Privacy Policy

We are pleased that you are visiting our website at www.reeply.ai. Data protection and data security when using our website and Chatbots are very important to us. We would therefore like to inform you which of your personal data we collect when you visit our website and use our chatbots and for what purposes it is used.

Who is responsible?

The person responsible in the sense of the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening gegevensbescherming) (“UAVG”) and the EU’s General Data Protection Regulation (“GDPR”) is Reeply BV, Sterreschansweg 77, 6522GL, Nijmegen, The Netherlands (“Reeply AI”, “we”, “us”, “our”).

If you have any questions about this policy or our data protection practices, please contact us using contact@reeply.net.

Principles of data processing

Personal data

Personal data is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, e-mail address, IP address or user behavior.

Processing

The processing of personal data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis.

Legal basis

In accordance with the UAVG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: i) you have given your consent, ii) the data is necessary for the fulfillment of a contract / pre-contractual measures, iii) the data is necessary for the fulfillment of a legal obligation, or iv) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Retention

Processed personal data will be deleted as soon as the purpose of the processing has been achieved and there are no longer any legally required retention obligations.

International Data Transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. Specifically, information collected in the European Economic Area (EEA) may be transferred to our third-party service providers, located in the United States. While the United States does not have the same data protection laws as those in the EEA, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers, which require all recipients to protect the personal data that they process from the EEA in accordance with European Union data protection law. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

We acknowledge that the transfer of personal data to countries outside the EEA carries certain risks, particularly where the destination country does not afford the same level of protection to personal data as within the EEA. To mitigate these risks, we have implemented measures to ensure that your personal data remains protected according to the standards described in this policy. This includes conducting thorough transfer impact assessments and enhancing our security measures for data in transit and at rest.

Data we collect

Provision and use of the website

When you call up and use our website, we collect the personal data that your browser automatically transmits to our server. This is technically necessary for us to display our website and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your computer as well as the name of your access provider. The legal basis is our legitimate interest.

Hosting

We use the hosting services of A2 Hosting for the purpose of hosting and displaying our website. A2 Hosting does so on the basis of processing on our behalf, and that also means that all data collected on our website is processed on A2 Hosting’s servers. The legal basis for processing is our legitimate interest.

Content Management System

We also use the Content Management System (CMS) of WordPress by Automattic Inc to publish and maintain the created and edited content and texts on our WordPress. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.

Data management and customer support

For optimal customer support, we use first name, last name, email address, and the data related to your contract with us. Your data may be stored on our website and or our proprietary customer relationship management system (“CRM system”). This data processing is based on our legitimate interest in providing our customer service.

Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the Dutch Telecommunications Act (Wet van 4 februari 2015 tot wijziging van de Telecommunicatiewet) (“TA”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

Cookie consent

Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest.

Economic analyses and market research

For business reasons, we analyze the data we have on business transactions, contracts, enquiries, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use Google Analytics and you can find more information about Google Analytics in our Cookie Policy. The legal basis is our legitimate interest and your consent.

Contacting Us

We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.

Contractual Services

We process the Personal Data involved when you enter into a contract with us in order to be able to provide our contractual services. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

Your end users and your Reeply Chatbot

When you design, integrate and configure your Reeply Chatbot we may also process Personal Data of your end users. The Personal Data processed by us depends on how you are using your Reeply Chatbot and the requests you and/ your end users are submitting. In this sense you have full control over how you and your end user are using our services, for example by using configuration options and settings, and the Personal Data that is processed by us. The personal data your end users provide as part of their Reeply Chatbot request, will depend on your configuration and may requires integration via an Inline Frame element (iframe) and the processing of your end users IP address and other personal data and will be processed for the purpose of responding to your end users request using the API services of OpenAI (utilizing OpenAI`s Enterprise Privacy). The legal basis is the provision of a contractual service. Further and in accordance with the UAVG and the GDPR we act as the Data Processor. Some jurisdictions may require you to disclose your use of your Reeply Chatbot as your processor in your privacy policy and/or data processing agreement as applicable.

Our Reeply Chatbots Services

As mentioned above, we process the Personal Data involved in your use of our Reeply Chatbot Services (“Service Data”) in order to be able to provide our services. We recognize that you own your Service Data and provide you with complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data.

