Effective Date: August 1, 2021
When we refer to “Replypad”, we mean the Replypad entity that acts as the processor or controller of your information, as explained in the “Identifying the Data Controller and Processor” section below.
Table of Contents:
- Information We Collect and Receive
- How We Use Information
- Data Retention
- How We Share and Disclose Information
- Age Limitations
- International Data Transfers: Privacy Shield and Contractual Terms
- Data Protection Officer
- Identifying the Data Controller and Processor
- Your Rights
- Data Protection Authority
- Contacting Replypad
Information We Collect and ReceiveReplypad may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:
- Customer Data. Customers or individuals with access to a Workspace (“Authorized Users”) routinely submit Customer Data to the Services.
Other Information. Replypad also collects, generates and/or receives Other Information:
- Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer or your vendor) supply Replypad with an email address, phone number, password, domain and/or similar account details. In addition, Customers provide Replypad and/or any third party that handles payment or billing aspects for Replypad, with billing details such as banking information, credit card information and/or a billing address.
- Usage Information.
- Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol address (IP), browser type and settings, the address of the web page visited before using the Website or Services, information about browser configuration and plugins, the date and time the Services were used, cookie data and language preferences.
- Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, Replypad logs the Workspaces, views, mailboxes, conversations, people, features, content and links you interact with, the types of files used, uploaded, downloaded or shared, and what Third Party Services are used (if any).
- Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device, or an address submitted by your employer or vendor to determine approximate location. Replypad may also collect location information from devices in accordance with the consent process provided by your device.
- Device information. Replypad collects information about devices accessing the Services, including type of device, device settings, what operating system is used, unique device identifiers, application IDs, and crash data. Whether we collect some or all of this Other Information many times depends on the type of device used and its settings.
- Third Party Services. Customer may choose to use or permit Third Party Services for their Workspace. Typically, Third Party Services are software that link to or integrate with our Services. Once enabled or used, the provider of a Third Party Service may share certain information with Replypad, including but not limited to email address of Authorized Users, along with additional information that the application has elected to make available to Replypad. Authorized Users should regularly check the notices and privacy settings in these Third Party Services to understand what data may be disclosed to Replypad. When a Third Party Service is enabled, Replypad is authorized to connect and access Other Information made available to Replypad in accordance with our agreement with the Third Party Provider. We do not, however, store or receive passwords for any of these Third Party Services when connecting them to the Services.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
- Third Party Data. Replypad may receive data about Website visitors, organizations, industries, marketing campaigns and other matters related to our business from parent corporation(s), subsidiaries and affiliates, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to countries, regions or zip codes. Or it might be more specific: for example, how well an email campaign or online marketing performed.
- Additional Information Provided to Replypad. We receive Other Information when submitted to our Websites or if you participate in an activity or event, a focus group, apply for a job, contest, request support, interact with our social media accounts or otherwise communicate with Replypad.
How We Use InformationCustomer Data will be used by Replypad in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Replypad is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, configure settings and assign roles, access, share, modify and remove Customer Data and otherwise apply its policies to the Services.
Replypad uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Replypad uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, technical or security issues, monitor and analyze trends, usage and other activities or at an Authorized User’s request.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features. Replypad tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may make Services suggestions based on predictive models and historical use, improve search functionality by using Other Information to help determine and rank the relevance of content or conversations to an Authorized User, identify organizational insights and trends, to customize a Services experience or create new productivity features and products.
- For account management, billing and other administrative matters. Replypad or third parties Replypad works with may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To send emails and other communications. We may send you technical, service and other administrative messages, emails and other types of communications. We may also contact you to let you know about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about promotional communications, new product features or other news about Replypad. These are marketing messages so you can control whether you receive them.
- To investigate and help prevent abuse and security issues.
- As required by applicable law, legal process or regulation.
How We Share and Disclose InformationThis section describes how Replypad may share and disclose Information. Customers determine their own policies and practices for the disclosure and sharing of Information, and Replypad does not control how they or any other third parties choose to disclose or share Information.
- Customer’s Instructions. Replypad will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or other Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile or their account profile.
- Customer Access. Owners, Authorized Users, administrators and other Customer personnel and representatives may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to review logs of Workspace activity, or accessing or modifying your profile details.
- Collaborating with Others. Authorized Users working in independent Workspaces may use the Services to collaborate. Other Information, such as an Authorized User’s profile Information, may be shared.
- Third Party Service Providers and Partners. We may engage third party individuals or companies as business partners or service providers to process Other Information and support our business. These third parties may, for example, provide storage and virtual computing services. More information about the subprocessors we use to support delivery of our Services is set forth at Replypad Subprocessors.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Replypad may share Other Information with Third Party Services. Third Party Services are not controlled or owned by Replypad and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
- During a Change to Replypad’s Business. If Replypad engages in a merger, acquisition, reorganization, dissolution, bankruptcy, sale of some or all of Replypad’s assets or stock, public offering of securities, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Corporate Affiliates. Replypad may share Other Information with its corporate affiliates, subsidiaries and/or parents.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with partners or prospects for business or research purposes, such as telling a prospective Replypad customer the average first time to reply to a conversation within a typical Workspace.
- To enforce our rights, for safety, and to prevent fraud. To protect and defend the rights, property or safety of Replypad or third parties, including enforcing policies or contracts, or in connection with preventing and investigating security issues or fraud.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we believe disclosure is in accordance with or required by any applicable law, legal process or regulation.
- With Consent. Replypad may share Other Information with third parties when we have consent to do so.
Age LimitationsTo the extent prohibited by applicable law, Replypad does not allow use of our Services and Websites by anyone younger than 18 years old. Please contact us if you learn that anyone younger than 18 has unlawfully provided us with personal data, and we will take steps to delete such information.
SecurityReplypad takes security of data very seriously. Replypad works to protect Other Information you provide from misuse, loss, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, store and process, and the current state of technology. To learn more about current security practices of the Services, please see our Security Practices. Given the nature of communications and information processing technology, Replypad cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
International Data Transfers: Privacy Shield and Contractual TermsReplypad may transfer your Personal Data to countries other than the one in which you live. Our procedures are inspired by the following safeguards if Replypad transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law: E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. These frameworks were developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to the United States.
Data Protection OfficerTo communicate with our Data Protection Officer, please email firstname.lastname@example.org.
Identifying the Data Controller and ProcessorData protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Replypad is the controller of Other Information and the processor of Customer Data. Skylix Ltd. dba Replypad, a company based in Tel Aviv, Israel, is the controller of Other Information and a processor of Customer Data relating to Authorized Users who use Customers’ Workspaces.
Your RightsIndividuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually achieve this using the tools provided in your Services account. If you cannot use such tools, contact Customer for assistance and additional access.
To the extent that Replypad’s processing of your Personal Data is subject to the General Data Protection Regulation, Replypad relies on its legitimate interests, described above, to process your data. Replypad may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Replypad’s use of your Personal Data for this purpose at any time.