Repustar Privacy Policy

Updated and effective May 7, 2020

This privacy policy (“Privacy Policy”) applies to any website, mobile application, feature, widget, or other online service that is owned and operated by Repustar, Inc. (“Repustar”) and that includes a link to this Privacy Policy (“Sites”) and to information collected offline by Repustar.

By accessing, visiting, using, or submitting information to the Sites or providing information to us offline, you agree to this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites.

This Privacy Policy covers the following

KEY POINTS

KEY POINTS

This section briefly highlights some of the key elements of our privacy practices. Please review our full Privacy Policy, below, before using the Sites.

• We may collect information from or about you, including personal information, demographic information, interest information, and user content you submit to us. We may ask you to provide additional information as you become more involved with our Sites, including – for those interested in becoming a Reviewer (described below) – information on your background and experience.

• We also automatically collect information through your use of the Sites. This may include usage information about your device and network (e.g., hardware and software information, device identifier, etc.). We may be able to infer your approximate location based on this information. We may also collect information about you from third parties. Please review the “Information That We Collect” section below for more information.

• We primarily use the information we collect in connection with your relationship with Repustar and your use of our Sites, to tailor the information we provide to you, to improve our Sites, and for sending you information. Please see the “How We Use Information” section below for details.

• We may share your personal information with third parties , such as with vendors providing services to us (e.g., hosting the Sites or sending emails for us), where you request that we share your information, or for administrative reasons or legal compliance. Please refer to section titled “How We Share Information” for details.

• We do not serve third-party advertisements on our Sites. We do, however, work with third-party analytics providers. We may also work with third-party network advertisers and similar third parties. These parties may use their own tracking technologies on the Sites and they may otherwise collect or have access to information about you and your interactions with us. If we work with advertising partners, they may use information they’ve collected about you from our Sites to serve you targeted ads elsewhere online. For more information, including your opt-out choices, please review the section titled “Third-Party Analytics and Advertising Providers”.

• We are a US-based company. Information you provide us may be transferred to the US and possibly other countries (including India). By using our Sites, you consent to such transfer.

• We employ commercially reasonable administrative, technological, and procedural safeguards to help protect the security of your personal information. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you.

• If you have any questions on our privacy practices, please contact us at privacy@repustar.com

GENERAL AUDIENCE SITES

The Sites are intended for a general audience and are not intended for use by or targeted to children younger than the age of 16. We do not knowingly collect personal information from children younger than the age of 16. If you are the parent or legal guardian of a child younger than age 16 and believe that we have collected personal information from your child, please contact us using the information in the “Contact Us” section below.

INFORMATION WE COLLECT.

We may collect information from you directly, automatically when you visit the Sites, and sometimes from third parties.

Some of this information may be considered “personal information” under various applicable laws. We consider information that identifies you as a specific, identified individual (such as your name, phone number, and email address) to be personal information. We will also treat additional information, including IP addresses and device identifiers, as “personal information” where required by applicable law.

Note that we may de-identify personal information so that it is non-personal, such as by aggregating or converting it to a code, sometimes using a function commonly known as “hash.” We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.

Information You Provide to Us Directly

We may ask you to provide information directly when you interact with us, such as when you create an account, communicate with us through the “Contact Us” or other feature on the Sites, submit content to the Sites or identify particular content for review (a “Flag”), apply to be or participate as a reviewer for the Sites (“ Reviewer”), sign up for our marketing emails, or through other features of the Sites. This may include:

• Contact information (such as your full name, email address, or phone number);
• Demographic information (for example, your city/state, gender, or similar information); and
• Information about your preferences and interests and other information.

We may offer some users the opportunity to participate in additional features of the Sites (e.g., if you express an interest in becoming a Reviewer) and may require you to provide additional personal or other information as part of evaluating you for access to these additional features, such as information about your social-media accounts, information we can use to verify your identity, and information about your education, experience, and/or employment history

If you sponsor any review services on the Sites, we may ask you to provide payment and billing information (such as a bank account or payment card number and other associated information), which may be processed by a third-party payment processor.

Information We Collect Automatically

We and our third-party service providers may use a variety of technologies that automatically or passively collect certain information about your use of a Site whenever you visit or interact with the Sites (" Usage Information"). Usage Information may include, among other information:

• the hardware model, browser, and operating system you are using,
• the URL or advertisement that referred you to the Sites,
• all of the areas within the Sites that you visit,
• your time zone,
• mobile network (if applicable), and
• IP address, mobile device identifier, or other unique identifier (“ Device Identifier”) for any computer, mobile phone, tablet, or other device used to access the Sites. (A Device Identifier is a number that is automatically assigned to your device and our servers identify your device by its Device Identifier.)

