We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, provide information to our chatbots, fill out a form, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, organization name and type, time zone, credit card information and any other information you choose to provide.Information we collect automatically when you use the services
When you access or use our Services, we automatically collect information about you, including:
- Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
- Information Collected by Cookies and Other Tracking Technologies: We use various technologies (including those from third parties) to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. The third-party technologies we use may collect information about your online activities over time and across different web sites. For more information about cookies, and how to disable them, please see “Your Choices” below.
We use information about you to:
- Provide, maintain and improve our Services;
- Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices,
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, and events offered by Reply and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage and activities in connection with our Services;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Reply and others;
- Personalize and improve the Services and provide content or features that match user profiles or interests; and
- Carry out any other purpose for which you provide consent.
- With vendors, consultants or other service providers (such as infrastructure providers that host our servers and databases and third-party tools that we use to spot potential bugs and help us improve our Services);
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, public authority request or legal process, including to meet national security or law enforcement requirements;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Reply or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among Reply and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
- With your consent or at your direction.
- We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
The information we collect about you may be transferred to, and accessed from within, the United States, which may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdictions in which we process it. If you are a resident of the United Kingdom, European Economic Area (“EEA”), or Switzerland, please see our privacy shield notice below.
Your ChoicesAccount Information
You may update or correct information you provide as part of your online account by logging into your online account. If you wish to delete your account, please email us at email@example.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.Promotional Communications
You may opt out of receiving promotional emails from Reply by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Or, if you are a resident of the EEA:
Reply Labs Spain S.L. C/ Princesa, 5, 4a, 28008 Madrid, Spain.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).
Subject to certain limitations and exceptions, the CCPA provides California consumers the right to request to know more details about the categories and specific pieces of personal information we collect, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. We do not “sell” the personal information we collect.
In the last 12 months, we collected the following categories of personal information: identifiers, demographic information, commercial information, internet or other electronic network activity information, audio, electronic, visual or similar information. For more details about the specific pieces of personal information we collect and the categories of sources of personal information, please see the Collection of Information section above. We collect this information for the business and commercial purposes described in the Use of Information section above. We share this information with the categories of third parties described in the Sharing of Information section above.
California consumers may make a rights request for access by sending an email to firstname.lastname@example.org. If you want to make a deletion request, you may also contact us by mailing us at 450 W 33rd St, New York, 10001 NY, United States. We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
NOTE TO EEA RESIDENTS
If you are a resident of the EEA, you have certain rights and protections under the law regarding our processing of your personal data. Please see the sections below for more details.Legal Basis for Processing
We will only process personal data about in accordance with the following legal bases:
- When we have a legitimate interest in processing your personal data. For example, to communicate with you about changes to our Services or legal documents, to prevent fraud, or to provide, protect and improve our products and services.
- If we request your consent to a specific processing activity (such as to send marketing emails), and you provide your consent in the manner indicated.
- In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.
You have the right to access personal data we hold about you and to ask that this data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide you with the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us as indicated above.Data Retention
We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.EU-U.S. and Swiss-U.S. Privacy Shield
In connection with Reply’s processing of personal data it receives from the European Economic Area and Switzerland (“Covered Data”), Reply adheres to the EU-U.S. and Swiss-U.S. Privacy Shield Framework Principles issued by the U.S. Department of Commerce (the “Principles”) in connection with its processing of Covered Data. For more information about the Principles, please visit the Department of Commerce’s Privacy Shield website (at www.privacyshield.gov). You may contact us about any question or complaint regarding our adherence to the Principles as indicated above. If we do not resolve your complaint, you may submit your complaint free of charge to JAMS at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim, our designated Privacy Shield independent dispute resolution provider. Under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share Covered Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that party’s processing of Covered Data in violation of the Principles, unless we can prove that it is not responsible for the event giving rise to the damage.Questions or Complaints
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.