1. WHAT IS REO AND WHAT DOES REO DO?
- 1.1. Reo isa B2B company, primarily focused on delivering valuable data and insights to its Clients while prioritizing privacy and data security. Here's a summary of what Reo does (hereinafter collectively referred to as the “Services"):
- 1.1.1. Reo collects business contact and related information pertaining to individuals (usually the kind of information that would be made available on a business card. For more information, please see Section 2 (What information does Reo collect and how) of this Policy).This data allows Reo to analyze and identify potential customers and/or other relevant business connections for Reo’s Clients, and provide them with relevant information, including contact information, to enable them to contact you and optimize their marketing spending and sales efforts.
- 1.1.2. Reo’s comprehensive analysis provides valuable information to the Client’s marketing, sales, and community teams. By leveraging this data-driven intelligence, Clients can make informed decisions and enhance their strategies, resulting in more effective outreach and engagement with their target audience
- 1.1.3. Through the aggregation of anonymised data from multiple Clients, Reo derives industry-level insights, including best practices and trends. These insights help businesses across various sectors better understand the market landscape and make informed decisions regarding their marketing, sales, and community engagement strategies.
2. WHAT INFORMATION DOES REO COLLECT AND HOW?
- 2.1. Information collected to create profiles.
- 2.1.1. Reo collects various types of information to create professional profiles of individuals and business profiles of companies (each a “Profile”, collectively “Profiles”)stored on its database (“Reo’s Database”) to provide Services to Clients.These information categories include:
- a. Personal, professional-or employment-related information:Information such as name, Internet Protocol (“IP”) address, email addresses (including business and other email domains like Gmail, Yahoo,Hotmail, etc.), current or past job history, job title and department, industry, professional proficiency information (such your preferred coding languages),revenue information, phone numbers (general, direct business, fax, and/or mobile), business-related address, and links to social media profiles and handles (including LinkedIn, Twitter and Facebook);
- b. Commercial information: Information about products or services purchased by individuals and/or organisations affiliated with an individual, and information about an individual's interaction with websites, applications, or advertisements;
- c. Geolocation information: Information about the physical location of individuals, including their IP address, obtained from geolocation features on their devices.
- 2.2 Primary sources of information.
- 2.2.1 Reo relies on the following sources to collect the information specified in Section 2.1 and to create Profiles:
- a. Clients and their representatives: Reo may collectin formation from Clients and their authorized representatives. This includes information that is stored on their infrastructure and databases, information that was provided to them in relation to a purchase of any products or services of the Clients, information that was provided to the Client during the registration process, information that was provided during and interaction or communication with Clients;
- b. Activity and interactions on Client’s websites, products, services, applications, etc.: Reo may collect information about you based on your interactions with websites, products, services, applications, or other digital platforms owned or operated by Clients or their affiliates. This may include data such as your browsing history, usage data, preferences, and engagement with specific content or features, etc.;
- c. Third-party data vendors: Reo may obtain your information from third-party data vendors to help us create accurate and comprehensive Profiles;
- d. Through first-hand research on publicly available web sources: Reo conducts first-hand research on publicly available web sources to gather information that contributes to creating Profiles. This may include collecting data from publicly accessible websites, professional networking platforms, social media profiles, or other publicly available sources of information;
- 2.3 Information collected through Reo’s integrations.
- 2.3.1 As part of the Services,Clients have the option to integrate Reo’s Services with various platforms.These integrations allow the transmission of information from various software that may be installed by you or the Client, for instance, the Client’s CRM tools, email systems, and browser extensions. Through these integrations, Reo may collect information about individuals and companies and process the same to create, organize, scan, merge, and update Profiles in Reo’s Database. This helps improve Reo's research processes and enhances the Services provided to the Clients.
- 2.4 Information collected from users of Reo’s Website.
- 2.4.1 Reo collects the following information from users of Reo’s Website who create an account, use Reo’s Services, or contact Reo via Reo’s Website or other channels (“User(s)”):Name; Email address; Phone number; Mailing address; Location; User activity;Any other information that you provide to Reo voluntarily when you communicate with Reo. Additionally, Reo may collect the information mentioned in Section 2.5 (Information collected from visitors to Reo’s Website) from Users.