We or our third-party service providers may be able to infer your approximate location through other information we collect, such as IP address.

We typically consider Usage Information to be non-personal, but, as stated above, we will treat certain Usage Information – such as Device Identifier – as personal information where required by applicable law.

The technologies used to collect Usage Information may include the following:

Cookies and Local Storage. A cookie is a data file placed on your computer or other device when it is used to visit the Sites or otherwise access our online content. We use both session and persistent cookies (which remain on your computer after the browser has been closed). To get information about cookies from AllAboutCookies.org. Certain web browsers and browser add-ons may also provide additional local data storage mechanisms.

Cookies and local storage may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our Sites. Most browsers provide you with the ability to disable or decline cookies and local storage. You will need to check your browser’s settings for further information. If you disable cookies, adjust privacy settings on your device, restrict local storage, or otherwise limit these technologies, you may not be able to use some features of the Sites.

Web Beacons. We may use web beacons (small graphic images or other web programming code, also known as “1×1 GIFs” or “clear GIFs” or “pixel tags”) and similar technologies on our Sites and within our communications to you. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed, and to improve your experience on the Sites, including to provide you with content customized to your interests.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Sites, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect Usage Information and similar information for security and fraud detection purposes and to enforce our intellectual property rights.

For mobile users, Usage Information is typically associated with your Device Identifier, though we may use other tracking technologies to collect Usage Information.

Send-to-a-Friend Features

If you send a friend a communication from the Sites, the information you provide (name, email address, etc.) is used to facilitate the communication and is not used for any other marketing purposes, unless we obtain consent from that person. If you disclose any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Information We Receive from Third Parties

We may receive information about you from third parties. For example, if you are on another website and agree to receive information from us, that site will forward your information to us so that we may contact you. If you are the subject of a Flag, we may receive information about you from the user submitting the Flag. If you sponsor reviewing services through the Sites, we may receive information about you from our third-party payment processor (such as your name and contact information). In some circumstances – such as when evaluating potential Reviewers – we may supplement information that we collect with outside records from other third parties, including public databases, publicly available social media pages, and other third-party sources. The information collected and stored by third parties is subject solely to the third party’s privacy practices.

COMMUNITY FORUMS & USER CONTENT

The Sites may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality (“Community Forums”). You may choose, through such features or otherwise, to submit or post questions, comments, suggestions, photographs, videos or other content (collectively, “User Content”). 

Note that anything you submit or publicly post to the Sites may be public– others may have access to your User Content and may use it or share it with third parties. Certain information, such as your name, username, and where you reside, may be publicly displayed on the Sites along with any User Content you post. For users performing certain activities on the Sites, we may require that the user verify and disclose his/her true identity when posting User Content, in accordance with Repustar’s principles of accountability. We are not responsible for how others use User Content you submit or post. If you choose to voluntarily disclose personal information in User Content, that information will be visible to others.

Note also that User Content submitted by Reviewers in providing claim verification services for the Sites (a “ Reviewer Contribution”) may be subject to different policies and restrictions, as set out in the agreement between Repustar and the applicable Reviewer (which will control in the event it conflicts with this Privacy Policy).

SOCIAL-MEDIA FEATURES

Functionality on the Sites may permit interactions between the Sites and a third-party service, such as YouTube, Facebook, Instagram, or Twitter ( “Social-Media Features”). Examples of Social-Media Features include enabling you to “like” or “share” content from the Sites or to “like” or “share” our page on a third-party service; to register with the Sites using login information for a third-party platform, and to otherwise connect the Sites to a third-party service. If you choose to share content or to otherwise post information through the Sites to a third-party service, or vice versa, that information may be publicly displayed. We and the third party may both have access to certain information about you and your use of the Sites and the third-party service. These third-party social media companies may collect information about your visit to a Site through the Social-Media Features we have integrated into the Site. The information we collect in connection with Social-Media Features is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices.

