Effective from: 25 May 2018
This is the privacy and cookies policy for www.replymanager.com and our associated services both online and offline as well as through email communications that we send to you (together, the Site). The Site is operated by xSellco Limited (we, us and our). “You” or a “user” refers to any individual who visits or otherwise uses the Site, you are accepting and agreeing to the practices outlined in this privacy and cookies policy.
For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and any other applicable laws, as may be amended from time to time, we are the Data Processor and you are the Data Controller.
We are committed to protecting your privacy online. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have.
We may collect and process the following information about you:
Information (such as your name, title, company name, email address, job function or position, social media details, postal address and telephone number) that you provide by completing forms on the Site, including if you register as a subscriber, customer or affiliate to any service, request any information, or enter into any competition or promotion we may sponsor;
IP Address which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP); this may be identified and logged automatically in our server log files whenever you access the Site, along with the time of the visit and the page(s) that you visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses to calculate usage levels of the Site, help diagnose problems with its servers, administer the Site, and monitoring the regions from which you navigate to our Site;
in connection with an account sign-in facility, your log-in and password details;
details of any transactions made by you through the Site;
communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site or its content; and
information from surveys that we may, from time to time, run on the Site for research purposes, if you choose to respond to, or participate in, them.
We only use your personal data in relation to the services/products that we provide, also where we need to comply with a legal or regulatory obligation, and where it is necessary for our legitimate business interest. Non-personal information is data about usage and service operation that is not associated with a specific personal identity. xSellco collects and analyses non-personal information to evaluate how visitors use the xSellco websites.
Any personal information which you provide to us will be treated strictly in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) and any other applicable laws.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.
Other Information is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation of the Sites and for other purposes described below.
We and our service providers may collect information in a variety of ways, including:
Through the Site: We may collect information through the Site, e.g., when you request a free trial or demo, register for a webinar, contact us, subscribe to our email newsletter, download content (e.g. ebooks), or register to use our Site.
Offline: We may collect information from you offline, such as when you attend one of our events, during phone calls with sales representatives, or when you contact customer service.
Through You: xSellco may collect information such as your location or your preferred means of communication when you voluntarily provide it. Note that there is no legal obligation for you to provide us with personal information and any information collected by us will be provided by you at your own will and with your consent.
Information From Other Sources: In order to enhance our ability to provide relevant marketing, offers, and services to you, we may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, as well as from other third parties.
Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Site (such as the Apps) you are using.
Through Your Use of the apps: When you download and use an app of xSellco’s, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number.
Through Cookies and Other Similar Technologies: Cookies and other similar technologies may be used to collect information. We may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Site and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags and web beacons). Please refer to the cookies section below for more information. xSellco may not recognize automated browser signals regarding tracking mechanisms, which may include 'do not track' instructions.
xSellco also uses web analytics services, which currently include Google Analytics. xSellco also uses Google AdWords.
When you interact with the Site, we try to make that experience simple and meaningful. When you visit the Site, our web server sends a cookie to your computer. Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the Site. For example, cookies are used to personalise web search engines and to store shopping lists of items a user has selected while browsing through a virtual shopping mall. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer.
Remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;
Customise elements of the promotional layout and/or content of the pages of the Site;
Collect statistical information about how you use the Site (including how long you spend on the Site) and where you have come to the Site from, so that we can improve the Site and learn which parts of the Site are most popular with visitors; and
to speed site navigation and recognise your access rights on the site.
Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting https://en.wikipedia.org/wiki/HTTP_cookie which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies used on the Site, you may not be able to take full advantage of the Site.
Cookies used by xSellco can be largely categorised as follows:
These cookies are essential in order to enable you to move around websites and use the websites’ features, such as accessing secure websites or secure areas of websites. Without these cookies, services you have asked for, such as identifying you as being logged in to the Site throughout your visit, cannot be provided.
These cookies allow the Site to remember choices you make (such as your preferred language) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. Other examples include cookies that keep track of your progress when filling online application forms.
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. xSellco uses both first and third party analytics cookies for this purpose.
Targeting cookies remember individual websites you have visited and help xSellco to present relevant and targeted online advertising to you. Targeting cookies may be placed on your machine when you visit the Site. When targeting cookies have been placed on your device, they can be recognised by subsequent websites you visit, and this allows those sites to present targeted xSellco and third party advertising to you. While targeting cookies can track your visits around different websites, the information collected is anonymous.
In addition to cookies, tracking Gifs and web beacons may be set by us or third parties in respect of your use of the Site. Web beacons support the delivery of cookies and help determine the number of times a page on the site has been viewed. Tracking Gifs are small image files within the content of the Site or the body of our newsletters so we or third parties can understand which parts of the Site are visited and whether particular content is of interest.