- 2.5 Information collected from visitors to Reo’s Website.
- 2.5.1 When a person visits Reo’s Website (“Visitor(s)”),Reo may collect the following information sent to it by the computer, mobile and other access devices of the Visitor:
- a. Device information: details about your device, such as the browser type, operating system, language preference, domain name, and the time of your visit;
- b. Mobile network information: information pertaining to your mobile network;
- c. IP address: your IP address to help Reo identify your device and provide a general idea of your location;
- d. Alerts for troubleshooting: information related to alerts and notifications received during your usage, to address errors and bugs effectively.
- 2.6 Information collected through cookies and similar technologies.
- 2.6.1 When you visit a webpage, small text files called cookies are placed on your computer or mobile device. These cookies consist of letters and numbers and serve various purposes to enhance your experience with the webpage. Cookies are widely used to optimize website functionality and improve efficiency. They facilitate seamless navigation between pages, remember your preferences, and enhance the interaction between you and the webpages. Additionally, cookies play a role in ensuring that the online advertisements you encounter are relevant to your interests.
- 2.6.2 To enhance theService, Reo employs cookies and other similar technologies such as web beacons, log files, API, scripts, and eTags (collectively,“Cookies”) on Reo’s Website, and the Client’s website and other portals(“Client’s Website”). When individuals access Reo’s Website and/orClient’s Website, Reo’s servers, and/or those of the Client automatically record certain information that the web browser sends, such as web request, IP address, browser type, referring/exit pages and URLs, page loads and clicks, domain names, landing pages, pages viewed, time and date of use, and other in formation. The information collected through Cookies is utilized to enhance your browsing experience on Reo’s Website, improve the performance of Services and personalize your interactions.Additionally, Reo utilizes this information to compile usage statistics, conduct analytics, and administer Services to its Users, Visitors and Clients.
- 2.6.3 On Reo’s Website, you are free to decline cookies and can configure your browser to accept all cookies, reject all cookies, erase cookies, or receive a notification when a cookie is set. Electing to reject or disable cookies may substantially limit your ability to use Reo’s Website.
3. DOES REO COLLECT CHILDREN’S INFORMATION?
3.1. Reo's products and services are designed for individuals who are 18 (Eighteen) years of age or older and are not intended for children. If Reo becomes aware that aUser, Visitor, or any individual whose Profile has been created on the Reo Database is under the age of 18 (Eighteen) or under the legal age of consent under the applicable law, Reo will promptly delete their information. If you have reason to believe that Reo is in possession of the personal information of a minor, please reach out to Reo at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.
4.HOW AND WHY DOES REO USE THIS INFORMATION?
- 4.1 Reo may utilize the information that it collects for various purposes, in addition to those mentioned earlier. These purposes include:
- 4.1.1 Providing, personalizing, maintaining, and enhancing Reo’s Website and Services;
- 4.1.2.Verifying, correcting, updating, and managing information collected from and about you;
- 4.1.3. Delivering theServices, processing transactions, and sending related information, including communications and invoices;
- 4.1.4. Detecting and preventing fraudulent and illegal activity, or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
- 4.1.5.Sending technical notices, updates, security alerts, and support and administrative messages;
- 4.1.6. Responding to comments, questions, and requests, and offering customer support;
- 4.1.7. Creating Reo user accounts, authenticating user logins, verifying email addresses and registration to the Services or Reo’s Website;
- 4.1.8. Communicating about products, services, offers, promotions, rewards, events, news, and information provided by Reo and other relevant parties;
- 4.1.9. Monitoring and analyzing trends, usage, and activities related to Reo’s Website;
- 4.1.10. Protecting the rights and property of Reo, itsClients, and others;
- 4.1.11. Notifying Users,Visitors and other relevant persons of significant changes to Reo’s Website,including updates to this Policy;
- 4.1.12. Considering individuals for potential employment with Reo, and communicating regarding employment opportunities or submitted job applications;
- 4.1.13. Fulfilling requests from individuals to access, correct, or delete their information, or to exercise other rights regarding their information under applicable laws;
- 4.1.14. Creating aggregated statistical data, generating inferred non-personal data, or anonymizing and pseudonymizing data (making it non-personal and non-identifiable) that may be used by Reo, or Clients to improve their respective services;
- 4.1.15. Complying with contractual and legal obligations, resolving disputes with Users, Visitors and other relevant persons, and enforcing agreements;
- 4.1.16. Investigating violations and enforcing Reo’s policies;
- 4.1.17. As required bylaw, regulation, or other governmental authority, to comply with a subpoena or similar legal process, or to respond to a government authority’s request;
- 4.1.18. Carrying out any other purpose described at the time the information was collected.
