Haga clic para ver el

Last Updated OCTOBER 18, 2024

1. Overview

Connecta Group Corporation. (“ReplyAgent,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describeshow we collect and use your Personal Information when you visit our website at https://www.replyagent.com or otherwise use the Platform as described further in the Terms of Service, and that you may provide in electronic messages to ReplyAgent.

Please read this Privacy Policy to understand our policies and practices regarding your PersonalInformation and how we will handle it. If you do not agree with our policies and practices, do not use thePlatform. By accessing or using the Platform, you agree and consent to this Privacy Policy.

ReplyAgent may change this Privacy Policy at any time, at its discretion. Your continued use of thePlatform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

This Privacy Policy is subject to and governed by the ReplyAgent Terms of Service. The Services are partof the Platform and are described further in the Terms of Service.

2. The Types of Information That ReplyAgent Collects About You and How ReplyAgent CollectsInformation About You

ReplyAgent may collect two types of information from you when you visit the Platform: PersonalInformation and Non-Personal Information (collectively “Information”).

● “Personal Information” refers to data by which you may be personally identified, such as name,email address, employer, job title and department, and telephone number.
‍
● “Non-Personal Information” means data that is about you, but does not identify you specifically. Ifyou do nothing during your visit to our Platform but browse, read pages, or view content, we willgather and store Information about your visit that does not identify you personally.We collect Information:
‍
● Directly from you when you provide it to us. When you subscribe to a newsletter, create anaccount, make a purchase or request information from ReplyAgent, we will ask for things like yourname, contact, billing, shipping and communication information, and account ID or credentials inorder to fulfill your request. If you set up an appointment with us through the Platform, attend a tradeshow or event, or otherwise contact us, you may also voluntarily provide similar information. If yousubmit any Personal Information about other people to us or to our service providers, you areresponsible for making sure that you have the authority to do so and to allow us to use theirPersonal Information in accordance with this Privacy Policy (for example, by You asking for theirconsent).
‍
● From third parties. We obtain information through partners, vendors, suppliers and other thirdparties. The parties from whom we obtain information are typically corporate enterprises (althoughsome may also be educational or public enterprises) and they may be located in any of thelocations in which we do business. These enterprises largely fall into the following categories:Advertising and marketing companies, data set and information vendors, public database providers,social media platforms, partners, providers of products or services, hosts or vendors at events ortrade shows, research partners, or enterprises that use ReplyAgent Services. We take steps toconfirm that information we receive from these third parties has been collected with your consent orthat these parties are otherwise legally permitted to disclose your Personal Information to us. Wemight also obtain information through a partner, or co-create datasets with a partner, as part of ourbusiness operations. This kind of data is used for work like improving the Platform and otherReplyAgent Services, enhancing existing products and developing new capabilities and features. Insome cases we combine Personal Information about individuals that we receive from multiplesources, including directly collected from you or through your use of the Platform.● Automatically as you navigate through the Platform or during the time in which you utilizeour Services. We collect information about how you interact with the Platform through the use ofcookies, pixel tags, and similar technologies. Please view our separate Cookies Policy for moreinformation on our use of cookies and similar technologies, how you can manage cookies and howwe respond to Do Not Track signals.

3. How ReplyAgent Uses Personal Information It Collects About You and the Purposes for theCollection and Use

We use Personal Information that we collect about you or that you provide to us for the following purposes:
‍
● For Functionality and Development of the Platform and ReplyAgent Services. We useinformation to provide, offer, and personalize the Platform and other ReplyAgent Services providedto you. Some information, like your IP address, is used to communicate with your device to providenetwork connectivity, measure usage levels of the Platform, diagnose server problems and providesecurity features. Other business purposes that depend on use of your information include dataanalysis related to testing, modifying, improving or developing new products, services andtechnologies, and to identify trends. We use cookies to make our websites and the Platformoperate, work more efficiently, and provide analytic information. Technologies similar to cookies,such as pixel tags are also used in connection with the Platform. For more information on our use ofcookies, please read our Cookies Policy.
‍
● For Customer Support, Platform Updating and Reporting. The Platform may use information toprovide ReplyAgent with updates and reports, and to check that the Platform is working properly.Update functions may automatically check your system to see whether files need to be refreshed,updated, or modernized, in order to provide you with the up-to-date security, versions, features,options and controls associated with your systems or devices. We rely on information to analyzeperformance and improve and maintain the Platform. We also rely on Personal Information youprovide to us to provide you with customer support for the Platform and other ReplyAgent Services,and to verify eligibility for promotional offers.

