respond-io

Privacy Policy

Respond.io collects some Personal Data from its Users.


Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.


This document contains a section dedicated to Brazilian Users and their privacy rights.


This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

ROCKETBOTS LIMITED

Unit 2406B, 24/F, Low Block, Grand Millennium Plaza,

181 Queen's Road Central, Sheung Wan, Hong Kong


For GDPR, Cookies and Data Protection/Privacy related matters, email us at [email protected].

TYPES OF DATA COLLECTED

Among the types of Personal Data that respond.io collects, by itself or through third parties, there are: Usage Data; Tracker; email address; phone number; first name; last name; various types of Data; password; Data communicated while using the service.


Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.


Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using respond.io.


Unless specified otherwise, all Data requested by respond.io is mandatory and failure to provide this Data may make it impossible for respond.io to provide its services. In cases where respond.io specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.


Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.


Any use of Cookies – or of other tracking tools – by respond.io or by the owners of third-party services used by respond.io serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.


Users are responsible for any third-party Personal Data obtained, published or shared through respond.io and confirm that they have the third party's consent to provide the Data to the Owner.

MODE AND PLACE OF PROCESSING THE DATA

METHODS OF PROCESSING

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.


The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.


In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of respond.io (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

LEGAL BASIS OF PROCESSING

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
  • In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

PLACE

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.


Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.


If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.


If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

RETENTION TIME

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

MANAGING DATA DELETION REQUESTS

User data deletion requests are processed and handled securely and within specified timelines. The following outlines the scenarios under which data deletion requests are managed and the corresponding turnaround time.

Subscription Cancellation and Direct Deletion Request: Upon subscription cancellation, all User data associated with the account is marked for deletion from respond.io within 90 business days. Furthermore, Users can contact respond.io support team to request data deletion from respond.io. These direct requests are processed and completed within 7 business days.

Channel and Third-Party Connection Deletions: When channels or associated third-party connections, such as channels and integrations, are deleted, all User and account data associated with those channels or connections are deleted from respond.io within 7 business days.

Third-Party Integration Data Deletion Requests: When a data deletion request is received through third-party connected integrations, such as Meta, all User data and account details associated with the originating account are deleted from respond.io within 90 business days. Expedited deletion requests may also be submitted to respond.io support team and are processed within 7 business days.

Unique data deletion requests not explicitly covered by the scenarios listed above may also be submitted. Such requests are evaluated on a case-by-case basis to ensure compliance with applicable data protection regulations.

Turnaround times for data deletion may vary depending on the complexity or volume of the requests, but all efforts are made to process them as promptly as possible. Users can reach out to respond.io support team to inquire on the statuses of their data deletion requests.

THE PURPOSES OF PROCESSING

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from external platforms, Tag Management, Contacting the User, Analytics, Managing contacts and sending messages, Handling payments, Infrastructure monitoring, Hosting and backend infrastructure, User database management, Connecting Data, Content performance and features testing (A/B testing), Data transfer outside the EU, Registration and authentication provided directly by respond.io, Interaction with live chat platforms, Registration and authentication, Remarketing and behavioral targeting, SPAM protection, Platform services and hosting, Advertising and Traffic optimization and distribution.


For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following services:

ADVERTISING

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on respond.io, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside respond.io. For more information, please check the privacy policies of the relevant services.

Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.

JSDELIVR (jsdelivr.com)

  • JSDELIVR is an advertising service provided by jsdelivr.com.
  • Personal Data processed: Tracker; Usage
  • Data.Place of processing: United States – Privacy Policy.

ANALYTICS

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Ireland Limited)

  • Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of respond.io, to prepare reports on its activities and share them with other Google services.
  • Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy – Opt Out.

Attribution (Attribution, LLC)

  • Attribution is an analytics service provided by Attribution, LLC.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: United States – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

  • Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on respond.io. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy.

MixPanel (MixPanel)

  • MixPanel is an analytics service provided by Mixpanel Inc.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: United States – Privacy Policy – Opt Out.

CONNECTING DATA

This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.

This results in Data flowing through these services, potentially causing the retention of this Data.

Zapier (Zapier, Inc.)

  • Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.
  • Personal Data processed: Tracker.
  • Place of processing: United States – Privacy Policy.

CONTACTING THE USER

  • Mailing list or newsletter (respond.io).

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning respond.io. Your email address might also be added to this list as a result of signing up to respond.io or after making a purchase. Personal Data processed: Tracker.

  • Contact form (respond.io).

By filling in the contact form with their Data, the User authorizes respond.io to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data processed: email address; first name; last name.

CONTENT PERFORMANCE AND FEATURES TESTING (A/B TESTING)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of respond.io.

Google Optimize (Google Ireland Limited)

  • Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").
  • Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy.

DATA TRANSFER OUTSIDE THE EU

The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.