5. HOW DOES REO SHARE PERSONAL INFORMATION?
- 5.1 Reo may share personal information with the following third parties for the purposes stated in Section 4 (How and why does Reo use this information):
- 5.1.1 With Clients: Reo shares Profiles with Clients to provide Services andgrant access to accurate and updated information.
- 5.1.2 With Reo’s affiliates: Reo may disclose information to its affiliated companies, including any parents, subsidiaries, and other companies under common control and ownership with Reo. These affiliates may act on Reo’s behalf for the purposes outlined in this Policy.
- 5.1.3 With Reo’s service providers: Reo relies on service providers to provide various services and tools including: (a) customer support; (b) email communications; (c)infrastructure; (d) data storage; (f) security services; (g) web-hosting services; (h) data analytics; (i) integrating Reo to Client’s CRM tools, email systems, browser extensions (such as Chrome add-ons), or other software; (j) collection of information for creating Profiles; (k) collection of information to update or correct the information on the existing Profiles; (l) and/or system logging services. These service providers will be given access on a need-to-know basis to the information collected by Reo, which may contain personal information about individuals. To ensure the security and privacy of your information, Reo conducts thorough evaluations of the privacy and security practices of its service providers before engaging their services. Additionally, Reo mandates that its service providers enter into agreements that uphold the confidentiality of your information and adhere to data protection obligation sin accordance with applicable privacy laws. Reo’s commitment to maintaining the security and privacy of your information remains a top priority.
- 5.1.4 For Legal Reasons: Reo may disclose information, including, to a third party if it believes in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities ,including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect Reo’s rights or those of Reo’s affiliates, Clients, and Users, or as part of legal proceedings affecting or that may affect Reo or Reo’s affiliates, Clients, or Users; (iv) to allow Reo to exercise its legal rights or respond to a legal claim; and/or (v) to respond to requests for access to information to the extent necessary to comply with applicable laws.
- 5.1.5 To an acquirer of Reo: If Reo or substantially all of Reo’s assets are acquired, or in the event of a merger or bankruptcy, your personal information that is in Reo’s possession may be among the transferred assets.
6. HOW LONG DOES REO RETAIN PERSONAL INFORMATION?
- 6.1 Reo retains your personal information only for as long as necessary to fulfil the purposes described in this Policy.
- 6.2 Reo retains the information collected from its Clients for the duration required to provide Services to the Client or during the validity of Reo’s agreement with the Client. Information collected from Clients that may be relevant to fulfil Reo’s legal obligations, settle disputes or enforce Reo’s policies, may be retained for longer as required.
- 6.3 Reo retains the personal information it collects from its Users for as long as theUser’s information is likely required for Reo to effectively meet the User’s requests, render Services, or as long as the User’s account remains active on Reo, whichever is later. Reo may retain your information for 3 (Three) years or later, following the last activity in your account, in order to comply with Reo’s legal and contractual obligations or to protect Reo from any potential disputes or as long as required by laws applicable to record-keeping, and to have proof and evidence concerning your relationship with Reo, should any legal issues arise following the termination of your account).
- 6.4 Additionally, Reo retains the information that it collects when an individual exercises their right to opt-out, withdraw consent, or erasure for the duration necessary to ensure information related to such individuals is removed from Reo’s Database.
