service providers are required to take appropriate security measures to protect your personal information.

6. Keeping your data secure

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those of our personnel and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see ‘How can you contact us?’ below). We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

7. Transfers of your information out of the EEA

We store our databases on servers provided by a third party supplier, and such servers are currently located in the United Kingdom. Our members make their own data storage and hosting arrangements in relation to any data held and/or processed by them. We and/or our members may need to transfer your personal data outside the European Economic Area (EEA), for example, if one of our suppliers or members is located outside the EEA. Any transfer of your data will be subject to appropriate safeguards, such as for example a European Commission approved contract (if appropriate) that will ensure you have appropriate remedies in the unlikely event of a security breach.

8. Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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. As our members operate in different jurisdictions, they may be subject to different requirements as to the retention of records. Please refer to the relevant member’s privacy policy or contact any such member directly to obtain further details about data retention periods. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you.

9. Rights and duties

Your rights in connection with personal information

Under certain circumstances, by law you may have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to the processing of your personal information 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.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
• Request the transfer of your personal information to another party.

If you would like to exercise any of the above rights, please:

• email, call or write to us (see paragraph 10 below);
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
• let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services in relation to your requirements.

10. Contact us or the relevant supervisory authority

Please contact us if you have any questions about this privacy policy or the information we hold about you. If you wish to contact us, please send an email to privacy@realworld-systems.com. If you wish to contact any specific member of Realworld Systems please refer to the relevant site on our Website for their contact details. If you are based in the EU or other EEA countries, you have the right to make a complaint at any time to the relevant local supervisory authority, in particular in the Member State of your residence or place of work. Please contact us if you wish to receive the details of the relevant supervisory authority.

11. Changes to the privacy policy

We may change this privacy policy from time to time. Please refer to this Website for the most recent copy of this privacy policy.