HOW WE USE INFORMATION

We may use information we collect, including personal information and Usage Information:

• To enable you to use the Sites or other services we offer.
• To communicate with you and send you information about us and the Sites.
• To contact you about administrative matters, such as changes to our Privacy Policy or other policies.
• To tailor and target the content, recommendations, and offers we display to you or others on the Sites, and to analyze trends and statistics.
• To serve our advertisements off of the Sites.
• To provide customer service, such as responding to your questions and getting your feedback.
• For internal business purposes, such as improving the Sites and our products and services.
• To comply with legal requirements and our business practices, such as our recordkeeping, backup, and document-retention policies.
• To operate and protect the Sites from errors, misuse, fraud, and any activities that are illegal or violate our terms and policies, detect and troubleshoot problems, resolve disputes, and enforce applicable agreements and policies.
• To evaluate potential Reviewers or to consider an application for employment by Repustar.
• For other reasons that we disclose when you provide your information or otherwise with your consent.

HOW WE SHARE INFORMATION.

We do not share personal information with unaffiliated third parties for their own direct marketing purposes without your consent. We may share non-personal information, such as aggregate user statistics, hashed or otherwise de-identified information, and Usage Information, with third parties. We may also share personal information as disclosed when you provided it, with your consent, as described elsewhere in this Privacy Policy, and in the circumstances described below – all as permitted by applicable law:

Third Parties Providing Services on our Behalf

We use third parties to provide services to us or on our behalf, such as operating and supporting the Sites, sending our communications, analyzing data, or performing marketing or consulting services. We give these third parties access to your personal information (or allow them to collect information from or about you) so that they can provide the services.

When You Agree to Receive Information from Third Parties or Request That We Share Your Information

We may share information when you direct us to do so. For example, you may be presented with an opportunity to receive marketing offers from a third party or you may engage with Social Media Features or other third-party applications or features, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Administrative and Legal Reasons

We reserve the right to use or disclose any information as needed (a) to satisfy any law, regulation or legal request; (b) to fulfill your requests; (c) to cooperate in any law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual-property infringement; (d) to protect and defend the legal rights or property of Repustar, our parent companies, affiliates, subsidiaries and investors and/or shareholders, the Sites or any Site users, or any other party; or (e) in an emergency, to protect the health and safety of our users or the general public. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.

Business Transfers and Transitions

Repustar may share your information with any Repustar parent, subsidiary, or affiliate, primarily for business and operational purposes. In the event Repustar goes through a business transition (such as a merger, acquisition by another company, or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process), your personal information will likely be among the assets transferred. By providing your personal information, you agree that we may transfer such information to the acquiring entity without your further consent.

Employment Applications

If you apply for a job through the Sites, we or our service provider(s) may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with the laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state, local, or other applicable regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints. (Please note that we may utilize a careers portal that is operated by a third party, in which case your use of the careers portal will be subject to the third party’s privacy practices as disclosed on the portal, and not to this policy.)

Promotions

We may offer promotions, such a sweepstakes, contests, or other offers (any, a “Promotion”). Your participation in any Promotion is governed by the rules/terms of that Promotion. If you choose to participate in a Promotion, your personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with prize fulfillment, as required by law, or as permitted by the Promotion’s rules/terms (such as on a winners list).

THIRD-PARTY ANALYTICS AND ADVERTISING PROVIDERS

We do not serve third-party ads on the Sites. However, Repustar works with third-party analytics companies that provide us with information about the Sites and Site users. We may also work with third-party advertising companies to serve our advertisements elsewhere online.

These third parties may set their own tracking technologies on your device (including cookies and web beacons) and they may otherwise collect or have access to Usage Information and other information about you (including information collected over time and across online services). Some may use this information to target advertisements and assess the effectiveness of our advertising. We may also share certain information, such as Usage Information or aggregated, de-identified, or hashed information, with some of these third parties for similar purposes.

Some of the analytics providers we may work with include Mixpanel and Google Analytics. To learn more about how Google treats the data it collects through Google Analytics, visit www.google.com/policies/privacy/partners/.

Your Advertising Choices

Some of these third parties may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“ DAA”) Self-Regulatory Program for Online Behavioral Advertising. Both NAI and DAA provide information regarding procedures for opting-out of targeted online advertising from participating companies. For information from NAI about opting out click here. For information from DAA about opting out click here.

For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. Also, on most mobile devices, you can install the DAA's AppChoices app to make choices about cross-app interest-based advertisements from participating third parties. You may review additional information on opting out of mobile devices click here.

Opting out through these mechanisms does not block all online advertising; you will continue to receive generic advertisements while online.