- 6.5 The retention periods are determined considering the quantity, nature, and sensitivity of the personal information, as well as the purposes for which it was collected. Once the retention period expires, Reo will delete the information. In cases where deletion is not feasible, appropriate measures will be implemented to prevent any further use of the information.
7. YOUR RIGHTS
- 7.1 Reo provides options for managing your information and preferences. Depending on where you reside and the law applicable to you, you may have the choice to opt out of Reo’s database or submit requests to access and update your information.You can reach out to Reo at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.
- 7.2 To the extent provided under applicable laws, individuals may have the following rights (please note that this is not an exhaustive list):
- 7.2.1 The right to access: Individuals may have theright to request access to, and a copy of, their personal information free ofcharge, as well as certain information about Reo’s processing activitiesrelated to their personal information including: the purposes of the processing;the categories of personal data concerned; the recipients or categories ofrecipient to whom the personal data have been or will be disclosed; informationpertaining to the source of data; information regarding automateddecision-making, including profiling.
- 7.2.2 The right to correct: Individuals may request correction or completion of their personal information if it is inaccurate or incomplete. Taking into account the purposes of the processing, the individual may have the right to complete any incomplete or inaccurate personal information, including by means of providing a supplementary statement.
- 7.2.3 The right to restrict processing: Individuals may have theright to obtain from Reo restriction of processing in certain events, such aswhen, the accuracy of the personal data is contested, for a period enabling Reoto verify the accuracy of the personal data or when the data subject hasobjected to processing;
- 7.2.4 The right to data portability: Individuals may havethe right to request a copy of their data in a machine-readable format. They mayalso request that Reo transmit their data to another entity where technicallyfeasible.
- 7.2.5 The right to erasure : Individuals may have the right to have their data erased from Reo’s Database on certain grounds, such as if the personal information is no longer necessary for the purpose for which it was collected, if they withdraw consent and if no other legal basis for processing exists,.
- 7.2.5 The right to object to processing: Individuals may have the right to object to processing by Reo if Reo is processing information based on legitimate interests, and their fundamental rights to data privacy and protection outweigh Reo’s legitimate interest in continuing the processing.Where data is processed for direct marketing (including profiling), data subjects may be able to object to such processing.
- 7.3 If you wish to exercise any of your rights under applicable law, please reach out to Reo at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.
8. INFORMATION FOR INDIVIDUALS RESIDING IN THE EUROPEAN ECONOMIC AREA
- 8.1 Reo strives to comply with the provisions of the General Data Protection Regulation(the “GDPR”) concerning any personal information it possesses about individuals based in the European Economic Area (for the purpose of thisSection 8, referred to as “Data Subjects”). Reo only processes personal information of Data Subjects when Reo a lawful basis to do so, which may include the following:
- 8.1.1 Consent;
- 8.1.2 Performance of Reo’s agreement to provide Services or other applicable agreements;
- 8.1.3 Compliance with a legal obligation to which Reo is subject; and/ or
- 8.1.4 Legitimate interests of Reo in: (a) operating a successful business; (b) providing accurate and up-to-date Profiles, allowing Clients to engage with other businesses in effective online and offline interactions; (c) direct marketing and sales; d) ensuring the safety and proper functioning of Services; (e) fraud prevention, network and information security; (f) ensuring that Reo’s policies and agreements are complied with; (g) exercise of Reo’s rights, the defense of Reo’s legal rights and compliance with Reo’s legal obligations.
- 8.2 Reo respects the rights of Data Subjects outlined in Articles 12-23. Data Subjects have the right to access and correct their personal information, to data portability, to request data erasure, to restrict processing and to object to processing.
