Website Privacy Notice

Last Updated February 8, 2023

This Privacy Notice (“Notice”) provides you with information on how Reputell™ will process personal information. As you use and interact with Reputell™’s websites and customer portals we process personal information from and about you to provide access to our tools, an enhanced experience, and support. That means the collection, use, transmission, storage, sharing, and deletion of your personal information.

1.   Our relationship with you

In situations where we collect personal information from you or about you to respond to inquiries related to Reputell™ products and services, provide you with information about our products and services, or provide you access to Reputell™ service portals, Reputell™ is the controller of the personal information.

Where Reputell™ processes personal information in connection with Reputell™’s verification, payment, and related online services, including but not limited to Authentication and ID Verification, please visit the Reputell™ Online Services Privacy Notice.

2.   Personal information we process

Reputell™ processes information we receive directly from you, automatically collected when you use Reputell™ or visit one of our websites, and collected by Reputell™ from third parties. However, please note that this Privacy Notice does not apply to the processing of your information by third parties through your use of any third-party integrations available via our services. Please visit those third-party websites directly for more information on their privacy and data protection practices.

Information you provide to us through your use of Reputell™ services

Reputell™ collects the following personal information:

  • personal identifiers (e.g., name, email address, phone number); and

  • profession or employment information, such as your title or role at your company.

Reputell™ may also collect the following information from you:

  • billing information, such as name, address and telephone number;

  • financial information, such as business bank account information; and

  • other data provided by you in your communications with Reputell™ (e.g., your requests, questions, and responses to Reputell™ via forms or emails).

Information automatically processed when you visit our websites or use our customer portals

When you use our websites and customer portals, we also automatically collect certain information which enables us to provide, improve and develop our website and customer portals. This information may include:

  • online identifiers (e.g., IP Address);

  • Internet or other electronic network activity, including information about your browsing history, operating system browser type, website preferences, your use of our website or application (e.g., time access, duration of visit, etc.); and

  • geolocation information, such as approximate geographic location inferred from IP address.

Information Reputell™ receives from other sources

Sometimes Reputell™ receives your information from third parties (other individuals, marketing services, third-party integrations), which may include:

  • name, email, and business contact information

We may also work with third parties, including Google Analytics, who collect information about your use of our website, other websites, and/or online services over time. This information may be used for a variety of purposes including online behavioral advertising. For more information about how Google Analytics collects and uses information when you use our website. To read more about how we use cookies and similar tracking technologies visit our Cookie Notice.

3.   How we use your personal information

Reputell™ uses your personal information to operate our products and services, communicate with you, process transactions when you change Reputell™ services, for security and fraud prevention, and to comply with the law.

We may process personal information you provide to us through the use of our services to:

  • provide services and support to you and operate our business;

  • maintain, provide, and improve our products and services;

  • analyze and research how you interact with our websites and applications;

  • protect Reputell™ and you, for example:

    • Securing our systems and products against fraud or unauthorized activity

    • Identifying, troubleshooting, and fixing bugs and errors

    • Complying with global laws and regulations

  • establish, exercise or defend legal claims;

  • investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property, the property or physical safety of any person or third party; and

  • facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of Reputell™’s business or assets.

In addition, we use the personal information about your use of Reputell™, account information (such as your email address and name), and information related to third-party integrations to:

  • communicate with you; and

    • about Reputell™ by phone, text, email, or chat

    • to share important notices and updates, product changes, and other necessary notices such as security and fraud alerts

    • to advertise or market Reputell™ services to you. You have the ability to unsubscribe from promotional communications at any time

  • facilitate reporting and analyze performance of the Reputell™ platform or available features.

Unless otherwise prohibited by law, we may combine the information that we collect through your use of our products and services with information that we receive from other sources, both online and offline, and use that combined information as set out above.

All the personal information described in this Notice may also be used to comply with a valid legal subpoena, request, or other lawful process that meets the requirements of our Law Enforcement Guidelines or that we otherwise determine is necessary to respond to.

Aggregated and De-identified data. We may aggregate and/or de-identify information related to your use of Reputell™ so that such information can no longer be linked to you or your device. We may use such aggregated and de-identified data for any purpose, including but not limited to for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and others.

4.   How we share personal information

Sharing for business purposes. We may provide personal information to service providers to help us improve our products and services and to deliver, manage, and improve our websites and customer portal.  We may share all the categories of information listed in this Notice with other companies including affiliates, subsidiaries, or parent companies:

  • to operate our products and services or support general operations of business including provide information to customers;

  • to integrate the products and services of our business partners;

  • to use third-party cloud services to process the personal information; and

  • for any other legitimate business purpose.

