Effective January 01, 2023
Reputation.com, Inc. and its subsidiaries, including Social Mecca, Inc. (“Nuvi”), (“Reputation,”, the “Company” or “we”, “us”, and/or “our”) are committed to transparency and protecting the privacy of individuals who visit our website(s), and those individuals and businesses who purchase and/or use our desktop or mobile applications, and associated sub-domains (collectively, the “Site”) and in relation to use of our Site and the related applications and services offered by us (together with the Site, “Services”). This Privacy Notice describes the Company’s privacy practices in relation to the use of our website and the related applications and services offered for sale by Reputation and your choices about how we use personal data about you.
About Our Privacy Notice
- In this Privacy Notice, “Personal Data” (or “Personal Information” under the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”)) means any information that, either alone or in combination with other information, can be used to identify you. This Privacy Notice explains: (i) what Personal Data we collect when you use the Site or the Services; (ii) how the Company collects, uses, shares, transfers and secures your Personal Data, and (iii) your choices regarding your Personal Data.
- If there are any inconsistencies between the English language version of this Privacy Notice and any translated version, the English language version shall prevail.
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.
- Information We Collect
- Use of Information
- Disclosure of Information
- International Transfers of Personal Data
- Additional Information for European and UK Individuals
- Additional Information for California Residents
- Updating Information
- Data Retention
- Personal Data We Receive From Our Clients
- Cookie Notice (opens new page)
- Linked Sites
- Choice and Opt Out
- Desktop and Mobile App Disclosures
- Wireless Disclosures
- Changes to our Privacy Notice
- Contact Us
The Information We Collect
- In some areas of the Site (such as when you set up an account or provide information for us to contact you or when you ask for additional information) and in connection with our Services, Reputation and Nuvi may collect Personal Data, including your name, address, e-mail address, telephone number, username[s], credit card number, billing information and other information which you voluntarily provide. We may also collect information through the use of commonly-used information-gathering tools such as email, telephone, social media interactions, cookies, web beacons, browser data, IP address, mobile devices, third parties, and the actions you take through the use of Service. When expressing interest in obtaining additional information about products or services offered by us, you will be required to provide contact information, such as company name, company email, personal email, address, phone number, and other necessary information will be required. When purchasing products or services, we will require financial billing information, such as billing name and address, and credit card number. At user’s request, we will access and store authentication credentials, and other user data required by us to aggregate and publish data to Social Media Platforms on user’s behalf.
- If you request us to do so, by signing up for one of our services which involves collecting or tracking your Personal Data, we may collect your Personal Data from third-party sources and platforms (such as online review sites, social media sites or other sites on the Internet).
- As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyse trends in the aggregate and administer the Site.
- We also collect information regarding your use of this Site via tracking technologies. (See our Cookie Notice.)
Our Site is not intended for children under the age of 13. We do not knowingly solicit or collect information from any individuals under the age of 13. For information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: www.ftc.gov.
Our Use of Information
Registration; Service Delivery
- In order to use certain areas of the Site, you may first be required to complete a registration form, including a username and password. During registration, you may be required to give contact information, such as your name and email address.
- We use this information to contact you about the services on the Site in which you have expressed interest. Specifically, we will send you a welcome email and will also email you when a report has been prepared for you related to the product(s) that you have selected. This use of your data is necessary to respond to or implement your request before we enter into a contract or, for our clients, it is necessary for the performance of the contract between you and the applicable Reputation entity with whom the contract is executed.
Special Offers and Updates
Using your name and email address, we may send you information on products, services, discounts and promotions related to the Company. You can sign up for these emails on our registration page during the registration process. You have the option to opt-out from these types of communications. Please see the “Choice and Opt-out” section in this Privacy Notice. If you are an individual in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, we will only send you this information if you consent to us doing so at the time you provide us with your Personal Data (in such case, our legal basis for the processing of your Personal Data will be your consent, but you shall always have the option to unsubscribe).
The Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We urge you to consider the sensitivity of any information you input into these areas. To request removal of your Personal Data from our blog, contact us at email@example.com.
Social Media Widgets
Our Site includes social media features, such as the Facebook button and widgets, such as share buttons or interactive mini-programs that run on our Site (“Social Media Features”). The Social Media Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Social Media Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Social Media Features are governed by the privacy notice or practices and terms of service of the company providing it.
Internal Uses of Your Personal Data
We use Personal Data for certain legitimate business interests, notably in order to:
- process your transactions and related payments
- provide customer support and manage your account
- communicate with you about the Services
- conduct analytics on how the Site and our Services are being used by you, in order to improve our Services (for example, to ensure that our Site is presented in the most effective manner for you and for your computer/device) and inform our marketing strategy (by presenting you with products and sending you offers tailored to you and your interests)
- send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies
- respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services
- share Personal Data among our affiliates and subsidiaries for administrative and business operation purposes and in relation to our sales and marketing activities (read also the “Our Disclosure of Information” section below)
- prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks
- manage data privacy requests.
Our Disclosure of Information
- We will not disclose any Personal Data about any individual except as set forth in this Privacy Notice. This applies to information about our clients and information that our clients provide to us about their customers.
- We give access to your Personal Data only to those who require it for the above purposes.
- We will not share any of your Personal Data with third parties except in the limited circumstances described below:
- We share information with service providers under contract who help with our business operations, payment and order processing, IT and hosting, fraud investigation, bill collection, information management and analytics, providers of Customer Relationship Management, marketing and sales software solutions. If content generation is included in your Services, we may share information with service providers under contract to create, edit and/or publish such content. These third parties are obligated to protect your Personal Data and to use it only as necessary to provide these services to us.
- We may be required to disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified subscriber or limited group of subscribers, we will make reasonable business efforts to contact the subscriber(s) before providing information to the party that requests it.
- When a user signs up for a co-branded version of our Services through links to www.reputation.com or www.nuvi.com from our co-branded partner’s website, we will share with the co-branded partner that user’s name, e-mail address and physical address in order to provide enhanced integration between the Company’s services and the services of our co-branded partner. If you do not want your information shared with the Company’s co-branded partner, you should sign up for the Company’s Services directly through www.reputation.com and other sub-domains and not through a link from our co-branded partner’s website.
- We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- We may disclose your information to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
- We share your Personal Data with our parent company (Reputation.com, Inc.) and/or subsidiaries to provide products, services or support to you, in relation to our sales and marketing activities, to enforce our terms and conditions, and promote trust and safety.
- The implementation of our Services, by its very nature, may require publishing your Personal Data in order to post review responses, post on social media sites, etc. For example, we may have to disclose your name to a review website in order to post a response to a review.
- We disclose information as necessary to our subprocessor in order to fulfill the Reputation services purchased. See our list of subprocessors.
- The Company maintains two separate platforms, one hosted in the United States and one hosted in the European Economic Area (EEA). For the EEA platform, due to the unpredictable nature of Internet routing, your information may pass through other countries while in transit to our servers. Please read the “Additional Information For European and UK Individuals” section in this Privacy Notice for further information about the safeguards we implement when we transfer your Personal Data outside of the EEA and the UK.
International Transfers of Personal Data
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our servers are located in the United States and the EEA and our subsidiaries and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.
Additional Information for European and UK Individuals
- Scope. This section applies solely to individuals in the EU and the UK (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Our Privacy Notice describes why and how the Company and its subsidiaries collect, use and store your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights (please read “Your Rights” below) and our obligations are in relation to such processing under Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”).
- Data Controller. In cases when the Company collects or gathers information directly from you (see “The Information We Collect” above) and in relation to Personal Data obtained through the use of tracking technologies (described in our Cookie Notice), the Company is the data controller for processing your Personal Data. The data controller is responsible for deciding why and how Personal Data about you is used. Generally, the relevant Company entity with whom you interact acts as the data controller for your Personal Data. The Company is the data controller for Personal Data collected through your use of the Site, including the use of tracking technologies as described our Cookie Notice. Please see the “Contact Us” section below to find out how to contact us.
