Repsly Website Privacy Policy

 

Effective Date: September 24, 2021

Repsly, Inc. (with its affiliates, “Repsly,” “we” or “us“) is committed to protecting the privacy of the users of its website at the address www.repsly.com or any other website managed and controlled by Repsly (the “Site“).  This Website Privacy Policy is meant to help you understand what information we collect through the Site, why we collect it, and how you can update, manage, export, and delete your information.  If you do not agree with the practices described in this Website Privacy Policy, you should not use the Site.

Changes to this Privacy Policy

Repsly reserves the right to change this Privacy Policy. Repsly will provide notification of the material changes to this Privacy Policy through the Site. 

How to Contact Us

If you have questions or concerns about this Privacy Policy, or our collection and use of your Personal Data, you are welcome to send us an email or otherwise contact us at the following address and we will make an effort to reply within a reasonable timeframe.  You may contact us through our Data Protection Officer, Branimir Karacic, by email at privacy@repsly.com; by telephone at +1-617-356-8125; or by postal mail at 55 Summer Street, 3rd Floor, Boston, MA 02110, attention Legal Department. By using the above email, you will also contact our EEA legal representative, Krunoslav Smolcic, , HYDRA CONSULTING d.o.o., Prve Poljanice 7, 10040 Zagreb, Croatia.

E.U. residents have the right to lodge a complaint with a supervisory authority (Data Protection Authority in your jurisdiction) in case of a breach of any E.U. data protection and privacy regulations. If the supervisory authority fails to deal with a complaint or inform you within the time frame set under applicable law, you have the right to an effective judicial remedy.

What information do we collect through the Site?

You may electronically submit data or information to the Site that identifies or may be used in combination with other information to identify you (“Personal Information”).

We collect Personal Information from you:

  • When you visit the Site
  • When you register or request additional information on the Site;
  • When you transmit information through the Site, our application or service;
  • When you register for or attend corporate events.

When using our Site, you may be asked to enter your name, e-mail address, mailing address, phone number or credit card information. You may, however, visit our Site anonymously (although we may still use cookies – see our Cookie Policy at www.repsly.com/legal). 

While you use our Site, we may, with your consent, collect information based on your interaction with our Site or from the devices or computers you use to access the Site, including web log information, page views, IP addresses, geographic location (if detectable from a mobile device).  We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

For which purposes do we use your information?

 Any of the Personal Information we collect from you on the Site may be used in any of the following ways:

  • To provide you with additional information about our service and Repsly’s partners, promotions, and events;
  • To improve the Site, our application and service;
  • To personalize your experience (your information helps us to better respond to your individual needs);
  • To send periodic e-mails and targeted marketing; and
  • To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs).

Principals of processing data

Repsly processes data lawfully, in a transparent manner and in accordance with individuals’ rights (as applicable). The use of information collected through our Site will be limited to Repsly’s legitimate interests, where we have considered these are not overridden by your rights, or based upon your informed consent.

Personal Information or Personal Data is information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, or any other information that is defined as Personal Information, Personal Data, or Personally Identifiable Information under an applicable law (hereinafter referred to as “Personal Information”)

Repsly aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfil the purpose for which the data is gathered. Repsly only collects data in connection with a specific legitimate purpose and only processes data in accordance with this Privacy Policy.

How do we protect your information?

We take great care in implementing, enforcing and maintaining the security of our Site and Users’ information. Repsly implements, enforces and maintains security policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Information or Personal Data and to monitor compliance of such policies on an ongoing basis. All information is stored with logical separation from information of other Customers. However, we do not guarantee that unauthorized access will never occur.

We use a combination of processes, technology and physical security controls to help protect Personal Information and Personal Data from unauthorized access, use, or disclosure. Each server is protected by a firewall, exposing it only to the minimum ports necessary. However, no security controls are 100% effective, and we cannot completely ensure or warrant the security of your Personal Information.

Subject to applicable law, Repsly will act in accordance with its policies to promptly notify you in the event that any of your Personal Information or Personal Data is lost, stolen, or where there has been any unauthorized access to it.

Repsly may use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to operate the Site. We seek to obtain confidentiality agreements that are consistent with this Privacy Policy and that limit others’ use or disclosure of your Personal Information and Personal Information.

Do we use cookies?

Repsly may use browser cookies on the Site to keep track of your visit. For further information, please see our Cookie Policy at www.repsly.com/legal.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer to outside parties your Personal Information. This does not include disclosure of data to trusted third parties who assist us in operating our Site or service, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when demanded by governmental authorities and we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety, to the extent permitted by law.  We may also share your Personal Information with another organization that buys all or substantially all of our business assets.

