This Privacy Policy (this “Policy”) applies to the Personal Data (as defined below) and other information collected while you are using or inquiring about Reputation Institute, Inc. d/b/a The RepTrak Company’s (“RepTrak”, “we“, “us“, or “our“) reputational analysis and related products and services, including, without limitation, our online, client-accessible platform (collectively, the “Services“).  This Policy also governs your interaction with our website, www.reptrak.com (the “Website”), as well as our general online and offline collection of information.  This Policy applies equally to all of our global parents, subsidiaries and affiliated companies (collectively, the “RepTrak Group”).

By accessing or using our Website and/or the RepTrak online platform (the “Platform”), you agree that you have read, understand, and are bound by this Policy and our terms of use (the “Terms of Use”).  IF YOU DO NOT AGREE TO BE BOUND BY THIS POLICY OR OUR TERMS OF USE, PLEASE DO NOT USE OR ACCESS OUR WEBSITES OR THE PLATFORM.

This Policy explains, among other items: (1) What Personal Data and other information we collect; (2) How we use the Personal Data and other information; (3) How we share the Personal Data and other information; and (4) Your choices regarding our use of your Personal Data and other information.

Collection of Personal Data

Personal Data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, mailing address, phone number or Internet Protocol (“IP”) address. We may need to collect and process Personal Data in order to provide requested information, provide Services to you, allow you to access the Website or the Platform and/or because we are legally required to do so.  Personal Data may be collected directly from you, from your employer and/or from third parties.

Personal Data may be requested from you as part of the Platform registration process. This information may be collected via the Platform or offline.  The registration process typically requests that you provide your name, business email address, business mailing address and business  phone number.  We also may collect Personal Data when you subscribe to our newsletter(s), respond to a survey, inquire about our Services and/or contact us for customer service or technical support. Your Personal Data helps us to better respond to your interests and needs.

In some circumstances, RepTrak may receive and utilize Personal Data from your posts on social media platforms having and applying their own privacy policies and terms of service.

RepTrak may collect Personal Data voluntarily provided by you, including in emails, online forums, order and registration forms, surveys, promotion participation, phone calls and online chats with customer service or technical support and through other means.

RepTrak collects information through various other means, including participation at conferences, tradeshows and events, individual introductions from companies or governmental entities that use our Services or ask us to conduct market research on their behalf, and from selected third-party business partners. From time to time, we may also acquire from third-parties certain lists containing Personal Data of individuals who may be interested in our Services or Websites.

Use of Personal Data

In general, you can use and visit our Website without submitting any Personal Data. However, in order to utilize and access certain features on our Website and to access the Platform you will need to submit your Personal Data.

We use Personal Data for legitimate business purposes, including the following:

Delivery of Services and Fulfillment of Requests. We may use Personal Data about you to: (a) register you for the Platform or Services, activate and deliver Services to you, provide you with information about Services that were ordered, allow you to access the Platform and/or provide you with customer service or technical support; (b) manage our contractual relationship with you or your employer;  (c) comply with a legal obligation.  As appropriate, we may share your Personal Data with a client and/or a third party who engages in market research services.  We, or our business partners, may use your Personal Data to contact you for the purposes of conducting surveys or market research.

Other Communications. From time to time, we may use Personal Data about you to inform you through targeted advertising of products, programs, services and promotions that we believe may be of interest to you as well as for general marketing purposes.  We sometimes use a marketing automation tool to identify individuals who may be interested in receiving information about the Website, the Platform or our Services.

Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of Services), editorial and feedback purposes, providing customer service or technical support, customizing and improving the content and layout of the Website or the Platform, completing business transactions, development of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Website or the Platform are of most interest to users), product development, market research, administering individual accounts, and meeting regulatory requirements.  We engage in these activities to manage our relationship with you, to comply with a legal obligation and/or because we have a legitimate interest.

Administrative Communications. We reserve the right to use Personal Data to send you important information regarding the Website, Services, the Platform, your account status, changes to this Policy, or any other policies, agreements or transactions relevant to your use of the Website, the Platform and/or Services. Because this information may be important to your use of the Website, the Platform and/or Services, you may not opt-out of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.

Provision of Service; Data Transfers. We will share your data with platform hosts and similar vendors who provide the mechanical foundation of the services. The provision of the service often involves transmission of data across national borders and outside of the European Union to the United States and possibly other jurisdictions. Such transfers are customarily governed by data processing agreements.

Employment.  We may use your Personal Data to consider you for employment when you apply for a position with us or submit a resume or an employment application to us.

We believe that we  have established reasonable organizational and technical measures designed to protect Personal Data from loss, misuse, or unauthorized access, disclosure, alteration or destruction. However, no electronic transmission, storage or processing of information can be entirely secure and you assume all risk of loss, unauthorized access to or misuse of your information.  Please note that one of the most effective security measures is protecting your password.  Do not use any common passwords (such as “password”, “1234” or your child’s name) and do not share your password with others.  Most Personal Data is stored electronically on third-party servers located in the European Economic Area. In cases where it is transmitted outside such area, such transmittal is governed by Data Processing Agreements between the data controller and data processor.

By submitting your Personal Data, you expressly authorize RepTrak to contact you on your mobile telephone to the extent you provide the same to us.  This contact may be a text message or a telephone call.