● For Business Operations. We use information to operate our business; for example, to performaccounting, auditing, billing, reconciliation, and collection activities. Other business purposes thatdepend on use of your Personal Information include crime or fraud monitoring and prevention,protecting our legal rights, and performing contractual obligations. We also use PersonalInformation to contact you to advertise, market and sell ReplyAgent Services in accordance withyour communications preferences.

● To Communicate. We use contact information to send messages; to provide ReplyAgent Services;to respond to customer service requests; to provide alerts such as security updates or changes inour policies or about subscriptions that are ending; and to send marketing or informational materialslike newsletters or white papers, in accordance with your communication preferences. We occasionally conduct surveys, or do focused research or studies which may require you tovoluntarily share Personal Information in order to participate. These activities typically haveadditional notices that provide more information about the use of your Personal Information and towhich you may be asked to consent.

● For Advertising and Marketing. We may use Personal Information collected from you, combinedwith information about what advertisements you viewed and other information we collect, to enableus to provide personalized content and to study the effectiveness of advertising and marketingcampaigns. You may choose whether to allow or deny uses or sharing of your device’s location bychanging your device settings, but if you choose to deny such uses or sharing, we may not be ableto provide you with certain personalized ReplyAgent Services and content on the Platform.

● For Statistical Purposes to Improve the Platform. We may compile Platform statistics into trafficreports, which help ReplyAgent understand, anticipate, and respond to user needs. If we learn, forexample, of heightened interest in certain aspects of the ReplyAgent Platform, we are likely tohighlight that information on the Platform home page. This Information helps us create a betteroverall experience for Platform users.

LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): Ifyou are in the European Economic Area or the United Kingdom, our legal basis for collecting and using thePersonal Information described above will depend on the Personal Information concerned and the specificcontext in which we collect it. However, we will collect Personal Information from you only where we have your consent to do so, wherewe need the Personal Information to perform a contract with you, where we have a legal obligation to doso, or where the processing is in our legitimate interests (such as processing for administrative purposes,direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contractwith you, we will make this clear at the time of collection. We will also tell you whether the requirement forthat information is mandatory and explain any consequences to you if you do not provide the information.

Similarly, if we collect and use your Personal Information based on our legitimate interests (or those of anythird party), we will take reasonable steps to provide clear notice and describe our legitimate interests.

ReplyAgent is the Data Controller of all Personal Information collected through the Platform in the EEA andthe United Kingdom, except with respect to the Services (where ReplyAgent is the Data Processor) orwhere a supplemental Privacy Policy says otherwise. The contact details for ReplyAgent are set out in the"HOW TO CONTACT US” section.

If you have questions about or need further information concerning the legal basis on which we collect anduse your Personal Information for any specific processing activity, please contact us using the contactdetails provided under the “HOW TO CONTACT US” Section below.

RETENTION OF YOUR PERSONAL INFORMATION: We will only retain your Personal Information for aslong as reasonably necessary to fulfill the purposes we collected it for, including for the purposes ofsatisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes describedin this Privacy Policy. We may retain your Personal Information for a longer period in the event of acomplaint 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 Information, we consider the amount, natureand sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure ofyour Personal Information, the purposes for which we process your Personal Information and whether wecan achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting orother requirements. In some circumstances you can ask us to delete your data: see “YOUR LEGALRIGHTS” below for further information. And in some circumstances we will anonymize your PersonalInformation (so that it can no longer be associated with you) for research or statistical purposes, in whichcase we may use this information indefinitely without further notice to you.

