1. Important Information
1.1. General terms
At Reply App Inc. (“Reply,” “we,” “us” or “our”), putting our users (“you” or “your”) first means exceeding global privacy and data protection standards in order to keep important contacts and sensitive data and communications private, safe and secure.
We set up our infrastructure, applications, and tools in a way that enables you to strengthen and leverage your important relationships when they matter the most, without having to worry about data security or privacy concerns.
Our Privacy Promise:
- No one will access, read, or delete your emails.
- When Reply connects to your email server, we pull only the minimum amount of information required for our service to function.
- Our server only stores emails you have sent via Reply and any responses you received to those emails, so we can detect replies and you can have access to them from the application.
- You own your data.
- Your personal data will be kept private according to this policy and to the greatest extent allowed by the law.
Additional questions? Don’t hesitate to send us an email at firstname.lastname@example.org
For the purpose of this Policy, “Personal Information” means information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual.
For the purpose of this Agreement, “Services” refers to the Company’s website which can be viewed or accessed at www.reply.io (“Website”), our applications or any other services that we may supply to you which are further described in our Terms of Service.
By accepting our Policy and our Terms of Service, you expressly consent to our collection, storage, processing, use and disclosure of your Personal information as described in this Policy.
In case your organization acts as a data controller under ‘General Data Protection Regulation (EU) 2016/679’ of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data you will need to sign or agree to an additional Data Processing Agreement with Reply in order to process data in our Services.
Reply complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. See the section entitled EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield, below, for further information.
Reply reserves the right to revise, modify or update this Policy at any time. Your continued use of the Services after any such revisions, modifications or updates constitutes your acceptance of any such change.
2. Use of our services
2.1. Our customers use
You can use the Services to create communication campaigns in order to reach out to or nurture prospects with sales, marketing or customer success purposes.
Reply does not control the content of campaigns (text, email or other communications templates) or the types of information that our customers may choose to collect or manage using the Services.
Reply processes our customers' information as they direct and in accordance with our agreements with our customers, and we store it on our service providers' servers, but we do not have control over its collection or management.
We have no direct relationship with individuals who provide Personal Information to our customers.
Reply acknowledges that you have the right to access your Personal Information.
You control and are responsible for correcting, deleting or updating the information they have collected from you using the Services.
If requested to remove data we will respond within a reasonable timeframe.
We may work with you to help them provide notice to their visitors about their data collection, processing, and usage.
Our agreements with your customers prohibit usage of the Services to collect, manage, or process Sensitive Information.
We are not responsible for your customers' use of information on the Services.
Reply collects information under the direction of its customers and has no direct relationship with the individuals whose Personal Information it processes.
If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our Services, please contact the customer that you interact with directly or leave a request on our Trust page.
We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the processing agreements with our customers.
2.2. "Sensitive Information"
This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.
Also, sensitive information includes credentials to Reply application services or email accounts (Google or other providers) that are connected to Reply application.
3. Information We Collect
When you provide Reply with your Personal Information you consent to our providing your information to any third parties that are necessary to offer, support and improve the Services.
Reply also collects Personal Information from you when you place an order including your name, physical address, email address. Reply only uses this data for the purpose of fulfilling orders or communicating with you and Reply’s partners regarding the Services.
3.1. When You Visit our Website
You are free to explore our Website without providing any Personal Information about yourself. Reply collects your Personal Information when you register and open an account with Reply to help us operate and support the Services and to contact you in connection with your use of the Services. Also, we collect navigational Information.
3.2. "Personal Information"
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.
Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.
3.3. "Navigational Information"
This refers to information about your computer and your visits to and use of the Services such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, to verify users have the authorization needed for the Services to process their requests, and for advertising purposes.
For more details please see the "Navigation Information" section below.
3.4. Payment Information
We collect and process payment information from you when you subscribe to the Service, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.
3.5. Information About Children
The Websites and our Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at email@example.com, so that we may delete the information.
3.6. Information You Provide
You may also provide us with information that you post to the Services. Your questions, answers, and other contributions on the Services, and metadata about them (such as when you posted them), are publicly viewable on the Services. This information may be found by search engines and be published elsewhere on the web in accordance with our Terms of Service and this Policy.
3.7. Disclosure regarding information received from Google APIs
Reply.io use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
3.8. Google User Data
If you choose to connect a Gmail account to Reply, we will ask you to grant Reply application permissions to access your Gmail account. These permissions are necessary to sustain the functionality of our Services, as intended and described in the Terms of Service. In particular, we will need to access your inbox folder to detect replies to emails that have been sent via Reply.
Our servers only store emails that you have sent via Reply and any responses you have received to those emails so we can detect replies, classify them, and provide access to them in your Reply account. All data obtained via Gmail API is available in your Reply account.
Also, we will store your authentication token and account email address. This data will be securely stored to be used by Reply to provide you with the Services (including but not limited to logging into your account, sending emails via the Reply platform, accessing emails you sent, and viewing replies you received to these emails). Under no circumstances will this data be voluntarily shared with any third parties; Reply could only provide this information to legal authorities upon their lawful request. Should you choose to disconnect your Gmail account or decide to close your account, any information from Google that is stored on our servers will be removed permanently.
At Reply, we do not use data obtained from our customers (from their Google accounts) for advertising purposes; this includes personalized, re-targeted, and interest-based advertising.