- 8.3 To make opt-out requests, inquiries related to privacy, or exercise your rights under GDPR, please reach out to Reo at the contact information listed under Section 12 (ContactUs) at the end of this Policy
- 8.4 Depending on Reo’s activity, Reo may act as a controller and processor under the GDPR, as explained below:
- 8.4.1 Reo acts as controller: When Reo collects and uses information about Data Subjects who are Clients, Users or Visitors, Reo acts as a controller. Reo also acts as a controller when Reo directly collects information about Data Subjects to create and maintain Profiles to provide Services
- 8.4.1 Reo acts as a processor: When Clients use Services, they act as the controller and are responsible for ensuring lawful processing of personal information collected about Data Subjects. In those cases, Reo acts as the processor and receives personal information as agents of Clients solely for processing purposes instructed by them. Clients are solely responsible for determining whether and how they wish to use Services and for ensuring that all necessary legal requirements are met, including providing adequate notice to third-party individuals and obtaining informed consent where necessary. Clients are also responsible for handling Data Subject rights requests under GDPR. Reo’s obligations regarding personal information for which Reo is solely a processor are defined in Reo’s agreements with Clients and are not covered by this Policy.
9. INFORMATION FORINDIVIDUALS RESIDING IN CALIFORNIA
- 9.1 TheCalifornia Consumer Privacy Act of 2018 (the “CCPA”) grants specific rights to residents of California (for the purpose of this Section 9, referred to as “Consumers”)regarding their personal information.
- 9.2 Subject to the exceptions, limitations and restrictions in the CCPA, a Consumer has the right to access information, data portability, data correction and data deletion.
- 9.3 To exercise any of your rights, please reach out to us at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.
10. HOW DOES REO KEEP THIS INFORMATION SECURE?
- 10.1 Reo takes information security seriously and will make every reasonable effort to ensure the secure treatment of your information in accordance with this Policy. Reo adheres to generally accepted industry standards to protect the information you submit during collection, transmission and storage.
- 10.2 Upon receiving your information, Reo implements appropriate technical and organizational measures, as well as reasonable precautions, following industry best practices to safeguard it against loss, theft, unauthorized access, use, or modification. However, it is important to note that no method of Internet transmission or electronic storage is 100% secure. While Reo employs precautionary measures to protect your information, Reo cannot guarantee absolute security.
- 10.3 Reo is headquartered in Delaware, USA, and Reo’s data is stored on Amazon Web Services in the United States of America. Some of Reo’s data processing activities are conducted in other countries by Reo’s staff or service providers who may be located outside the European Economic Area.
- 10.4 In situations where Clients, Users, Visitors or other individuals whose information we collect are subject to the GDPR, Reo has entered into / will enter into contracts based on the Standard ContractualClauses approved by the European Commission or the UK International DataTransfer Agreement or Addendum (as applicable) or similar agreements to ensure a comparable level of protection for any further data transfers
11. CHANGES TO THIS POLICY
- 11.1 Reo may update this Policy periodically in order to accommodate any changes in Reo’s information processing practices. If there are significant changes to this Policy, such as modifications to Reo’s processing purposes, or the methods for exercising your rights in relation to Reo’s processing activities, Reo will notify you accordingly, through email or by posting a notice on the homepage ofReo’s Website prior to the changes taking effect. Continued use of the Reo’sWebsite or the Services after any updates to this Policy constitutes acceptanceof the updated Policy
12. CONTACT US
- 12.1 For questions, concerns or complaints, please contact us at:firstname.lastname@example.org
- 12.2 If you have not received a satisfactory response to any of your questions, concerns or complaints that were sent to the aforementioned emails/ addresses, we apologize for the inconvenience. We encourage you to reach out to our Founders at: email@example.com
- 12.3 We value your feedback and strive to address any issues promptly and effectively.
- 12.4 Please note that in order to verify an individual's identity, Reo may require them to provide Reo with personal information before accessing any records containing information about them or giving effect to any rights they may have under the applicable law
- 13.1 If you believe that your information has been mishandled or if you are dissatisfied with Reo’s response to your requests concerning the use of your personal information, you have the option to file a complaint.
- 13.2 Please send the details of your complaint to:
13.2.1 In the European Economic Area: contact details of EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
13.2.2. In the UK: you can contact theInformation Commissioner's Office at https://ico.org.uk/.
13.2.3. For residents of other countries: you have the right to submit your complaint to the appropriate data protection regulator inyour country of residence.