- Reputation.com, Inc. and its subsidiaries, including Social Mecca, Inc. (“Nuvi”), (“Reputation.com,”, the “Company” or “we”, “us”, and/or “our”) are committed to protecting the privacy of individuals who visit our website, and those individuals and businesses who purchase or use our products and services. This Privacy Notice describes Reputation.com’s privacy practices in relation to the use of our website and the related applications and services offered for sale by Reputation.com and your choices about how we use personal data about you.
- We collect and use personal data to operate effectively and provide you the best experiences with our services. We only use your personal data where we have a proper legal basis for doing so.
- We do not sell, give, rent or trade your personal data to third parties, including advertisers, marketers or spammers.
- We store your personal data only so long as we need it to provide our services to you and fulfill the purposes described in this Privacy Notice.
- If you provide personal data to us about your customers, clients or patients, we will keep that personal data confidential and will use it only as necessary to provide the services you have purchased. We will share such personal data with third parties only for purposes of assisting us in providing our services and only with appropriate confidentiality agreements and protections in place. We will not sell or give such personal data to third parties, including advertisers, marketers or spammers.
- We take the security of your personal data seriously, and use industry standard safeguards to protect any personal data stored on our systems.
- In connection with your use of our services, we transfer personal data from the European Economic Area (EEA), the United Kingdom (UK) and Switzerland to Reputation.com, Inc. in the United States (U.S.). We rely on the European Commission’s Standard Contractual Clauses as a legal mechanism for these transfers. Moreover, certain transfers of your personal data from the EEA and the UK to Reputation.com, Inc. in the U.S. are necessary to perform the agreement we have entered into, or are about to enter into, with you.
- We are not responsible for the privacy practices of any websites linked to our site if they are not controlled or owned by Reputation.com. Please be diligent when visiting any other websites.
- We like to send you information and updates via email but you are welcome to opt out of receiving this information at any time. We will ask your prior consent if required by the law of the country in which you are located.
- This Privacy Notice is legally binding and may be updated from time to time.
- If you have any questions about this Privacy Notice, you may contact us at email@example.com.
Effective August 1, 2021
ABOUT OUR PRIVACY NOTICE
- Reputation.com, Inc. and its subsidiaries, including Social Mecca, Inc. (“Nuvi”), (“Reputation.com,” the “Company” or “we”, “us”, and/or “our”), have created this privacy statement (“Privacy Notice”) in order to demonstrate our firm commitment to your privacy and to be transparent about our policies and practices in order to protect your privacy as you visit the Reputation.com website and/or use our mobile applications, and associated sub-domains (collectively, the “Site”) and in relation to your use of our Site and the related applications and services offered by us (together with the Site, “Services”).
- In this Privacy Notice, “Personal Data” (or “Personal Information” under the CCPA) 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 Reputation.com 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.
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.com 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. Nuvi collects 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 Nuvi, the information necessary to contact you such as company name, company email, personal email, address, phone number, and other necessary information will be required. When purchasing products or services, Nuvi will require financial billing information, such as billing name and address, and credit card number. At user’s request, Nuvi will access and store authentication credentials, and other user data required by Nuvi 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 analyze trends in the aggregate and administer the Site.
- We also collect information regarding your use of this Site via tracking technologies. (See “Tracking Technologies” below.)
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 customers, it is necessary for the performance of the contract between you and the applicable Reputation.com entity with whom the contract is executed.
Special Offers and UpdatesUsing your name and email address, we may send you information on products, services, discounts and promotions related to Reputation.com. You can sign up for these emails on our registration page during the registration process. Out of respect for your privacy, we present you with the option not to receive these types of communications each time we send you such 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).
Public ForumsThe 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 firstname.lastname@example.org.
Social Media WidgetsOur 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 DataWe 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
- (a) respond to requests from public and government authorities including public and government authorities outside your country of residence; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) allow us to pursue available remedies or limit the damages that we may sustain
- If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing
OUR DISCLOSURE OF INFORMATION
- Reputation.com will not disclose any Personal Data about any individual except as set forth in this Privacy Notice. This applies to information about our customers and information that our customers provide to us about their customers.
- We give access to your Personal Data only to those who require it for the above purposes.
- Reputation.com will not sell or rent any of your Personal Data to third parties. Reputation.com 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 CRM, 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 Reputation.com.
- 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 Reputation.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 Reputation.com’s services and the services of our co-branded partner. If you do not want your information shared with Reputation.com Inc.’s co-branded partner, you should sign up for Reputation.com directly through www.reputation.com and other sub-domains and not through a link from our 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. This occurs with your express permission for a specific, given purpose.
