V1.7 Last Updated: 14th December 2022
Data Protection General Statement:
BLOKK is an app and service provided by Revoke Limited.
This Data Protection Policy outlines BLOKK’s commitment to its customers, and other individuals to operate its business activities in a manner that meets the compliance obligations of the Data Protection (Jersey) 2018 Law (“DPJL”), the Data Protection (Bailiwick of Guernsey) Law 2017, Data Protection Act 2018, (UK) and the General Data Protection Regulation (EU) 2016/679.
BLOKK understands and respects your right to privacy, and we are committed to ensuring the confidentiality and security of your personal data and the personal data processing activities within our organisation by applying the appropriate technical and organisational measures required to achieve this objective.
This document covers the policies and procedures for processing personal data in a compliant manner and outlines the rights of the data subjects in respect of that data. The Privacy Notice below explains how we may use, process, and store your personal data.
Revoke Limited is the data controller of all personal data and data processing activities of its apps and websites. The company runs the BLOKK app and associated services. It also operates the www.revoke.com and www.blokkapp.com websites. The company’s head office and Registered Office is located at 2nd Floor, Conway House, 7-9 Conway Street, St Helier, Jersey, JE2 3NT.
Revoke Limited is registered as a data controller with the Jersey Office of the Information Commissioner and its number is 61116.
Special notice regarding children:
Our Services are not directed at people under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with Personal Data without the proper consent, please contact us at firstname.lastname@example.org and we will take steps to remove such information and terminate the account as necessary.
Scope of application:
This policy applies to our business activities and the personal data processing of the data subjects within the European Economic Area (EEA), UK, Jersey, and Guernsey in the Channel Islands.
Personal data means any information relating to an identified or identifiable natural person. Revoke collects the following categories of personal information:
Note that Revoke does not collect personally identifiable information such as first name, last name, email address and is unable to link any data collected to an individual.
Purposes of data processing:
BLOKK uses the personal data noted above for the following range of activities:
|Purpose||Lawful bases for processing|
|To send you notifications through the BLOKK app, to keep you updated on the responses we have received in relation to the services you have requested from us||Processing is undertaken in the performance of a Contract i.e., the app services|
|To manage the operation of your free subscription||Processing is undertaken in the performance of a Contract i.e., the app services.|
|To advertise and market our BLOKK app services and features, and keep you updated on any new or existing customer services which may be available to you||Legitimate interest basis for BLOKK to promote its business products and services. You have the right to object to such processing by contacting our data protection manager.|
|Managing security and access controls to the BLOKK app, Revoke’s computer systems, computer platforms, and website||Legitimate interest basis for BLOKK to protect its business app, computer systems, platforms and website and vendor related applications. You have the right to object to such processing by contacting our data protection manager.|
|Establishment and exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.||Legitimate interest basis for BLOKK to protect and assert its legal rights and the legal rights of others.
You have the right to object to such processing by contacting our data protection manager.
|Obtaining or maintaining insurance cover, managing risks, or obtaining professional advice.||Legitimate interest basis for BLOKK to protect and assert its legal rights and the legal rights of others.
You have the right to object to such processing by contacting our data protection manager.
|Comply with legal, tax and regulatory obligations.||In the performance of a task carried out in compliance with a Legal obligation.|
Services provided to our customers:
We have designed our app services to comply with the requirements of data protection legislation in the areas of Privacy by Design and Default.
The BLOKK app blocks access to tracking sites and services a bit like a firewall; we call it a shield. All blocked events are recorded and manageable by you. We help you to keep safer online by increasing your privacy and security and giving you the power to manage what websites and apps you trust.
How it works:
BLOKK is an app that uses elements of VPN technology on your phone to prevent data from being leaked to tracking companies. Phishing sites are also blocked, preventing you from accidentally sharing data with malicious 3rd parties.
The app creates a list of suspicious activity and blocked events and enables you to set a level of protection that best suits you.
BLOKK works on your device only; unlike a traditional VPN, we are unable to see any of your other activity.
You are always in control when using our app, as you need to turn BLOKK on to engage the privacy and security services that are available to you. You can turn off BLOKK at any time, but please be aware that our privacy and security services will not be available to you when Blokk is turned off.
Key points to note about this app:
Direct Marketing Activities:
BLOKK may use a number of marketing activities to help promote its business services and the various features within the range of privacy and security app services on offer to customers.
Before a customer receives any direct marketing information, they will be asked if they would like to “opt-in” to receiving such information. The customer will be free to “opt-out” at any time.
Data collection methods:
We collect personal data in the following ways:
Customer personal data will only be used by us where you are using our BLOKK app and associated services.
The personal data collected is used to:
Only personal data that is necessary for the purposes of assisting our customers with the provision of products or services as outlined above are actively collected.
Recipients of data:
Personal data collected may be disclosed or transferred to;
Third-party service providers are bound by the requirements of the Data Processor Agreement obligations, where your personal data is to be processed to high standards of confidentially and with the required security standards and arrangements to be in place.
Social media platforms:
When we use social media platforms e.g., Facebook, Twitter, Instagram, we only operate it so as to promote our own business and we would not knowingly engage in activities that go beyond this scope. Customers (and other data subjects) are advised to refer to the respective privacy notices of these social media platforms to check their data protection and privacy rights. BLOKK cannot be held responsible for third-party social media platforms or website activities.
