Privacy Policy

1. Introduction

This Privacy Policy details how we, Netduma Limited of 9 Journey Campus, Castle Park, Cambridge, CB3 0AX and our associated companies collect, use and process personal data provided to us.  If you have any questions on this Privacy Policy or otherwise relating to how we process your personal data you can contact us at [email protected] or at the address above.

This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us.

We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it.

We are the controller of the personal data provided to us for the purposes of applicable data protection legislation.

2. Whose personal data do we collect?

By personal data we mean identifiable information about you, such as your name, email address, gender, age, mobile and home telephone number and your IP address and your router’s MAC address.

We do not collect  special categories of personal data about you and we do not knowingly obtain personal data from individuals under the age of 18.

Information you provide to us

From time to time you may provide to us personal data. This may be because you wish to:

  • use our website and associated mobile applications, including our forums;
  • register your NETDUMA router;
  • create an account on our R-App Store and when you then download an R-App;
  • otherwise purchase products or services from us;
  • provide services to us;
  • accept or cancel the terms of our software EULA; or
  • otherwise contact us including with queries, comments or complaints and/or for technical support.

We shall process all such personal data in accordance with this Privacy Policy. Certain personal data is mandatory to be provided to us in order that we can fulfil your request, for example to make a purchase of a product or services from us, and we shall make this clear to you at the point of collection of the personal data.

All personal data that you provide to us must be true, complete and accurate.  If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this and we may also report this to the appropriate authorities.

At our request, you shall promptly provide evidence of your identity.

When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.

Information we automatically collect about you

When you use our platforms, including our website, mobile applications,  the R-App Store and/or or a NETDUMA router, we automatically collect and store information about your device and your activities. This information could include:

  • technical information about your device, including type of device, web browser or operating system and IP address;
  • performance statistics, including network speeds, network Internet service provider (ISP), and other device data (e.g., temperature, CPU, memory),
  • network bandwidth usage statistics (i.e. the volume of data transferred and the protocol of packets),
  • information about your visits to and use of the website, including your geographical location, referral source, length of visit and number of page views; and
  • information about your use of the NETDUMA router including which functions you use, how frequently and for how long.
Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use on our website, why, and how you can control them, please see our Cookies Policy. We use this information on an anonymous basis to improve our products and services, to analyse and report on user activities, and it helps us to diagnose any problems you might have if you contact us for support.

Information we receive from others

If we reasonably believe that any of the personal data you have provided to us is inaccurate, we may receive further personal data from third parties confirming your identity.  We may also receive personal data about you from our payment providers and other third party service providers.

3. Lawful use of your personal data

We will only use your personal data where we have a lawful basis to do so.  The lawful purposes that we rely on under this Privacy Policy are:

  • consent (where you choose to provide it);
  • performance of our contract with you;
  • compliance with legal requirements; and
  • legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests.
  • to contact you with surveys or to request feedback on our products and services.

If you have ordered products or services from us, we shall use your personal data to provide those products and/or services in accordance with the contract for supply agreed between us, including where applicable our Rapp Store Terms our Terms and/or our EULA. We may from time to time contact you with information about your account with us, including any changes to our Rapp Store Terms our Terms and/or our EULA.

We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.

We may use your personal data for our legitimate interests including :

  • to improve our products and services;
  • in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
  • to deal with any customer services you require;
  • for audit purposes; and
  • to contact you about changes to this Privacy Policy.

4. Who do we share your data with?

For our legitimate interests, we may share your personal data with our service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including IT service providers, payment providers, accountants, auditors and lawyers.

We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems subject to their rights under applicable data protection legislation.

We also use broadband benchmarking service providers, to perform speed tests to measure and collect the performance results of user networks that are maintained through user devices.  The results are anonymous, but may be used by us and our broadband benchmarking service providers for research purposes, to improve services and systems and to issue reports on network performance.

If you use our router to measure your home’s connection speed, you will be connected to our provider, M-Labs who carry out the test.  So that they can do so, we will share your IP address with them (but no other personal data) and they will process your IP address in accordance with their privacy policy. M-Labs and retains all experiment data indefinitely and publishes it publicly to support research into trends in internet performance.

5. Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside the EEA or if any of our service providers are based outside of the EEA.

Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).


6. Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.  In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.

However, unfortunately, because of the nature of electronic storage,  we cannot promise that your personal data or any other data you provide to us will always remain secure.   If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data.

7. Marketing

You may consent to receive marketing email messages from us about the products and services we offer.  You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email.  Please note that it may take us a few days to update our records to reflect your request.

If you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information.  However, we may still send you information in relation to any other contract we have in place with you, such as our Rapp Store Terms, our Terms and/or our EULA.

8. Your rights

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here

  • Right of access: You have the right to obtain from us a copy of the personal data that we hold for you.
  • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date.
  • Right to portability: You can request that we transfer your personal data to another service provider.
  • Right to restriction of processing: In certain circumstances, you have the right to require that we restrict the processing of your personal information.
  • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it. However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.
  • Right to stop receiving marketing information: You can ask us to stop sending you information about our services.

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive.

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.  You can also contact the Information Commissioner, see or if you are based outside of the United Kingdom, please contact your local regulatory authority

9. Retention of personal data

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws.

You agree that we are required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents.

10. General

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts.

Last updated: June 2020