Users can inquire with the Owner to learn which legal basis applies to which specific service.

Data transfer abroad based on standard contractual clauses (respond.io)

If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

Personal Data processed: various types of Data.

DISPLAYING CONTENT FROM EXTERNAL PLATFORMS

This type of service allows you to view content hosted on external platforms directly from the pages of respond.io and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google Ireland Limited)

  • Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows respond.io to incorporate content of this kind on its pages.
  • Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
  • Place of processing: Ireland – Privacy Policy.

HANDLING PAYMENTS

Unless otherwise specified, respond.io processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Respond.io isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc)

  • Stripe is a payment service provided by Stripe Inc.
  • Personal Data processed: various types of Data as specified in the privacy policy of the service.
  • Place of processing: United States – Privacy Policy.

HOSTING AND BACKEND INFRASTRUCTURE

This type of service has the purpose of hosting Data and files that enable respond.io to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of respond.io.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  • Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
  • Personal Data processed: various types of Data as specified in the privacy policy of the service.
  • Place of processing: Singapore – Privacy Policy.

INFRASTRUCTURE MONITORING

This type of service allows respond.io to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of respond.io.

Sentry (Functional Software, Inc. )

  • Sentry is a monitoring service provided by Functional Software, Inc. .
  • Personal Data processed: various types of Data as specified in the privacy policy of the service.
  • Place of processing: United States – Privacy Policy.

INTERACTION WITH LIVE CHAT PLATFORMS

This type of service allows Users to interact with third-party live chat platforms directly from the pages of respond.io, in order to contact and be contacted by respond.io‘s support service.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

Facebook Messenger Customer Chat (Facebook Ireland Ltd)

  • The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook Ireland Ltd
  • Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy.

Respond.io Widget

  • Respond.io is a business messaging platform that connects customers from any channel to every team.

MANAGING CONTACTS AND SENDING MESSAGES

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Customer.io (Peaberry Software Inc.)

  • Customer.io is an email address management and message sending service provided by Peaberry Software Inc.
  • Personal Data processed: email address; Tracker; Usage Data.
  • Place of processing: United States – Privacy Policy.
  • Sendgrid (Sendgrid)
  • Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
  • Personal Data processed: email address; first name; last name.
  • Place of processing: United States – Privacy Policy.

PLATFORM SERVICES AND HOSTING

These services have the purpose of hosting and running key components of respond.io, therefore allowing the provision of respond.io from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Webflow (Webflow, Inc.)

Webflow is a platform provided by Webflow, Inc. that allows the Owner to build, run and host respond.io. Webflow is highly customizable and can host websites from simple blogs to complex e-commerce platforms.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy – Opt out.

REGISTRATION AND AUTHENTICATION

By registering or authenticating, Users allow respond.io to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, respond.io will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Google OAuth (Google Ireland Limited)

  • Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
  • Personal Data processed: various types of Data as specified in the privacy policy of the service.
  • Place of processing: Ireland – Privacy Policy.

REGISTRATION AND AUTHENTICATION PROVIDED DIRECTLY BY RESPOND.IO

By registering or authenticating, Users allow respond.io to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

Direct registration (respond.io)

The User registers by filling out the registration form and providing the Personal Data directly to respond.io.

Personal Data processed: email address; first name; last name; password.

REMARKETING AND BEHAVIORAL TARGETING

This type of service allows respond.io and its partners to inform, optimize and serve advertising based on past use of respond.io by the User.

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.

Some services offer a remarketing option based on email address lists.

In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ads Remarketing (Google Ireland Limited)

  • Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of respond.io with the Google Ads advertising network and the DoubleClick Cookie.
  • Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy – Opt Out.
  • Facebook Remarketing (Facebook Ireland Ltd)
  • Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of respond.io with the Facebook advertising network.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy – Opt Out.

SPAM PROTECTION

This type of service analyzes the traffic of respond.io, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited)

  • Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  • The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: Ireland – Privacy Policy.

TAG MANAGEMENT

This type of service helps the Owner to manage the tags or scripts needed on respond.io in a centralized fashion.

This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited)

  • Google Tag Manager is a tag management service provided by Google Ireland Limited.
  • Personal Data processed: Usage Data.
  • Place of processing: Ireland – Privacy Policy.
  • Segment (Segment Inc.)
  • Segment is a tag management service provided by Segment.io, Inc.
  • Personal Data processed: Tracker; Usage Data.
  • Place of processing: United States – Privacy Policy.

TRAFFIC OPTIMIZATION AND DISTRIBUTION

This type of service allows respond.io to distribute their content using servers located across different countries and to optimize their performance.

Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between respond.io and the User's browser.

Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

  • Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  • The way Cloudflare is integrated means that it filters all the traffic through respond.io, i.e., communication between respond.io and the User's browser, while also allowing analytical data from respond.io to be collected.
  • Personal Data processed: Tracker.
  • Place of processing: United States – Privacy Policy.

USER DATABASE MANAGEMENT

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to respond.io, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving respond.io.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on respond.io.

HubSpot CRM (HubSpot, Inc.)

  • HubSpot CRM is a User database management service provided by HubSpot, Inc.
  • Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
  • Place of processing: United States – Privacy Policy.

INFORMATION PF OPTING OUT OF INTEREST-BASED ADVERTISING

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

FURTHER INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA

  • Push notifications
  • Respond.io may send push notifications to the User to achieve the purposes outlined in this privacy policy.
  • Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for respond.io, some or all of the apps on the particular device.
  • Users must be aware that disabling push notifications may negatively affect the utility of respond.io.

THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

DETAILS ABOUT THE RIGHT TO OBJECT TO PROCESSING

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.


Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

APPLICABILITY OF BROADER PROTECTION STANDARDS

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

  • Is performed by an Owner based within the EU;
  • Concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
  • Concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

COOKIE POLICY

Respond.io uses Trackers. To learn more, the User may consult the Cookie Policy.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

LEGAL ACTION

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of respond.io or the related Services.

ADDITIONAL INFORMATION ABOUT USER'S PERSONAL DATA

In addition to the information contained in this privacy policy, respond.io may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

SYSTEM LOGS AND MAINTENANCE

For operation and maintenance purposes, respond.io and any third-party services may collect files that record interaction with respond.io (System logs) use other Personal Data (such as the IP Address) for this purpose.

INFORMATION NOT CONTAINED IN THIS POLICY

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

HOW "DO NOT TRACK" REQUEST ARE HANDLED

Respond.io does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

CHANGES TO THIS PRIVACY POLICY

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within respond.io and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.


Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

INFORMATION FOR USERS RESIDING IN BRAZIL

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running respond.io and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).

THE GROUNDS ON WHICH WE PROCESS YOUR PERSONAL INFORMATION

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

  • Your consent to the relevant processing activities;
  • Compliance with a legal or regulatory obligation that lies with us;
  • The carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
  • Studies conducted by research entities, preferably carried out on anonymized personal information;
  • The carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
  • The exercising of our rights in judicial, administrative or arbitration procedures;
  • Protection or physical safety of yourself or a third party;
  • The protection of health – in procedures carried out by health entities or professionals;
  • Our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and credit protection.
  • To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

CATEGORIES OF PERSONAL INFORMATION PROCESSED

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.

WHY WE PROCESS YOUR PERSONAL INFORMATION

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

YOUR BRAZILIAN PRIVACY RIGHTS, HOW TO FILE A REQUEST AND OUR RESPONSE TO YOUR REQUESTS

YOUR BRAZILIAN PRIVACY RIGHTS

You have the right to:

  • Obtain confirmation of the existence of processing activities on your personal information;
  • Access to your personal information;
  • Have incomplete, inaccurate or outdated personal information rectified;
  • Obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
  • Obtain information on the possibility to provide or deny your consent and the consequences thereof;
  • Obtain information about the third parties with whom we share your personal information;
  • Obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
  • Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
  • Revoke your consent at any time;
  • Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
  • Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
  • Request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • Request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
  • You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

HOW TO FILE YOUR REQUEST

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We will strive to promptly respond to your requests.


In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.


In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.


You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.


In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.


In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF BRAZIL PERMITTED BY THE LAW

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
  • when the transfer is necessary to protect your life or physical security or those of a third party;
  • when the transfer is authorized by the ANPD;
  • when the transfer results from a commitment undertaken in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal attribution of public service;
  • when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

DEFINITION AND LEGAL REFERENCES

PERSONAL DATA (OR DATA)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

USAGE DATA

Information collected automatically through respond.io (or third-party services employed in respond.io), which can include: the IP addresses or domain names of the computers utilized by the Users who use respond.io, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

USER

The individual using respond.io who, unless otherwise specified, coincides with the Data Subject.

DATA SUBJECT

The natural person to whom the Personal Data refers.

DATA PROCESSOR (OR DATA SUPERVISOR)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

DATA CONTROLLER (OR OWNER)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of respond.io. The Data Controller, unless otherwise specified, is the Owner of respond.io.

RESPOND.IO (OR THIS APPLICATION)

The means by which the Personal Data of the User is collected and processed.

SERVICE

The service provided by respond.io as described in the relative terms (if available) and on this site/application.

EUROPEAN UNION (OR EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

COOKIE

Cookies are Trackers consisting of small sets of data stored in the User's browser.

TRACKER

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

LEGAL INFORMATION

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).


This privacy policy relates solely to respond.io, if not stated otherwise within this document.

Latest update: September 20, 2022