Where we process Service Data as Data Processor or in other words on behalf of you, we will process the Service Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us.

We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

For the purpose of providing our Services all Service Data processed by us will be processed using Vercel on the Vercel network region eu-central-1 Frankfurt, Germany for hosting, and Clerk for user authentication and sign-ups as sub-processors and take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of your Service Data.

Support ticket

If you create a support ticket, we will request Personal Data and, where applicable, non-Personal Data in accordance with your request, this may include your name, email address and other order related data you voluntarily provide. The data provided is not shared with third parties and cannot read your data when it is entered. If you submit a support ticket, we process the data for the purpose of processing and handling your ticket.

Our employees will also have access to data that you knowingly share with us for technical support or to import data into our services. We communicate our privacy and security guidelines to our employees and enforce privacy safeguards strictly. The legal basis of the data processing is our obligation to fulfill the contract and/or our legitimate interest in processing your support ticket.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Payment Data

If you make a purchase your payment will be processed via our payment service provider Stripe. Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.

Promotional use of your data

We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.

Economic analyses and market research

For business reasons, we analyze the data we have on business transactions, contracts, enquiries, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose we use both Google Analytics and you can find more information about Google Analytics in our Cookie Policy. The legal basis is our legitimate interest and your consent.

Data Security

We undertake to protect your privacy and to treat your Personal Data and Service Data confidentiality. In order to prevent manipulation or loss or misuse of your data stored with us, we take extensive technical and organizational security precautions which are regularly reviewed and adapted to technological progress. These include, among other things, the use of recognised encryption procedures (SSL or TLS).



However, we would like to point out that, due to the structure of the Internet, it is possible that the rules of data protection and the above-mentioned security measures are not observed by other persons or institutions that are not in our area of responsibility. We have no technical influence on this. It is the user’s responsibility to protect the data he or she provides against misuse by encrypting it or in any other way.

Marketing

Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission, or sometimes your consent is implied from your interactions or contractual relationship. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Our Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent by us or on our behalf will include a means by which you may unsubscribe or opt out.

We use the services of ActiveCampaign to send our Newsletter and if you subscribe we will use your email address to send you information about products, promotions, news and customer satisfaction surveys. You can find an unsubscribe link at the end of each newsletter. The legal basis is your consent.

Advertising

We would like to show you interesting advertising outside of our website and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our website – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our website, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our website.

We also analyze this data to evaluate the relevance of the advertisements and to optimize the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our website. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our website (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies. For further information, please refer to our Cookie Policy.

Social Media

General

We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.

Market research and advertising

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. You can find more information about our advertising on social media in our Cookie Policy. The legal basis is our legitimate interest.

When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

How we may share your Personal Data

We may share your Personal Data with our Business Partners for the purposes described in this Privacy Policy, including (but not limited to) conducting the services you request, or customizing our business to better meet your needs. We share your Personal Data only with Business Partners who agree to protect and use your Personal Data solely for the purposes specified by us.

We may also disclose your Personal Data for any purpose with your consent or for law enforcement, fraud prevention or other legal actions as required by law or regulation, or if we reasonably believe that we must protect us, our customers or other business interests. Except as described above of which you will be informed in advance, we will not disclose your Personal Data.

What we do not do

We do not request Personal Data from minors and children;

We do not use Automated decision-making including profiling; and

We do not sell your Personal Data.

Privacy Rights

Under the UAVG and the GDPR, you can exercise the following rights:

Right to information

Right to rectification

Right to deletion

Right to data portability

Right of objection

Right to withdraw consent

Right to complain to a supervisory authority

Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information and withdrawing your consent

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing or want to withdraw any consents you have given us, please contact us.

Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the Netherlands is: The Autoriteit Persoonsgegevens (www.autoriteitpersoonsgegevens.nl). However, we would appreciate the opportunity to address your concerns before you contact the Autoriteit Persoonsgegevens or any other supervisory authority.

Validity and questions

This Privacy Policy was last updated on Wednesday, 17th January 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary. If you have any questions or comments about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us using the details provided above.