What Other Information We Collect

When you visit or interact with our Website or the Platform, we or our third-party service providers may also use cookies and other types of web technologies to collect technical and usage information such as browsing history, domain name, IP address, browser type, date and time of each visit, and pages that your web browser has visited. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information in order to collect technical and usage information such as browsing history, domain name, IP address, browser type, date and time of each visit, the pages you visit, and other technical and usage information.

We use cookies to understand and save your preferences for future visits and to compile aggregate data about Website traffic and Website, Platform and Services interaction so that we can offer better experiences and tools in the future.

Most web browsers permit you to set your web browser to block or delete all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it’s important to remember that our Website or the Platform may not function properly if you set your browser to reject our cookies.

We may use a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit our Website, what pages they visit when they do so, and what other sites they used prior to coming to our Website. We use the information we get from Google Analytics to improve our Website. To the best of our knowledge, Google Analytics collects only the IP address assigned to you on the date you visit our Website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. We do sometimes transmit IP addresses and email address to Google Analytics for the purposes of performing IP geolocation and/or customer segmentation.  Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. More information on Google Analytics can be found here: https://policies.google.com/technologies/partner-sites. If you would like to opt-out of having your data used by these cookies, please use the Google Analytics opt-out available here:  https://tools.google.com/dlpage/gaoptout/.

We may also use other third-party service providers to track our visitors. Most browsers also allow you to turn on a feature commonly referred to as “Do Not Track” so that websites and service providers will not track your behavior over time and across websites.

How We Share Information

Although we do not presently sell your Personal Data for monetary consideration, we will provide some or all of your Personal Data to our business partners such as third parties who assist us in operating our Website or the Platform, support us in providing Services, conduct surveys or market research and/or provide general business services (e.g., marketing, analytics). We may also share your Personal Data when we believe the disclosure is appropriate to comply with the law or legal process, enforce our policies, or protect ours or other’s rights, property, or safety.  We may share Personal Data with our clients as appropriate.

From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with RepTrak to provide or promote joint products, services, applications, features, or conducting seminars or webinars (together, “Jointly Offered Items”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.

We may share your Personal Data with other companies in the RepTrak Group.  We may also transfer your Personal Data to any successor company through a corporate transaction such as a merger, sale of assets, statutory consolidation and/or joint venture.

Choices Re: Personal Data

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.  If you no longer want to receive marketing-related emails from us on a going forward basis, you may stop receiving these marketing-related emails by sending an e-mail to Privacy@RepTrak.com. Similarly, if you would prefer that we do not share your Personal Data on a going-forward basis with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to Privacy@RepTrak.com. All of our email communications include the ability to opt-out from receiving future emails, except Administrative Communications.

We will try to comply with your request(s) as soon as reasonably practicable. Please note: (a) we will not be able to remove your Personal Data from the databases of third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request); (b) that requesting us not to share your Personal Data with the RepTrak Group or unaffiliated third parties may result in you no longer receiving any marketing emails from RepTrak; and (c) that if you choose not to receive marketing-related messages from us, we may still send you important Administrative Communications, and you cannot elect to stop receiving such communications, unless you choose to stop receiving Services from us.

You may also indicate your choices regarding marketing-related emails by contacting us via regular mail using the “Contact Information” below, or if you have an account on the Platform, by changing your preferences on such account at any time.

If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by contacting us using the information provided in the “Contact Information” section below. We will respond to your request consistent with applicable law. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

      Miscellaneous

A.     Changes to our Privacy Policy

We reserve the right to change this Policy from time to time. You are encouraged to regularly review this Policy.  If we decide to materially change this Policy, we will post a notice on the Website and/or within the Platform.

B.      Third Party Websites

Our Website or the Platform may contain links to other sites such as social networks or links to our business partners. Please be aware that we do not endorse and are not responsible for the privacy practices of such other sites and this Policy does not apply to such third-party sites. If you have any questions about these other companies’ data practices, you should review their privacy policies.

C.   Minors and Children

Our Website, the Platform and the Services are not directed to minors or children under the age of 16 and we do not knowingly collect Personal Data from any individual under the age of 16. If you are under the age of 16, please stop using our Website or the Platform.

D.     Additional Information for California Residents

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) may provide you with specific rights regarding your Personal Data.  These include:

• You can request information about our collection and use of your Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about you, (ii) the business or commercial purpose for collecting your Personal Data, (iii) the categories of sources from which your Personal Data is collected, and (iv) the categories of third parties with whom we share your Personal Data.  You can request a list disclosing the categories of your Personal Data we have shared in connection with a business purpose.

• You can request to receive a copy of your Personal Data in a commonly used and machine-readable format.

• You can request that we delete your Personal Data, subject to certain exceptions.

To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Data relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. We will not discriminate against you for exercising any of your privacy rights under CCPA or other applicable law.

During the past twelve (12) months, we collected the categories of Personal Data described above from California residents. We also disclosed such Personal Data to third parties for the purposes specified above during the past twelve (12) months.  Any request related to the CCPA may be made via the Contact Information below.

E.      Contact Information for RepTrak

If there are any questions regarding this Privacy Policy or how we process your Personal Data, you may contact us by sending an email to Privacy@RepTrak.com  or by sending registered mail to:

RepTrak

399 Boylston St., Seventh Floor

Boston, MA 02116

USA Attn: Privacy Department

Policy Last Updated: August 1, 2021