Repub Interactive Technologies, LLC.
Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How to access and control your information
- How we transfer information we collect internationally
- Other important privacy information
RePubIT, we, and us refers to Repub Interactive Technologies, LLC. We provide a content management and delivery platform that includes a range of services, including but not limited to digital editions, mobile and responsive editions, certain reader registration and subscription features, and email notification services. We refer to all of these products and services collectively as “Services” in this policy.
This policy sets forth in detail the following general principles that we apply to the processing of your personal information or data as a user of the Services. These principles include:
- Your personal information will be processed lawfully, fairly, and in a transparent manner;
- We collect and store personal information only for specified, explicit, and legitimate purposes;
- The personal information we request from you is adequate, relevant, and limited to what is necessary to provide the Services;
- The personal information we collect and store is accurate and kept up-to-date and, if found to be inaccurate, will be updated without delay as soon as we are notified;
- We collect and store personal information for no longer than is necessary to provide the Services and protect our legitimate interests;
- We process personal information with integrity and confidentiality and in a manner that ensures appropriate security of the information; and
- We will be accountable and responsible for complying with this policy.
This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
Where we provide the Services under contract with an organization (for example, your employer or a RePubIT Value Added Reseller) that organization controls the information processed by the Services. For more information, please see Notice to End Users below.
1. WHAT INFORMATION WE COLLECT ABOUT YOU
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.
A. Information you provide to us
Account and Profile Information: We collect information about you when you register for an account, create or modify your account settings, set preferences, or sign-up for certain Services. For example, when you register, we will collect your name, company name, address, phone number, and email. You may also link your account to third party services, like PayPal, Google Analytics, Google Tag Manager, DoubleClick for Publishers, or social media accounts, which may require you to provide us with certain limited information (like an I.D.) to identify (but not login) to your account.
Content you provide through our products: The Services include RePubIT’s content delivery platform, where we collect and store content that you publish to readers. This content includes any information about you that you may choose to include. Examples of content we collect and store include: 1) PDF content you upload to RePubIT; 2) video, audio, interactive, and animation files you upload to RePubIT; 3) content directly inputted into the Services for publishing to readers, like articles, author information, images, and product information; and 4) registration or subscription lists you upload to RePubIT.
Content you provide through our websites: The Services also include our websites owned or operated by us. We may collect content that you submit to these websites, which include social media or social networking websites operated by us. For example, you provide content to us when you participate in any interactive surveys, communicate with us through social media, or sign up for gated marketing content.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with the Service. Whether you engage in live chat, open a support ticket, speak to one of our representatives directly, or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots, or information that would be helpful in resolving the issue.
Unsolicited Information: You may provide us with ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and we shall be free to reproduce, use, disclose, or distribute such Unsolicited Information to others without limitation or attribution.
Payment Information: Outside of storing your PayPal ID where applicable, we do not collect or store credit card information or other payment information as part of the Services. Any credit card or wire transfer transactions are cleared through JPMorgan Chase & Co., Intuit Inc., or Stripe, Inc. and would be subject to their respective privacy and data protection policies.
B. Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with our Services. This information includes the features you select; the links you click on; and the files you upload to the Services.
Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services.
C. Information we receive from other sources
Other users of the Services: Other users of our Services may provide information about you when they use or submit content through the Services. For example, an administrator may provide your contact information when they designate you as an authorized user on your company’s account.
Other services you link to your account: We might receive limited information about you when you or your administrator integrate or link a third-party service, such as a fulfillment or app developer account, with our Services.
2. HOW WE USE INFORMATION WE COLLECT
How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the information we collect about you.
To provide the Services: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services.
For research and development: We are always looking for ways to make our Services better. We use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the Services.
To communicate with you about the Services: We use your contact information to send transactional communications via email and within the Services, including providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases you cannot opt out of them. If an opt out is available, you will find that option within the communication itself or in your account settings.
To market, promote, and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and trends we think may be of interest to you. We also communicate with you about new product offers and promotions. You can control whether you receive these communications as described below under “Opt-out of communications.”
Customer support: We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
For safety and security: We use information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal bases for processing: The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. For example, if you are an individual in the European Economic Area (EEA), you are protected by the General Data Protection Regulation. To the extent such laws apply, our legal grounds for collecting and processing your information are as follows:
To honor our contractual commitments to you. Much of our processing of personal data is to meet our contractual obligations to users of the Services or to take steps at users’ request in anticipation of entering into a contract with them.
To provide you the Services, including to operate the Services, provide customer support, and to protect the safety and security of the Services;
To satisfy a legitimate interest (which is not overridden by your data protection interests or your fundamental rights and freedoms), such as for research and development, to market and promote the Services, to protect our users, personnel, and property, and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g., your employer or a Value Added Reseller) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
3. HOW WE SHARE INFORMATION WE COLLECT
We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
A. Sharing with other Service users
When you use the Services, we may share certain information about you with other Service users.
Value Added Resellers: If you register or access the Services through a Value Added Reseller of RePubIT, certain information about you including your name, contact info, content, and past use of your account is accessible to that organization’s administrator and other Service users sharing the same account.
Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization, and such organization wishes to establish an account or site, certain information about you including your name, contact info, content, and past use of your account may become accessible to that organization’s administrator and other Service users sharing the same account. If you are an administrator for a particular site or group of users within the Services, we may share your contact information with current or past Service users, for the purpose of facilitating Service-related requests.
B. Sharing with third parties
Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, data entry, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or governmental request, including to meet national security requirements, (b) enforce our agreements, policies, and terms of service, (c) protect the security or integrity of our products and services, (d) protect RePubIT, our customers, or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Aggregated or Non-identifiable Data: We may also share aggregated or non-personally identifiable information with partners or third parties for business purposes.
4. HOW WE STORE AND SECURE INFORMATION WE COLLECT
A. Information storage
By using the Service, you acknowledge in all cases that RePubIT acts as the data processor of any reader data collected and processed on your behalf and that you are the data controller of the reader data under applicable data protection regulations in the European Union and European Economic Area. You must obtain and maintain any required consents necessary to permit the processing of reader data through the RePubIT Service.
If you require the Service to deliver content to readers in a manner which can be compliant with the General Data Protection Regulation (GDPR), please contact RePubIT to discuss the implementation of a GDPR-compliant version of the Services. Please note that our GDPR-compliant Service applies only to our processing of reader data on your behalf and does not apply to our collection and processing of your data as a user of the Services.
B. Information security
We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store. We also use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.
C. How long we keep information
By default, we will indefinitely keep the information we collect about you and the content you upload to the Service. We do so for historical and archival purposes and to comply with our legal obligations, to resolve disputes, to enforce our agreements, and to support business operations. However, after three years of storage on our system, we do reserve the right to delete your uploaded content absent your arrangement with us to continue to store that content in the Services.
5. HOW TO ACCESS AND CONTROL YOUR INFORMATION
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
Your Choices: You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work, or where you feel your rights were infringed.
Access and update your information: Our Services give you the ability to access and update certain information about you from within the Service. For example, you can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
Deactivate your account: If you no longer wish to use our Services, you or your administrator may request us to deactivate your Services account by contacting RePubIT support. Please be aware that deactivating your account does not delete your information. Your information remains available to RePubIT. For more information on how to delete your information, see below.
Delete your information: Our Services give you the ability to delete certain information about you from within the Service. For example, you can remove content that contains information about you using your dashboard and you can remove certain profile information within your profile settings. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions, or to comply with our legal obligations.
Request that we stop using your information: In some cases, you may ask us to stop accessing, storing, using, and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we deactivate and, in some cases, delete your account as provided in this policy. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
Opting out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within any promotional email you receive or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings or by using the unsubscribe link within certain Service related emails.
Send “Do Not Track” Signals: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Services do not currently respond to browser DNT signals. You can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving marketing from us as described above.
Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another. Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information, which may include your name, company name, address, phone number, and email.
6. HOW WE TRANSFER INFORMATION WE COLLECT INTERNATIONALLY
International transfers of information we collect
As more specifically described above, we collect information globally and primarily store that information in the United States and use a global content distribution network to deliver your published content to readers using servers located throughout the world. If you have opted into a GDPR compliant version of the Service, certain reader information will be stored only on servers located in Europe.
Notwithstanding, we may transfer, process, and store your information (as a user of the Services) outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. These countries may not have equivalent privacy and data protection laws to the country in which you reside, including, for example, an adequacy decision if you are located in the European Economic Area. Whenever we transfer your information, we take steps to protect it. When you or your organization signed up for the Service, you explicitly consented to the transfer to and collection and processing of your information in the United States and other countries. The possible risk of this transfer is that our protection efforts fail and a third party gains access to your information, which is limited to your name, company name, address, phone number, email, and the information contained within the content you upload to the Service.
7. OTHER IMPORTANT PRIVACY INFORMATION
Notice to End Users
Our Services are intended for use by organizations. Where the Services are made available to you through an organization (e.g., your employer or Value Added Reseller), that organization is the administrator of the Services and is responsible for the accounts and/or content over which it has control. If this is the case, please also direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Administrators are able to: •require you to reset your account password; •restrict, suspend or terminate your access to the Services; •access information in and about your account; •access or retain information stored as part of your account; •install or uninstall third-party apps or other integrations
In some cases, administrators can also: •restrict, suspend or terminate your account access; •change the email address associated with your account; •change your information, including profile information; •restrict your ability to edit, restrict, modify or delete information
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date.
If you do not want an administrator to be able to assert control over your account or use of the Services, use your personal email address to register for or access the Services. If an administrator has not already asserted control over your account or access to the Services, you can update the email address associated with your account through your account settings in your profile. Once an administrator asserts control over your account or use of the Services, you will no longer be able to change the email address associated with your account without administrator approval.
Please contact your organization or refer to your administrator’s organizational policies for more information.
We do not request, collect, or store in any way sensitive information like your credit card data, social security number, driver’s license number, racial or ethnic information, political or religious opinions, financial information, or health information. We ask that you not send or otherwise share with us any sensitive personal information of this nature.
Our Policy Towards Children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
Your information is controlled by Repub Interactive Technologies, LLC. If you have questions or concerns about how your information is handled, please direct your inquiry to the below contact information.
Repub Interactive Technologies, LLC.
Telephone: 321-262-3626 E-Mail: [email protected]