Storage of data:
Your preferred whitelisted domain name addresses, and other user app information is stored on your mobile phone app, so if you lose your mobile phone, this data and account is also lost.
The category of data that is stored on our servers relates to the database of the various types of ad tracking software, tracking bots and other software technologies that are used by companies to track you.
The normal app activity log files are kept on our servers for audit and security purposes. These are kept for as long as the app services are provided to app users.
Customer data is stored in the European Union in either the Netherlands or in Ireland.
Transfer and access to personal data:
BLOKK will only transfer data outside of the EEA, UK, Jersey, and Guernsey where it is necessary for the performance of the contract agreed by you.
Where the destination of the data transfer is outside the EEA, UK, Jersey, and Guernsey and does not include a third country that has an “adequacy equivalence” status, as recognised by the EU Commission, we would always ensure that appropriate safeguards are in place.
BLOKK engages the services of those vendors who are operating under the respective data protection compliant agreements and where they are using Standard Contractual Clauses or other approved data transfer mechanisms, where appropriate.
Where we cannot guarantee these safeguards, we would always request your consent before the data is transferred.
Any transfer of data is done in a secure way and in compliance with Data Protection Laws.
Retention of data:
BLOKK will only retain your personal data for as long as is necessary to fulfil the purpose for which it was collected.
Summary of the important data retention periods are as follows:
This is subject to the exception where the data cannot be deleted for legal or regulatory reasons.
Data subject rights:
Where a data subject in the European Union (or any “adequate/equivalent” status country) wishes to exercise their rights under applicable data protection laws, they should contact Revoke’s data protection manager at email@example.com.
Data subjects have a number of rights available to them:
You can assert this right by accessing your personal Account by contacting us directly via our website www.revoke.com or email firstname.lastname@example.org. We would request that any request to access personal data must be made to Revoke in writing and provide sufficient detail to identify the Personal Data that you are seeking.
If you are a registered user of our Services, you have the right to modify the personal data you provided to us and associated with your Account by making a request to email@example.com.
This right applies in certain specific circumstances; where the accuracy of personal data is contested and the data controller needs time to verify details; where processing is deemed unlawful but the data subject opposes erasure and requests restriction instead; where there is an objection to data processing under legitimate interest legal bases and pending verification that the legitimate interest overrides the data subjects rights; the purpose of processing is no longer valid but it is required by the data subject for the establishment, exercise or defence of legal claims.
This right is available to data subjects to request exclusion from any direct marketing activities or communications, including profiling to the extent that it is related to such direct marketing activities, and to any automated means using technical specifications in the context of information society services
You can delete or request deletion of your Account and uninstall the BLOKK app at any time. BLOKK will not however be able to delete all our personal data to the extent that it is necessary to meet its legal obligations
This is a new right and only applies to those processing activities that are conducted under the legal basis of Consent or on Contract and the processing is carried out by automated means. Your data can be transferred to another data controller or to you directly where technically feasible
The data subject can object to automated decision-making and profiling in certain circumstances and request human intervention in the decision-making process. BLOKK does not make any decisions based on purely automated means, but if we do, you have a right to object
Where the processing of personal data is conducted with Consent as the legal basis, the data subject can withdraw consent at any time.
Each data subject request to exercise the rights noted above will be reviewed against the requirements of the Data Protection (Jersey) Law 2018 and other relevant data protection laws, and in certain circumstances (e.g., restriction, erasure, objection, data portability) these rights may not be exercisable by the company. Full explanations will be given in such cases.
Making a complaint:
The Jersey Office of the Information Commissioner (“JOIC”), Channel Islands, is an independent statutory authority where you can make a complaint or learn more about data protection in Jersey. Their office is located at 2nd Floor, 5 Castle Street, St. Helier, Jersey, JE2 3BT. Their website is www.jerseyoic.org and their telephone number is 01534 716530.
BLOKK is committed to ensuring the security of your personal data and has implemented appropriate commercially reasonable technical, physical, and organisational measures to prevent unauthorised or unlawful processing of your personal data or accidental loss or destruction of your personal data.
Our website is encrypted using HTTPS (Hypertext Transfer Protocol Secure). In HTTPS the communication protocol is encrypted using Transport Layer Security (TLS). This provides a secure method of communication with us, and any personal data uploaded onto our website is securely managed by our website data processor services.
Email communications are scanned using the latest version of anti-virus and malware software deployed by our business.
Our computer systems have secure audit trails, and we have robust backup capabilities in place to ensure that our services can continue uninterrupted for our customers.
Management and employees are trained in their data protection responsibilities and obligation to handle personal data in a confidential manner.
Change to this notice:
Revoke has appointed Formiti Data International, 6 Fern Road, Dublin, D18 FP98, Ireland, as its EU Representative. They can be contacted on +353 1 485 3752 or by email using firstname.lastname@example.org.
Revoke has appointed Formiti Data International, Grosvenor House, 11 St Pauls Square, Birmingham B3 1RB, United Kingdom, as its UK Representative. They can be contacted on +44 121 582 0192 or by email using email@example.com.
2nd Floor, Conway House, 7-9 Conway Street, St Helier, Jersey, JE2 3NT
Registered with the Jersey Financial Services Commission, Registration Number 124314
© Revoke Limited 2022