4. How ReplyAgent Protects Your Information

The Platform is designed to provide reasonable and appropriate administrative, technical andorganizational security measures to protect your Personal Information against risks such as temporary orpermanent loss, destruction, and unauthorized or unlawful access, alteration, use or disclosure. We require our suppliers and vendors to apply similar protections when they access or use PersonalInformation that we share with them. Users of the Platform must also do their part in protecting the data,systems, networks, and service they are utilizing. No technology, data transmission or system can beguaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longersecure (for example, if you feel that your password to any ReplyAgent account has been compromised),please immediately notify us by contacting us using the instructions in the “HOW TO CONTACT US”section below.

5. When ReplyAgent Shares Your Information

We work through our affiliates to provide the Platform and other ReplyAgent Services. We also work withauthorized suppliers and business partners. When we share your Personal Information with thesecompanies, we put in place appropriate measures to limit the use of your information only for legal and authorized purposes that are consistent with this Privacy Policy, as well as appropriate confidentiality andsecurity measures.

We also share information with third parties for advertising and marketing; when required by law or torespond to legal process; to protect our customers; to protect lives; to maintain the security of the Platform;and to protect our legal rights. We may disclose Personal Information that we collect or you provide asdescribed in this Privacy Policy:● With Affiliates and Subsidiaries. For purposes limited to and consistent with this Privacy Policy.

● With Suppliers. Our authorized vendors and suppliers may require Personal Information to provideservices we have contracted for, such as product delivery, website hosting, data analysis, ITservices, auditing, or customer service. We use a wide variety of software and tools at ReplyAgent,and we process Personal Information using these tools as a regular course of business. Ourcontracts with suppliers and vendors include provisions to protect your Personal Information andlimit its use.

● With Partners. We occasionally have relationships with third parties that are not suppliers orvendors but are working with us to offer certain opportunities such as marketing and similarpromotions, to enable joint products or research studies, or to facilitate services on the Platform. Inthese cases, additional terms or Privacy Policies may be provided. For third parties or uses notdescribed in this Privacy Policy, we share your information only with a lawful basis to do so.

● For Advertising and Marketing. We share your information with our third-party company partnersto prepare and deliver advertising and marketing content, to provide content services and to enablethem to provide you with more personalized ads and to study the effectiveness of our campaigns.In particular, we use third-party companies to communicate regarding goods and services that maybe of interest to you, in accordance with your preferences. You may receive this content by avariety of means such as email, phone or when you access and use the Platform or otherReplyAgent Services, and other websites. Content may be based on information obtained, forexample, through prior purchases or transactions, through your device’s physical location, throughinformation about what advertisements and content you have viewed, or through cookies andsimilar technologies relating to your access to and use of the Platform and other websites. Pleaseread our Cookies Policy for more information. You can choose whether to allow or deny uses and/orsharing of your device’s location by changing your device settings, but if you choose to deny suchuses or sharing, our partners may not be able to provide you with the applicable Platform Servicesand content.

● Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplatedor actual corporate transaction such as a reorganization, merger, sale, joint venture, assignment,transfer or other disposition of all or any portion of our business, assets or stock (including inconnection with any bankruptcy or similar proceedings).

● With Your Consent. ReplyAgent may disclose your Personal Information to any other person orentity where you consent to the disclosure. For information about how to decline our advertising andmarketing, please see the section entitled "Your Choices & Rights" below.We also share non-personally identifiable information, such as anonymized or aggregated information, withsuppliers for purposes such as analysis, identifying trends in the areas of our products and to helpresearch and develop new ReplyAgent Services.ReplyAgent does not sell any of your Personal Information for monetary compensation.

6. Information From Children

We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we havecollected the Personal Information of a child under 16—or the equivalent minimum age depending on thejurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will takesteps to delete the information as soon as possible. If you are under 16, do not provide any Informationabout yourself to ReplyAgent, including your name, address, telephone number or email address. If youbecome aware that Information of a child under 16 years of age has been provided, please use one of themethods provided under the “HOW TO CONTACT US” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Platform,including the information or content contained therein. This Privacy Policy does not address, and we arenot responsible for, the policies and practices of third parties or other organizations that are not operatingon ReplyAgent’s behalf, including policies and practices related to privacy and security, data collection,processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service towhich the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linkedsite or service by us or by our affiliates; or (b) any app developer, app provider, social media platformprovider, operating system provider, wireless service provider or device manufacturer (such as Facebook,Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to otherorganizations through or in connection with the Platform or other ReplyAgent Services.

8. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites andonline services that you do not want to be tracked. At this time, the Platform does not respond to DNTsignals.

9. YOUR LEGAL RIGHTS

ReplyAgent respects your rights in how your Personal Information is used and shared. Depending onwhere you live, you may have rights to request access or corrections to your personal data and makechoices about the kinds of marketing materials you receive (or choose not to receive marketing fromReplyAgent at all). See below for more information, depending on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additionalchoices and rights may be available to you depending on which ReplyAgent Services you use.

● Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you maycontact us by visiting the Platform or by using the contact details provided under the “HOW TOCONTACT US” section below. If you request a change to or deletion of your Personal Information,please note that we may still need to retain certain information for recordkeeping purposes, and/orto complete any transactions that you began prior to requesting such change or deletion (e.g., whenyou make a purchase or enter a promotion, you may not be able to change or delete the PersonalInformation provided until after the completion of such purchase or promotion). Some of yourinformation may also remain within our systems and other records where necessary for compliancewith applicable law.At your request and where the law requires us to do so, we will confirm what Personal Informationwe hold about you. You may also have a legal right to obtain a copy of your Personal Information.You can make such a request by making a written request in one of the ways described in the“HOW TO CONTACT US” section below. We may charge a processing fee for this service wherepermitted by law and we will require evidence of your identity before fulfilling your request.

● Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland.

You can object to processing of your Personal Information, ask us torestrict processing of your Personal Information, or request portability of your Personal Information.You can exercise these rights by making a written request in one of the ways described in the“HOW TO CONTACT US” section below.Similarly, if we have collected your Personal Information with your consent, you can withdraw yourconsent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processingwe conducted prior to your withdrawal, or (2) processing your Personal Information under otherlegal bases.If you believe we are using your Personal Information in a way that is inconsistent with this PrivacyPolicy or for more information about your rights, contact your local data protection authority.Additionally, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S.DPF, you may contact JAMS Mediation, Arbitration, and ADR Services(https://www.jamsadr.com/eu-us-data-privacy-framework) to address complaints and provideappropriate recourse free of charge to you. Under certain conditions, you may invoke bindingarbitration.

● Advertising and Marketing Choices.

We give you many choices regarding our use and disclosureof your Personal Information for advertising and marketing purposes. You may access or updateyour contact details and modify your communication preferences by using one of the methodsprovided under the “HOW TO CONTACT US'' section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related toyour products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy includes more information on ReplyAgent’s use of suchtechnologies for advertising and other purposes.

11. International Compliance

ReplyAgent is a global company with its headquarters in the United States. As such, we may transfer your Personal Information between the United States and our affiliates and business partners in other countries.We may also transfer your Personal Information to our third party service providers, who may be located ina different country to you.

ReplyAgent transfers information internationally in order to operate efficiently, to improve performance, andto create redundancies to protect information in the event of an outage or other problem. In so doing, wewill process your Personal Information in a way that meets the commitments of this Privacy Policy andcomplies with the law wherever we transfer it.

Whenever ReplyAgent transfers Personal Information beyond the country of origin, we will do so inaccordance with applicable laws. For Personal Information originating in the European Economic Area(EEA), the United Kingdom (UK), or Switzerland that is transferred to a ReplyAgent entity outside the EEA,UK, or Switzerland, ReplyAgent participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and,as applicable, the UK extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework(Swiss-U.S. DPF). ReplyAgent commits to the DPF Principles and, as needed, will take additional steps toprovide appropriate safeguards for the Personal Information we transfer. The Federal Trade Commissionhas jurisdiction over ReplyAgent’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S.DPF, and the Swiss-U.S. DPF). ReplyAgent may be required to disclose Personal Information in responseto lawful requests by public authorities, including to meet national security or law enforcementrequirements. ReplyAgent is liable in cases of onward transfers to third parties.