- 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 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 DATAYour 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 Website 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 Reputation.com 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 Reputation.com collects or gathers information directly from you (see “Information We Collect” above) and in relation to Personal Data obtained through the use of tracking technologies (described in the “Tracking Technologies” section below), Reputation.com 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 Reputation.com entity with whom you interact acts as the data controller for your Personal Data. Reputation.com, Inc. is the data controller for Personal Data collected through your use of the Site, including the use of tracking technologies as described below. Please see the “Contact Us” section below to find out how to contact us. In other cases, when services are being provided by Reputation.com to its customers, who provide Personal Data to Reputation.com to perform certain services, then Reputation.com is a data processor for that Personal Data and we process this data on behalf of customers and pursuant to customers’ instructions set forth in our agreements with them. If you are a customer, client or patient of one of our customers 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 Customers” 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 found here
- 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 to the U.S., including primarily Standard Contractual Clauses for the transfer of Personal Data as approved by the European Commission. Certain transfers of Personal Data from the EEA and the UK to Reputation.com, Inc. in the U.S. are also necessary to perform the agreement we have entered into, or are about to enter into, with you. As noted above, the Reputation maintains a separate platform to provide its services that is hosted on the Google Cloud Platform in the EU and can accommodate requests that all of your Personal Data remain in the EU. For more information on the safeguards that we implemented for these transfers, please Contact Us.
CALIFORNIA RESIDENTS: PRIVACY RIGHTS UNDER THE CCPA
- Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around Reputation.com’s collection, use, and sharing of their Personal Information.
- If you are a resident of California, you have the right to know what Personal Information has been collected about you, and to access that information. You also have the right to request deletion of your Personal Information, though exceptions under the CCPA may allow Reputation.com to retain and use certain Personal Information notwithstanding your deletion request.
- You also have the right to request that Reputation.com not sell your Personal Information. Reputation.com does not sell your Personal Information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your Personal Information.
- Separate from the CCPA, 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
- To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either of the following methods:
- using our Data Protection Request form found here; 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 also make a verifiable consumer request on behalf of your minor child. 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 endeavor 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.
- We value your privacy and will not discriminate in response to your exercise of privacy rights.
UPDATING INFORMATIONUpon request, Reputation.com will provide you with information about whether we hold any of your Personal Data. You may review, correct, update, change or delete your Personal Data on your Reputation.com account profile at any time. Simply log into your Reputation.com 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 email@example.com. If you wish your Personal Data to be deleted from our database, you may email your request to firstname.lastname@example.org. The process of removing information may take up to 30 days.
- 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 CUSTOMERS
- The implementation of our Services may require our customers 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 customers’ instructions and subject to our agreements with them.
- The use of Personal Data collected through our Services will be limited to the purpose of providing the services for which our customers have engaged Reputation.com.
- Reputation.com collects this information under the direction of its customers (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). We may transfer Personal Data to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our customers.
- The security of your Personal Data is important to us. If you provide sensitive information, such as credit card number, we encrypt that information using secure socket layer technology (SSL).
- The Personal Data that we collect, and that you provide, is stored by us is and contained behind a “firewall” and only accessible by those who need to know that information and who have special access rights to our production systems. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information.
- We test our security systems regularly and also contract with outside companies to test our security systems and processes. However, no security system is perfect. We do not guarantee or warrant that there will be no unauthorized access to your data.
- We will make all reasonable business efforts to protect your information, but no system can prevent all malicious attacks against our system or commonly used Internet protocols or software (e.g., SSL). Please see our technical pages for more information about the security systems used.
- The security of your Reputation.com and/ or Nuvi account also relies on your protection of your chosen password. You are responsible for maintaining the security of your password. You are solely responsible for any and all activities that occur under your account. You should not share your Reputation.com password with anyone.
- We will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the Site, which will always have a URL beginning with https://www.reputation.com or https://www.nuvi.com. If you receive an email that asks you for your log in information or password, it is not from us and you should not respond.
- Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with the URLs noted above should be treated as unauthorized and suspicious and should be reported to Reputation.com immediately by emailing email@example.com.
- If you do share your Reputation.com password with a third party for any reason, the third party will have access to your account and your Personal Data, and you may be responsible for actions taken using your password.
- If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings. If you believe that an unauthorized access has already occurred please report it immediately by emailing firstname.lastname@example.org.
- Reputation.com may have access to your password and may use such password to access your account for debugging, quality assurance, or other internal purposes.
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 by emailing us at email@example.com. We also offer an opportunity to opt-out of certain communications on the Site, via our user account area.
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 mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. 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 do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.