Privacy Policy

This privacy notice provides information on how RLS collects and processes your personal data when you visit our website (releaselayer.com) (Website), including any data you provide when registering your interest with us.
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Who we are
Hexr Ltd trading as RLS (“RLS”, “we’, “us” or “our”) is a private company registered and incorporated under the laws of England and Wales with company number 10999327 and registered address at Lock Studios, 7 Corsican Square, London, England, E3 3YD.

We are responsible for your personal data as data controller. We may collect and use your data when you visit the Website or request more information about or purchase a product from us.

If you have any questions about this policy or wish to exercise your rights relating to your personal data, please contact us using the information set out in Contact Details below.
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The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
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• Identity Data includes first name, last name and any previous names.
• Contact Data includes email address and telephone numbers.
• Usage Data includes information about how you interact with and 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
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How we collect your personal data
We use different methods to collect data from and about you including through:
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• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  - apply for our products;
  - subscribe to our service or publications;
  - give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see a link to our Cookies Policy here.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Technical Data is collected from the following parties:
  - analytics providers such as Google Analytics based outside the UK;
  - advertising networks such as Klaviyo based outside the UK;

How we use your personal data
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
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• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below a description of all the ways we plan to use the categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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Direct marketing
‍During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email OR You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third party
We may share limited personal data with trusted third parties:
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• Klaviyo (Email Marketing): Used to manage newsletters, marketing campaigns, and communications.
• Google Analytics (Website Analytics): Used to track and analyze how visitors use our site. Google may process data outside the UK.

Each third-party service has its own privacy policy. We encourage you to review them for more details:
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• Klaviyo: https://www.klaviyo.com/legal/privacy
• Google: https://policies.google.com/privacy

‍Opting out of marketing
‍You can ask to stop sending you marketing communications at any time by following the opt-out or “unsubscribe” links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

‍Cookies
‍For more information about the cookies we use and how to change your cookie preferences, please see here

‍How we share your personal data
‍We may share your personal data where necessary with parties such as internal third parties, external third parties, specific third parties or third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

‍International transfers
‍We may transfer, store and process your personal data outside the UK to service providers that carry out certain functions on our behalf. If we do so to countries which have laws that do not provide the same level of data protection as UK law, we ensure that a similar degree of protection is afforded by only transferring your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

‍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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

‍Data retention
‍We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data (see your legal rights below).

Your legal rights
You have a number of rights under data protection laws in relation to your personal data.

You have the right to:
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• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  
  - If you want us to establish the data's accuracy;
  - Where our use of the data is unlawful but you do not want us to erase it;
  - Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  - You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the details below. If you make a subject access request:
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• You will not have to pay a fee to access your personal data (or to exercise any of the other rights), unless your request is clearly unfounded, repetitive or excessive. In these circumstances, we may charge a reasonable fee or refuse to comply with your request.
• We may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may contact you to ask for further information relating to the request to provide a response quicker.
• We will aim to respond to legitimate requests within one month. It may take us longer if your request is complex or you have made several requests. If so, we will notify you and keep you informed.

Contact details
If you have any questions about this privacy notice or our data protection practices, please contact us via:
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• hello@releaselayer.com
• 7 Corsican Square, London, E3 3YD

Complaints
‍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 appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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‍Changes to the privacy policy and your duty to inform us of changes
‍We keep our privacy policy under regular review. This version was last updated on 5^th September 2025.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, for example a new address or email address.

‍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.