For avoidance of doubt, Repsly may transfer Personal Information to its affiliates, which will be obligated with the same restrictions as specified in this Privacy Policy.

Where is your information stored?

We store your Personal Information on our servers located in either or both of Virginia or Ohio, USA.

Data retention

Repsly will retain your Personal Information for only as long as necessary to achieve the purpose for which it is processed. How long we need your Personal Information depends on what we are using it for, as set out in this Privacy Policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep Personal Information while you are still using our product or services. 

Information for European data subjects

When we receive information directly from visitors to the Site who are citizens or residents of countries in the EEA, that information is likely to include “personal information,” as regulated by GDPR. As the recipient of this information (generally just contact information), we are a “data controller” under the GDPR.  As such, we will use that information only for the limited purpose of providing information about our products and services until the person who submitted the information no longer wishes that to occur, and anyone who submits personal information to the Site consents to our use of that data for those purposes.

Data subjects’ rights

As mandated by the GDPR, you can contact us with regard to the following rights in relation to your Personal Information:

  • If you would like to have a copy of the Personal Information, we hold regarding you or if you think that we hold incorrect Personal Information about you, Repsly will honor your request.
  • Where you have provided us with consent to use your Personal Information, you can withdraw this at any time (but please note that, if you use the Repsly service, we may continue to use your Personal Information, including to contact you in connection with the service for as long as you use it).
  • You also have the right to ask us to delete your Personal Information or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your Personal Information for certain purposes.

If you want to make any of these requests, please contact us using the contact information provided above.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

Transfer of personal information

Whenever we transfer your Personal Information out of the EEA, we put in place at least one of these safeguards:

  • We will only transfer your Personal Information to countries that have been found to provide an adequate level of protection for Personal Information.
  • We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your Personal Information the same protection it has in the EEA.

But please understand that, if you use the Repsly service on behalf of your employer, we will comply with any contractual requirements between us and your employer governing our use of any Personal Information you submit.

We may transfer your Personal Information to the United States of America for the following reasons:

  • To provide the Repsly service to you, if you are a customer
  • To store your Personal Information
  • To communicate with you
  • To monitor the behavior of visitors to the Site.

California Online Privacy Protection Act Compliance

Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your Personal Information to outside parties without your consent.

Modification or deletion of Personal Information gathered through the Site

Upon request, Repsly will provide you with information about whether we hold any of your Personal Information. A User may have a legal right under certain applicable laws (for instance if the User is residing in the EEA or in California as applicable) to receive, rectify, erase, and restrict Personal Information about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent. Users may also have the right to withdraw consent for processing for statistical and research purposes and in some cases (subject to applicable laws) to request cessation of any collection of Personal Information. Repsly will never discriminate against any person based on his or her exercising of their rights hereunder.

If, for any reason, a User wishes to modify, delete or retrieve his or her Personal Information collected through the website and is entitled to under applicable laws, he or she may do so by contacting Repsly at the address detailed above.  We shall perform the necessary process to identify the User as a User who has the right to retrieve the specific information and then we will ask for a specific identification of the User and data (as shall be applicable for the requested data – for instance IP address and time of uploading the information to Repsly’s servers (IP address is not enough for an identification of User or data)). Repsly cannot retrieve data without a specific identification of User and data. Repsly may not be able to delete, amend or retrieve User’s information without other Controller’s instructions and authorization (as applicable). We shall make efforts to respond to a User’s request within 30 days or as required under applicable law however, deletion of data may take longer (see below).

Please note that Personal Information may be either deleted or retained in an aggregated manner, without being linked to any identifiers or Personal Information, depending on technical commercial capability.

For any request or question regarding deletion or amendment of User data, you can contact our Data Protection Officer at the contact details listed above and we shall make efforts to respond and support your request within no more than 30 days.

The Information gathered through the Site shall not be retained longer than legally permitted.

Opting Out

You may opt out of receiving future communications from us  (with the exception of service information when you continue to use the Repsly service) by logging into your account and editing your profile.   You may also opt out of receiving commercial e-mail from us, or other target advertising, by following the instructions in each email.

Minors

Our Site is directed to people who are at least 16 years old. By using the Site, you represent and warrant that you are at least 16 years old, or have the permission of your parent or guardian, and otherwise have the right, authority and capacity to agree to and accept this Privacy Policy.