Our employees, contractors, and any human, in general, are not allowed to access your personal information, including the data obtained via Google API. We could access user data only after obtaining the user's affirmative agreement. We may need access to the user data to resolve a support issue, provide advice on service usage or provide any other help, requested by the user. Also, we can access such information when/if necessary for a security investigation or comply with applicable laws.
To obtain more information, please reach out to our Data Protection Officer (firstname.lastname@example.org).
3.9 Web beacons
We may also collect information using web beacons (also known as "tracking pixels").
4. Use of Information We Collect
4.1. We do not sell Personal Information
We do not sell your Personal Information to any third party.
4.2 Navigational data, cookies and web beacons.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Reply Services.
Web beacons are electronic images (also called "gifs") that may be used in the Reply Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
You can decline to show gifs or pictures in your email clients to avoid being tracked by email web beacons.
Also we use Navigational Information to operate and improve the Services.
4.3 Use of Personal Information
(a) improve your browsing experience by personalizing and improving the Services;
(b) send information to you which we think may be of interest to you by post, email, or other means;
(c) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, and
(d) provide other companies with aggregated and Non-Personal Information about our users — but this information will not be used to identify any individual user,
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party.
In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your personal information with these companies, contact us at email@example.com.
We use the information collected/stored via our Services by our customers for the following purposes:
(a) to provide the Services (which may include the detection, prevention, and resolution of security and technical issues);
(b) to respond to customer support requests;
(c) otherwise to fulfill the obligations under the Reply Terms of Service.
4.5. Customer Testimonials and Comments
We post customer testimonials and comments in our Services, which may contain Personal Information. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
4.6. Use of Credit Card Information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
4.7. Service Providers
We employ other companies and people to provide services to the visitors and users of the Services and we may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive or invalid information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such third parties, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.
4.8. Confidentiality and Security of personal information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.
All the Personal Information we have where Reply acts as a processor for a customer's data (e.g., use of the Reply Services) is encrypted via database encryption. All connections to our Website or Services are protected via the use of encrypted connections, such as the Secure Socket Layer (SSL) protocol.
Also we do store all email accounts or email accounts passwords we use to provide our services via your email servers encrypted.
Do not forget that your account in Reply service is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and keep it long and complicated enough and by logging out of your account after each use.
If you have any questions about the security of your Personal Information, you can contact us at firstname.lastname@example.org.
4.9. Social Media
4.10. External Websites
4.12. Retention of Personal Information
We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information.
We will delete this information from the servers at an earlier date if you so request, as described in "Opting Out and Unsubscribing" below.
If you provide information to our customers as part of their use of the Reply Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Service, then we will provide a customer with access to all information stored for the customer by the Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Reply Service.
4.13. International Transfer of Information
All our employees and contractors related to working with personal data as part of their duties are signed agreements that cover Reply and their responsibility regarding the transfer of data to remote working locations other than the United States.
4.14. Sharing with Third-party applications
Certain aspects of the Reply Service allow or require you to connect with third-party applications or services. In connection with your use of any such third-party applications or services, such third parties may receive information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary.
The Reply Service may automatically collect and upload certain data from such applications via direct integrations or proxy services.
4.15. Compelled Disclosure
Reply reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and security breaches, or comply with a law, court order, or legal process.
4.16. Data retention
After Reply account cancellation all the data within this account are due to be deleted in 60 days period time.
At the same time, personal data of customers could be retained longer as it needed for providing a legal and financial trace of past operations up to the time required by US law.
5. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
5.1. Commitment to Privacy Shield Frameworks
Reply is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Reply acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them. An EU or Swiss individual who seeks to access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
Our accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles.
In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles unless we prove that we are not responsible for the event giving rise to the damage.
We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We encourage European individuals (including Swiss individuals) to contact us should you have a Privacy Shield-related (or general privacy-related) complaint at email@example.com. Or via our Trust page.
Independent recourse mechanism
In compliance with the Privacy Shield Principles, Reply commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Reply at:
Reply has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
6. Opting Out and Unsubscribing
6.1. Reviewing, Correcting and Removing Your Personal Information
Upon request Reply will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:
- To review the user information that you have supplied to us
- To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
- To request that your user information not be used to contact you
- To request that your user information be removed from any solicitation list that we use
- To request that your user information be deleted from our records
- To opt out of being solicited by Reply or third parties
- To exercise any of these rights, please contact us at firstname.lastname@example.org. Or via our Trust page. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
6.2. Anti-Spam Policy
We at Reply committed to providing customers with tools and expertise to curate highly targeted and relevant communications via our platform. We monitor and prohibits the use of the Reply Service to send unsolicited commercial email in violation of applicable laws as stated in our Terms of service, and requires the inclusion in every email sent using the Service of an "opt-out" mechanism and other required information.
We require all of our customers to agree to adhere to the Terms of Service Policy at all times, and any violations of the Terms of Service Policy by a customer can result in suspension or termination of the Reply Service.
We also provide customers with the tools to manage their sending reputation and customer success team work closely to monitor all customer metrics and best-practices to ensure high quality and targeted campaigns.
6.3. To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, or by sending us an email at email@example.com. Customers cannot opt-out of receiving transactional emails or notifications related to their account with us or the Reply Service.
6.4. To Unsubscribe from Our Customers' Communications
Our customers are solely responsible for their own sales or marketing emails and other communications;
We make sure that all emails sent using Reply service have proper unsubscribe mechanics (links or text + AI sorting + Auto opt-out).
You can unsubscribe from our customers' communications by clicking on the "unsubscribe" link located on the bottom of their emails, responding to unsubscribe via email or by contacting them directly.