Some cookies that have been set on our websites are not related to xSellco. When you visit a page with content embedded from a third party such as YouTube, Twitter or Facebook, these service providers may set their own cookies on your web browser.
We may disclose aggregate statistics about visitors to the Site, customers and sales in order to describe our services to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifiable information.
We may also disclose your personal information to any of our affiliates, or to our agents or contractors who assist us in providing the services we offer through the Site, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
Where you consent, we may share your information with other related parties and any entity who is under common control. In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
We may disclose your personal information if required to do so by applicable law, lawful government requests or if we believe that such action is necessary to prevent fraud or cyber crime to operate our systems properly or to protect the Site, or the rights, property or personal safety of xSellco or any person.
We may provide links to third-party websites as part of the services we provide on this site. xSellco is not responsible for the content of external websites, or for their privacy policies.
How xSellco uses your information
xSellco uses your personal information to provide you with products or services and to help us better understand your needs and interests. Specifically, we use your information to help you complete a transaction or order, to communicate with you, to provide service and support, to update you on services and benefits, to personalize promotional offers and to personalize some xSellco websites. Occasionally we may also use your information to contact you for market research regarding xSellco products or services. We will give you the opportunity to choose your privacy preferences regarding such communications.
Credit card information is used only for payment processing and fraud prevention. Credit card information and sensitive personal data are not used for any other purpose by our financial services provider or xSellco, and will not be kept longer than necessary for providing the services, unless you ask us to retain your credit card information for future purchases.
Non-personal data is aggregated for reporting about xSellco website usability, performance and effectiveness. It is used to improve the customer experience, usability and website content.
Where third parties are involved, we require them to respect the security of your personal data and to treat it in accordance with applicable legislation.
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites
We place great importance on the security of all personally identifiable information associated with our users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information.
In the event of any suspected security breach involving personal data we have procedures in place to deal with any incidents.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.
It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.
In accordance with relevant financial and data statutory obligations we are required to retain basic information about you for a period of six years.
Information that you submit via the Site is sent to and stored on secure servers located in the United States and in the EEA. Information submitted by you may also be transferred by us to our other offices and/or to the third parties mentioned in the circumstances described above (see Information sharing), which may be situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The countries concerned may not have similar data protection laws to the EEA. Where we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected. By submitting information via the Site, you agree to this storing, processing and/or transfer.
When you complete our registration forms or use our services, we may transfer your information to processors outside the European Economic Area but will do so with appropriate measures and controls in place to protect that information in accordance with applicable data protection legislation.
When you give us information about another person, you confirm that they have appointed you to act for them and agreed to the transfer of their information abroad.
Under GDPR your rights are as follows:
The right to be informed
You must agree to your information to be processed for purposes you are aware of before it can be processed. You can do this by indicating your consent when providing the information.
The right of access
You may request a copy of all personal data we hold on you in our role as data controller. If you have an account, you can access this information via your profile. If you do not have an account, you can do this by sending us an email to firstname.lastname@example.org
As well as your personal data, we’ll provide you with:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed;
the envisaged period for which the personal data will be stored;
your rights, as laid out in this policy;
the right to lodge a complaint with a supervisory authority;
the source of the data
any automated decision-making in use on your data, including the logic involved, as well as the significance and the envisaged consequences.
The right to rectification
You have the right to have your data rectified, for example, if it is incorrect or incomplete. You can exercise this right by logging in to your profile. If you do not have an account or wish to amend other data, you can do this by sending an email to email@example.com
The right to erasure
You may exercise your right to withdraw consent or to request erasure of personal data by logging into your profile and deleting it. If you do not have an account or wish to delete specific data, you can do this by sending an email to firstname.lastname@example.org.
Please note that the deletion may not affect an ongoing recruitment process where the employer has already received the data as part of the recruitment process.
The right to restrict processing
You can request that we keep your data but do not process it further. You can do this by sending an email to email@example.com
The right to data portability
You can request a copy of the information you’ve provided to us in a commonly used format. You can exercise this right by logging in to your profile or by sending an email to firstname.lastname@example.org.
The right to object
You have the right to object to the use of your data for direct marketing purposes and profiling, should such profiling take place in the scope of direct marketing or our legitimate interest.
Rights in relation to automated decision making and profiling
You have the right to not be subject to entirely automatic profiling algorithms. If any such algorithms are used, you have the right to know details of their operation. You can request information about any automated profiling algorithms by sending email to email@example.com.
More information on data privacy rights is available directly from the Irish Data Protection commissioner.
Chief Financial Officer
Two Haddington Buildings
xSellco will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
We may change this policy at any time. Please refer to the “Last Updated” date at the top of this page to find out when this policy has been last amended.
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