Last Update: September 2024
This Privacy Notice for California Residents supplements the information contained in Reply S.p.A’s (“Company,” “Reply,” “us,” “we” or “our”) Reply Marketing Privacy Notice, and Reply Privacy and Cookie Policy, which are incorporated herein by reference, and applies solely to individuals who reside in the State of California (“Consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended from time to time, and any terms defined in the CCPA have the same meaning when used in this Notice. This Privacy Notice applies to the Reply websites (e.g., www.reply.com, www.reply.com/br) and Reply platforms (e.g., Reply Webinar Platform, Reply Events Platform, Reply Online Services) (collectively, the “Reply Services”).
Information We Collect
Reply (as defined in our Reply Privacy Marketing Notice) may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device (“Personal Information”). Personal Information does not include:
Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, such as: (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and (ii) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, Reply (as defined in our Reply Marketing Privacy Notice) collects (and has collected within the last twelve months) the following categories of Personal Information:
We obtain the categories of Personal Information listed above from the following categories of sources: (i) directly from you; for example, from forms or surveys you complete or products and services you purchase; and (ii) indirectly from you; for example, from observing your actions on our website, (iii) from our business partners, (iv) from customers and clients, (v) from social networks, (vi) from Internet service providers, (vii) from operating systems and platforms, (viii) from our Affiliates (as defined in our Reply Marketing Privacy Notice) and subsidiaries, and (ix) from our vendors and service providers.
Use of Personal Information
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product or service orders, or process returns.
To provide, support, personalize, and develop the Reply Services and to understand user behavior by showing what parts of the website you visited and stayed on.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud, verify your identity, and invoice you for any relevant payment.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns, monitor and improve our responses, and to diagnose possible problems with our website and accompanying Services.
To personalize your website experience, understand your preferences, and to deliver content and product and service offerings relevant to your interests, including targeted offers, ads, news, educational materials, and/or our partners’ services through our website, third party sites, and via e-mail or text message.
To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
For marketing the Reply Services.
For testing, research, analysis, and product development, including to develop and improve the Reply Services to better serve you and/or to provide Services more effectively.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To help Reply compile aggregate data about our website traffic and interaction with the website so we can offer you better experience and tools in the future.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Reply’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our website users, information obtained from our Customers through the use our Services is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosure of Personal Information
We may disclose your Personal Information to a third party or Reply Group Companies (as defined in our Reply Marketing Privacy Notice) for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, Reply has disclosed the following categories of Personal Information for a business purpose:
We disclose Personal Information for a business purpose to the following categories of third parties: (i) service providers (e.g., processors, contractors, suppliers, vendors, etc.); (ii) data aggregators; (iii) Affiliates (as defined in our Reply Marketing Privacy Notice) and business partners; (iv) acquirers of business assets; (v) ad networks; (vi) government entities; (vii) operating systems and platforms; and (viii) social networks.
We retain your Personal Information for as long as needed or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using Personal Information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
The CCPA defines "sale" as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-contextual behavioral advertising. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of Personal Information: identifiers, and Internet or other electronic network activity information. We disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share Personal Information about individuals we know are under age 16.
Your Rights and Choices
The CCPA provides California residents (Consumers) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Note that these rights only apply to Personal Information we collect and process under this notice where we decide how and why to use Personal Information (i.e., as a “Business” under the CCPA). For Personal Information we process on behalf of our business clients (i.e., in our capacity as a "Service Provider” under the CCPA), please submit your request directly to the business client with whom you have a relationship, and we will provide reasonable assistance to that business client as necessary to enable them to respond to your requests to exercise your privacy rights.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information. Once we receive and confirm your verifiable Consumer request (see Exercising Your Privacy Rights), we will disclose to you:
The categories of Personal Information we collected about you.
The categories of sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting, selling, or sharing that Personal Information.
The categories of third parties to whom we disclose that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold, shared, or disclosed your Personal Information for a business purpose, two separate lists disclosing:
Sales and sharing, identifying the Personal Information categories that each category of recipient purchased;
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Right to Correct. You have the right to request that we correct incorrect Personal Information.
Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request (see Exercising Your Privacy Rights), we will delete (and direct our service providers and Affiliates (as defined in our Reply Marketing Privacy Notice) to delete) your Personal Information from our records, unless an exception applies.
Right to Limit Use. We do not engage in uses or disclosures of “sensitive Personal Information” that would trigger the right to limit use of sensitive Personal Information under the CCPA.
Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. While we do not “sell” Personal Information in the traditional sense (i.e., for money), our use of third-party analytics and advertising cookies may be considered “selling” and “sharing” under CCPA. To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, click here or use the [Do Not Sell or Share My Personal Information][Your Privacy Choices] link at the bottom of our website.
You also have the right to opt-out of “sales” and “sharing” of your Personal Information through the use of an opt-out preference signal. If our website detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC— signal, we will opt that browser or device out of cookies on our website that result in a “sale” or “sharing” of your Personal Information. If you come to our website from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well.
Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.
Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your cookie settings, you may visit https://www.aboutads.info/choices. You may need to do this again each time you use a different IP address or device. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can send us an e-mail stating your request to marketing.privacy@reply.com.
Promotional Offers from the Company. If you do not wish to have your contact information (including e-mail address) used by the Company to promote our own or third parties’ products or services, you can click the “unsubscribe” link at the bottom of the relevant promotional e-mail or send us an e-mail stating your request to marketing.privacy@reply.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. Such requests do not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can set your browser opt-out accordingly.
We do not control third parties’ collection or use of your information to serve interest-based advertising. These third parties, however, may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
Exercising Your Privacy Rights. To exercise the privacy rights described above, please submit a verifiable Consumer request to us by e-mailing us at marketing.privacy@reply.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child.
You may only make a verifiable Consumer request for access or data portability twice within a 12- month period. The verifiable Consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, such as your name and email address.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable Consumer request does not require you to create an account with us.
We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
The response we provide will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically PDF format. We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We reserve the right to amend this privacy notice at our discretion and any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date. If we make any changes to this Policy that materially affect our practices regarding our use of the Personal Information that we have previously collected from you, we will endeavor to provide you with notice, such as by posting prominent notice on our website.
If you have any questions or comments about this notice, the ways in which Reply collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please to not hesitate to contact us at:
Website: www.reply.com
E-mail: marketing.privacy@reply.com
Postal Address:
Reply S.p.A.
Corso Francia n. 110
Torino, Italy