21. These terms
We are committed to protecting and respecting your privacy.
This policy (together with our Terms of Supply, Website Terms and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 2018 (the Act) the data controller is Reincubate Limited of Unit 5, St Saviour's Wharf, 23 Mill Street, London, SE1 2BE.
For the purpose of the General Data Protection Regulations (GDPR) Reincubate Limited of Unit 5, St Saviour's Wharf, 23 Mill Street, London, SE1 2BE, is both a data controller and a data processor.
22. Information we may collect from you
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, search for a product, place an order on our website, and when you report a problem with our website or with any of our products. The information you give us may include your name, address, email address and phone number, financial and credit card information and personal description, as well as any technical information or data you explicitly choose to provide to us in order to assist us with diagnosing a problem with our software.
Information we collect about you. With regard to each of your visits to our website or the use of any of our software we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- information transmitted through our servers by virtue of your use of our products or services. This may include device and account metadata. Your use of our services may also require us to temporarily process additional data such as device backups and other user data; such data is only held for as little time as is necessary in order to provide the service and we take all reasonable measures to minimise the storage of any such data.
Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
23. Uses made of the information
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, software and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means only if you have consented to this;
- to notify you about changes to our software;
- to ensure that content from our website is presented in the most effective manner for you and for your computer;
- to help diagnose and resolve any issues or technical problems you have reported to us;
- for analysis or testing purposes: such data will be anonymised and deleted when no longer necessary.
- Information we collect about you. We will use this information:
- to administer our websites and software and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our websites and software to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our websites and software safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our websites and software about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We may use advertising networks to show you relevant adverts based on what parts of our websites you have visited or what software you have downloaded or purchased from us. This may mean you see our adverts when you visit other websites. This is done using a process called "remarketing" or "interest based advertising".
You can opt out of such advertising by visiting the NAI opt-out page at optout.networkadvertising.org.
24. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 where we have a lawful basis to do so under GDPR.
We may share your information with selected third parties including:
- Business partners, suppliers and subcontractors for the performance of any contract we enter into with you (the "performance of a contract" lawful basis).
- Analytics and search engine providers that assist us in the improvement and optimisation of our website (the "legitimate interest" lawful basis).
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Reincubate Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
For the purpose of the California Consumer Privacy Act (CCPA) we will never "sell" your personal information unless it is for operational purposes as described in clause 24.3 above.
25. Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted and only transmitted over secure (TLS) connections. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access. Such measures include removing data where it is no longer relevant or necessary, anonymising technical data and encouraging the use of mechanisms such as two-factor authentication.
26. Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at email@example.com.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
27. Access to information
Both GDPR and the Act give you the right to access information held about you. Your right of access can be exercised in accordance with GDPR or with the Act. Any access request under the Act may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. Any access request under GDPR will not incur a charge.
Although we do not fall under the California Consumer Privacy Act (CCPA), if you are an individual living in California and wish to exercise your rights under CCPA then we will do our best to voluntarily comply with the provisions of CCPA. Please contact us at firstname.lastname@example.org.
30. General Data Protection Regulations (GDPR)
Through our iCloud API we enable our customers to access data from individual iCloud accounts. This data is clearly covered by GDPR as in many cases this will be personal data, as it can be tied to a living individual. In such cases Reincubate is a data processor as we are simply facilitating access to the appropriate data, which is being passed to our customer via our API or our software.
As a data processor we do still have obligations to ensure that any processing we do is lawful and reasonable. We fulfil this requirement in a number of ways:
- We will only process data where we are comfortable there is a lawful basis to do so under GDPR. In our case the lawful basis is that the processing is necessary in order to provide the service requested by our customer
- We do not retain any data in our systems; we are simply a conduit passing data to our customer
- We will comply with any request from a data subject to stop processing their data
31. The responsibilities of our customers under GDPR
Where our clients use our API or software to access data from iCloud accounts they are likely to be a "data controller" under GDPR. As such our clients have a number of responsibilities.
- Customers must ensure they have a lawful basis to access the data which they are requesting through the Reincubate iCloud API, where the data does not already belong to the customer. For our enterprise customers we can assist in determining the most appropriate lawful basis on request
- Where customers are accessing data that is not their own they must ensure they have a process to respond to any requests from data subjects for a copy of the data that is held on them, or to delete any such data on request. Where such a request has been made to a customer they must tell Reincubate so we can cease any data processing on the customer's behalf
- Customers must comply with any other GDPR requirements. This may include appointing a "Data Protection Officer" if the customer's core business involves the large scale processing of data
Responsible Disclosure Policy
32. Responsible Disclosure
At Reincubate, we consider the security of our systems a top priority. But no matter how much effort we put into system security, there can still be vulnerabilities present.
If you discover a vulnerability, we would like to know about it so we can take steps to address it as quickly as possible. We would like to ask you to help us better protect our clients and our systems.
Please do the following:
- Do not take advantage of the vulnerability or problem you have discovered, for example by downloading more data than necessary to demonstrate the vulnerability or deleting or modifying data,
- Do not reveal the problem to others until it has been resolved,
- Do not use attacks on physical security, social engineering, distributed denial of service, spam or applications of third parties, and
- Do provide sufficient information to reproduce the problem, so we will be able to resolve it as quickly as possible. Usually, the IP address or the URL of the affected system and a description of the vulnerability will be sufficient, but complex vulnerabilities may require further explanation.
- E-mail your findings to email@example.com.
What we promise:
- We will respond to your report within 3 business days with our evaluation of the report and an expected resolution date,
- If you have followed the instructions above, we will not take any legal action against you in regard to the report,
- We will handle your report with strict confidentiality, and not pass on your personal details to third parties without your permission,
- We will keep you informed of the progress towards resolving the problem,
- In the public information concerning the problem reported, we will give your name as the discoverer of the problem (unless you desire otherwise), and
- We strive to resolve all problems as quickly as possible, and we would like to play an active role in the ultimate publication on the problem after it is resolved.
As a token of our gratitude for your assistance, we offer a reward for every report of a security problem that was not yet known to us. The amount of the reward will be determined based on the severity of the issue and the quality of the report. The minimum reward will be a $50 gift certificate.
We ask that submissions contain the following in order to help expedite the process:
- A clear description of the issue, including a possible attack scenario.
- Reproduction steps that demonstrate a positive test case showing the presence of the vulnerability.
- Recommended fixes, mitigations or workarounds for the reported issues.
The following potential issues are not considered in scope:
- Lack of rate limiting on any resources
- Password policy issues, including lack of upper limit on passwords
- HTTP 404 or other error codes and pages
- Banner or version disclosure of any kind
- Presence of common public files, such as robots.txt
- CSRF on anonymous resources, or any CSRF issue which does not include an exploit showing control over sensitive actions
- Clickjacking issues, unless an exploit showing account takeover or disclosure of sensitive resources is provided
- Self-XSS issues
- SPF/DKIM/DMARC configuration issues
- SSL issues mitigated by Cloudflare
- Issues which are not practically exploitable or are already mitigated