- Data Processor. In other cases, when services are being provided by the Company to its clients, who provide Personal Data to the Company to perform certain services, then the Company is a data processor for that Personal Data we process this data on behalf of clients pursuant to clients’ instructions set forth in our agreements with them. If you are a customer, client or patient of one of our clients and have questions about how your Personal Data is processed by that customer or would like to exercise your privacy rights, please contact that customer directly. For more information, please read the “Personal Data That We Receive From Our Clients” section below.
- Your Rights. Subject to applicable law, you have the following rights in relation to your Personal Data that we process as a data controller:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless such profiling is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise or defend legal claims; or
- If we are processing your Personal Data for direct marketing.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
- How To Exercise Your Rights. You may exercise the above-referenced rights by contacting us as indicated under “Contact Us” section below or by submitting a Data Protection Request using our Data Protection Request Form.
- Legitimate Interest. “Legitimate interests” mean our interests in conducting and managing our organization and delivering the best Services to you. This Privacy Notice describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” above.
- International Data Transfers. We have implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred outside the EEA and the UK which includes compliance with the Standard Contractual Clauses for the transfer of Personal Data as approved by the European Commission. Certain transfers of Personal Data to Reputation’s personnel outside of the EU, including but not limited to the United States and India, are also necessary to perform the agreement we have entered into, or are about to enter into, with you. For more information on the safeguards that we implemented for these transfers, please Contact Us
Additional Information for California Residents
Under the CCPA/CPRA, California residents have certain rights related to the Company’s collection, use, and sharing of their Personal Information.
If you are a resident of California, you have the following rights to your Personal Information under the CCPA/CPRA:
- Access to Specific Information and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the last 12 months. You also have the right to receive your Personal Information in a structured and commonly used format so that it can be transferred to another entity.
- Request Deletion. You have the right to request that we delete specific pieces of your Personal Information that we collected from you and retained, subject to certain exceptions.
- Request Correction. In certain circumstances, you have the right to request correction of any inaccurate Personal Information.
- Right to Opt-Out/Do Not Sell My Personal Information. While we do not sell Personal Information in exchange for monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale,” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)). We support the CCPA/CPRA and wish to provide you with control over how your Personal Information is collected and shared.
- Limit Use and Disclosure of Sensitive Personal Information. Company generally does not seek data that may be considered Sensitive Personal Information (“SPI”) (e.g., government-issued identification numbers or information related to an individual’s racial or ethnic origin, political opinions, religious or other beliefs, health, criminal background, or trade union membership) from visitors of this Site. Company requests that you do not provide us with SPI. If we specifically require the use of SPI, we will request your consent to use the data in accordance with this Privacy Notice and/or in the ways described at the point where you were asked to disclose the data. If you voluntarily share with us any SPI for any reason, you consent that we may use such data in accordance with applicable law and this Privacy Notice.
- Not to be Retaliated Against for Exercising Rights. Company will not discriminate against you for exercising any of the rights afforded to you under the CCPA/CPRA.
Separate from the CCPA/CPRA, California’s Shine the Light law gives California residents the right to ask companies what Personal Information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your Personal Information to third parties for the purpose of directly marketing their goods or services to you.
How to Exercise Your Right Under the CCPA/CPRA
- To exercise the access, data portability, deletion, correction, and restriction of SPI rights described above, please submit a verifiable consumer request to us by either of the following methods:
- using our Data Protection Request form; or
- Calling us and leaving a message at (877) 553-0616.
- Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We are required to verify your identity in order to process your request.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Response Timing and Format. We endeavour to respond to a verifiable consumer request within 45 days of its receipt, unless we need additional time, in which case we will let you know. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
- If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may: charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or refuse to act on the request and notify you of the reason for refusing the request.