12. Data Privacy Framework

Connecta Group Corporation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forthby the U.S. Department of Commerce. ReplyAgent has certified to the U.S. Department of Commerce thatReplyAgent and LeadConnector adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPFPrinciples) with regard to the processing of personal data received from the European Union in reliance onthe EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to theEU-U.S. DPF. ReplyAgent has certified to the U.S. Department of Commerce that ReplyAgent andLeadconnector adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles)with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S.DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/orthe Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data PrivacyFramework (DPF) program, and to view our certification, please visithttps://www.dataprivacyframework.gov/.

13. California Privacy Rights

This section is addressed to California residents only and provides more information about your rightsunder the California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.), asamended. Subject to certain exceptions, the CCPA grants to California residents the rights to: be notifiedabout the collection, use, disclosure, sale or sharing of their Personal Information; request access to,deletion of, or correction of their Personal Information; request to opt out of the “sale” or “sharing” of Personal Information (where such information is sold or shared); limit the use or disclosure of SensitivePersonal Information (as defined under CCPA); and to not be discriminated against for exercising suchrights.ReplyAgent does not sell your Personal Information. If you wish to exercise your right to opt-out ofReplyAgent using your Personal Information for cross-contextual targeted advertising purposes (called“sharing” under the CCPA), you may do so by using the details in the “HOW TO CONTACT US” section orthe appropriate withdrawal mechanism provided to you on the Platform.You can request access to, correction of or deletion of your Personal Information by using the details in the“HOW TO CONTACT US” section. If you request a deletion of your Personal Information, please note thatReplyAgent may still need to retain certain information for recordkeeping purposes, to complete anytransactions that you began prior to requesting such deletion, to comply with applicable law, or for otherpurposes permitted by CCPA. If you submit a request to exercise rights under CCPA, ReplyAgent will askyou to provide certain information to verify your identity. This information will depend on your priorinteractions with ReplyAgent and the sensitivity of Personal Information at issue. If ReplyAgent deniesyour request, we will explain why.You can designate an authorized agent to make a request under the CCPA on your behalf in certaincircumstances. If you use an authorized agent for this purpose, ReplyAgent may ask you to verify youridentity or that you provided the authorized agent signed permission to submit a request under the CCPA.If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465,it may not be necessary to perform these steps and ReplyAgent will respond to any request from suchauthorized agent in accordance with the CCPA.The Privacy Policy describes the categories of Personal Information that ReplyAgent collects and howReplyAgent uses such Personal Information. If ReplyAgent collects Sensitive Personal Information, we limitour use of the Sensitive Personal Information to uses: (1) you have authorized, (2) that are required to fulfillyour requests for goods or services, or (3) that are otherwise allowed by the CCPA or required by otherlaws or regulations.The categories of Personal Information collected, disclosed, and sold from California residents over thepreceding 12 months and ReplyAgent’s applicable retention periods include:Personal InformationCategoryRetentionPeriodBusiness Purpose CollectedDisclosedSoldIdentifiers (such name,address, IP address,email, etc.)See Section 3of PrivacyPolicy:“Retention ofYour PersonalInformation”For functionality,customer support,business operations,communication,advertising andmarketing, andstatistical purposes.Yes Yes NoPersonal informationdefined in Civil CodeSection 1798.80(e) (suchas signature, SSN,financial information, andinsurance information,etc.)No No NoProtected personalinformation (such asgender, religion, sexualorientation, or disability)No No NoCommercial information(such as products orservices purchased,obtained, or considered,or other purchasing orconsuming histories ortendencies, etc.)See Section 3of PrivacyPolicy:“Retention ofYour PersonalInformation”For development,customer support,business operations,communication,advertising andmarketing, andstatistical purposes.Yes No NoBiometric information No No NoInternet or other similarnetwork activity (such asinformation on aconsumer’s interactionwith a website,application, oradvertisement, etc.)See Section 3of PrivacyPolicy:“Retention ofYour PersonalInformation”For functionality,business operations,and statisticalpurposes.Yes Yes NoGeolocation data No No NoAudio, electronic, visual,thermal, or olfactoryinformationNo No NoProfessional oremployment-relatedinformationNo No NoEducation information No No NoInferences (such asanalytics and preferencesYes Yes No