Corporate transactions. In the event of a corporate sale, merger, reorganization, dissolution or similar event, any personal information and other data we process from you may become part of the assets we transfer or share in preparation for any such transaction. Any acquirer or successor of Reputell™ may continue to process personal information consistent with this Notice.

Compliance and compelled disclosures. We may share personal information:

  • with public authorities to respond to valid and enforceable subpoenas, court orders, and other legal process, or as otherwise required by law;

  • to protect the rights, privacy, safety, and property of Reputell™, our Customers, our business partners, or others; and

  • to exercise our legal rights or defend against legal claims, to enforce our contracts, to investigate, respond to and resolve problems, or to permit us to pursue available remedies or limit the damages that we may sustain.

Aggregated information.  From time to time, Reputell™ may also share anonymized and/or aggregated information, such as by publishing a report on trends in the usage of our products and services.

5.   Storage and retention

Storage

The personal information described in this Notice may be transferred to and processed in the United States for the purposes described above.  Reputell™ also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence.  The data protection laws in these countries may be different from, or less stringent than, those in your country of residence.

Retention

Reputell™ will retain the personal information for the period necessary to fulfill the purposes outlined in this Notice, or as instructed by you, unless a longer or shorter retention period is required or permitted by law.

6.   Security

Reputell™ uses commercially reasonable physical, electronic, and procedural safeguards designed to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus Reputell™ cannot guarantee the absolute security of your personal information or other information.

7.   Your privacy rights

You can exercise any of the rights described in this section consistent with applicable law by emailing info@reputell.com. Please note that we may ask you to verify your identity and request before taking further action on your request.

Data Access and Portability

In some jurisdictions, applicable law may entitle you to:

  • request certain copies of your personal information or information about how we handle your personal information;

  • request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format; and

  • request that we transmit this information to another service provider (where technically feasible).

Data Deletion

In certain jurisdictions, you can request that your personal information be deleted. Please note that if you request the deletion of your personal information:

  • we may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety;

  • we may retain and use your personal information to the extent necessary to comply with our legal obligations (e.g., Reputell™ may keep information for tax, legal reporting, and auditing obligations); and

  • because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited time.

In accordance with applicable law, you may also have the right to: (i) request confirmation of whether Reputell™ is processing your personal information; (ii) object to or restrict our uses of your personal information; (iii) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (iv) lodge a complaint with the competent supervisory authority or regulatory agency.

Where we process your personal data based on your consent, you may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

We will not discriminate against you for exercising any of the above rights.

Appeals

If you are a resident of the Commonwealth of Virginia, you may request an appeal of a refusal of a request regarding your privacy rights under the Virginia Consumer Data Protection Act by sending an email to info@reputell.com.

8.   Other important information

Children’s privacy

The website and customer portals are not directed to children under the age of 13, and Reputell™ will never knowingly collect personal or other information from anyone it knows is under the age of 13. We recommend that persons over 13, but under 18 years of age, ask their parents for permission before using the Services or sending any information about themselves to anyone over the Internet.

Marketing practices and choices

If you receive email from us, we may use certain analytics tools to capture data. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions, and special events that might appeal to your interests by following the instructions located at the bottom of such emails or contacting us at info@reputell.com.

Please note that, regardless of your request, we may still use and share certain information as permitted by this Notice or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, such as those reflecting our relationship or transactions with you.

Legal basis for processing

If you are an EEA resident, Reputell™ processes your personal information on the following legal bases under the General Data Protection Regulation (“GDPR“):

  • where we have your consent;

  • where use of your personal information is necessary to perform our obligation under a contract with you;

  • where use of your personal information is necessary for our legitimate interests or the legitimate interest of others; and

  • where use of your personal information is necessary to comply with a legal obligation.

9.       Changes to this notice

As revisions to the Notice are made, Reputell™ will post any updates on the Notice in the footer section of the website www.reputell.com, so we recommend reviewing that page periodically.  If we make a material change to the Notice, you will be provided with appropriate notice.

10.       Contacting Reputell™

If you have any questions or comments regarding this Notice, please send an email to info@reputell.com. If you prefer to contact us by mail, please write to Reputell™, 318 East 89th Street, New York, NY 10128, United States. You may also call us on +1-917-770-7977.

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