- We value your privacy and will not discriminate in response to your exercise of privacy rights.
Any request to review, correct, update, change or delete your Personal Data with the Company depends upon where you are located. Complete our Privacy Request Form for more information.
If you use the Reputation platform, you can simply log into your account, go to your user profile, review your Personal Data and, if you wish, edit it with the options provided. If you are unable to edit your Personal Data by logging into your account, then please contact us for assistance. Customer Service is available to assist with this between 6:00 a.m. and 8:00 p.m. PST or you may email firstname.lastname@example.org.
- We will retain your information for at least as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. We may also keep your information for longer periods of time consistent with our normal business practices and record-keeping requirements. We will retain Personal Data we process on behalf of our clients for as long as needed to provide Services to our client.
- If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt-out of receiving these communications and in accordance with our policies.
- To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
Personal Data That We Receive From Our Clients
- The implementation of our Services may require our clients to share with us information about third parties such as their customers, clients or patients, including Personal Data such as names and email addresses or phone numbers. We treat such information confidentially and do not share it with any third parties, except as described above as necessary to perform our Services. Such information is maintained pursuant to our clients’ instructions and subject to our agreements with them.
- The use of Personal Data collected through our Services is limited to the purpose of providing the services for which our clients have engaged the Company.
- In connection with our Services, Reputation may receive Personal Health Information (PHI) voluntarily from our client’s customers through surveys or third-party sources and platforms. This information is not used to provide any services to our clients. It receives the same protection as other Personal Data in our platform. Visit our Security Posture page for more information.
- The Company collects and uses this information under the direction of its clients (as a data processor under the GDPR), and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our Service or would like to exercise your privacy rights, please contact the customer that you interact with directly (the data controller under the GDPR).
Visit our Cookie Notice page for more information.
The Site contains links to other sites that are not owned or controlled by the Company. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave the Site and to read the privacy statements of each and every website that collects personal data. This privacy statement applies only to information collected by the Site.
Third party sites that may be accessed by clients using the Services, include the following.
1. YouTube Terms of Service
3. Google Security Setting Page
4. Twitter Terms of Service
Choice and Opt-Out
- We provide you the opportunity to ‘opt-out’ of having your Personal Data used for certain purposes when we ask for this information. For example, if you purchase a product/service, but do not wish to receive any additional marketing material from us, you can indicate your preference in the Site’s account area.
- If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or completing a Privacy Request Form. We also offer an opportunity to opt-out of certain communications on the Site, via our user account area.
Desktop and Mobile App Disclosures
- When you download and use our Services, we automatically collect information on the type of device you use and operating system version.
- We may send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
- We use analytics software to allow us to better understand the functionality of our Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
We will use the information you provide to transmit text messages to you, under our Review Requesting Program. When you complete forms online or otherwise provide us the information in connection with the wireless message service, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If we, in our sole discretion, believe that any such information is untrue, inaccurate, or incomplete, we may refuse you access to the Service and pursue any appropriate legal remedies. See Wireless Terms of Service for more information.
Changes to Our Privacy Notice
You are responsible for regularly reviewing the Privacy Notice and related documents. We reserve the right to modify this Privacy Notice at any time and will publish such new Privacy Notice in advance of its applicable effective date.
If you have any questions about this Privacy Notice, or our practices with respect to your Personal Data, or your dealings with the Site, you can contact us at email@example.com, call us at (877) 553-0616 or write to:
Reputation.com, Inc./ Social Mecca, Inc. (dba NUVI)
Attention: Chief Privacy Officer
6111 Bollinger Canyon Road, Suite 500
San Ramon, CA 94583
Reputation.com (UK) Limited
ICO Registration Number ZA013179
Liverpool Innovation Park
360 Edge Lane
Fairfield, Liverpool, L7 9NJ
Reputation.com Germany GmbH
CAYA Postbox 799114