“DO NOT TRACK” REQUESTS

Some browsers can be set to send a “Do Not Track” signal that requests that a website not track the visitor’s activity. Currently, our Sites do not stop tracking in response to those requests except as specifically required by law. For information about “do not track” from The Future of Privacy Forum click here.

SECURITY

We employ commercially reasonable security methods and technologies to help secure your personal information. However, no system can be guaranteed 100% secure. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Sites and provide us with information at your own initiative and risk.

THIRD-PARTY LINKS AND CONTENT

The Sites may contain links to other web sites that Repustar does not control, as well as content hosted and served by third parties (for example, content that has been submitted for reviewing/claim-verification). The third parties whose content appears on the Sites may collect information about you through the use of cookies and web beacons, may independently collect or solicit personal information, and may have the ability to track your use of their sites and services. Likewise, our content may be included on third parties’ sites that are not associated with Repustar and over which we have no control. We may collect Usage Information through Repustar content appearing on third-party sites. Repustar is not responsible for the privacy practices of any third party.

JURISDICTION AND CROSS-BORDER TRANSFER OF INFORMATION.

Repustar is a United States company. If you are located in another jurisdiction, please be aware that information you provide to us will be transferred to and processed in the United States and possibly other jurisdictions, including India. By using the Sites, or providing us with any information, you consent to this transfer, processing, and storage of your information in and to the United States, India, and other jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

UPDATING INFORMATION AND YOUR MARKETING CHOICES.

You are responsible for maintaining and updating, as applicable, your account with current, accurate and complete information. You may be able to view and edit some of the registration data you have provided by logging in to your account, going to the “My Account” or similar page, and following the appropriate instructions. We will make good faith efforts to make requested changes in our active databases. Note, however, that information you update or change may persist internally or for our administrative purposes. It is not always possible to completely remove or delete all of your information from our databases, and residual data may remain on backup media or for other reasons.

Users who receive our marketing emails and wish to remove themselves from that mailing list (i.e. opt out) can do so by following the link provided in an email received. Please note that we reserve the right to send you certain communications relating to your use of the Sites (for example, policy updates, service announcements, or communications relating to your use of the Sites) and these administrative or transactional account messages may be unaffected if you opt-out from marketing communications.

If you have consented to receive push notifications from us on your device and you later decide that you no longer want to receive those notifications, you may disable them in your device settings.

You may request that we delete personal information that we have collected about you by sending an email to privacy@repustar.com. Please clearly state the nature of your request and provide your first and last name, Repustar username (if you have one), and any email address(es) through which you've interacted with us (including incognito addresses if you've used privacy features that disguise your email address when signing in through a third-party service).

We may ask for additional information as needed to fully verify your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information, we will not be able to process the request.

If you have provided content for publication on Repustar pursuant to an agreement between Repustar and you, your organization, or your employer, that content will not be disabled or deleted as a result of any request you submit regarding deletion of your personal information.

Note that we may not be able to completely delete all personal information we may have about you and may retain certain personal information in some instances, such as where: it is stored in archived or back-up systems, the information is necessary for us to comply with legal obligation or relevant in responding to an actual or anticipated dispute, it is necessary for recordkeeping (e.g., a record of deletion requests received and how we responded to them), deletion would impinge upon free-speech rights, that information is reasonably necessary to identify and repair errors in or to help ensure the security and integrity of our services, and in some other limited circumstances.

CHANGES TO THE PRIVACY POLICY

To the extent permitted by applicable law, we may change this Privacy Policy from time to time. We will notify you of material changes by posting the changed or modified Privacy Policy on our Sites. We may also notify you in other ways, such as through contact information you have provided. The revised Privacy Policy will take effect when posted, unless a later date is specified. To the fullest extent permitted by applicable law, you agree that by accessing, visiting, or using any of the Sites or submitting information to any of the Sites after the effective date (or taking any other action as specified in the revised Privacy Policy), you agree to the revised Privacy Policy. However, we will provide notice and obtain your consent (opt-in or opt-out) to any changes if required by law.

CONTACT US

If you have any questions or concerns about this Privacy Policy, please email us at privacy@repustar.com

NOTICE TO NEVADA RESIDENTS.

Repustar does not currently sell your covered information, as those terms are defined under applicable Nevada law. However, you may submit an opt-out request and we will honor that request as required by Nevada law if Repustar engages in such a sale in the future. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to nevada_optout@repustar.com. Your request must include your full name, street address, city, state, and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address as needed regarding this request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. We will respond to your request within sixty (60) days, either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.