Privacy Policy

5. HOW DOES REO SHARE PERSONAL INFORMATION?

• 5.1 Reo may share personal information with the following third parties for the purposes stated in Section 4 (How and why does Reo use this information):
• 5.1.1 With Clients: Reo shares Profiles with Clients to provide Services andgrant access to accurate and updated information.
• 5.1.2 With Reo’s affiliates: Reo may disclose information to its affiliated companies, including any parents, subsidiaries, and other companies under common control and ownership with Reo. These affiliates may act on Reo’s behalf for the purposes outlined in this Policy.
• 5.1.3 With Reo’s service providers: Reo relies on service providers to provide various services and tools including: (a) customer support; (b) email communications; (c)infrastructure; (d) data storage; (f) security services; (g) web-hosting services; (h) data analytics; (i) integrating Reo to Client’s CRM tools, email systems, browser extensions (such as Chrome add-ons), or other software; (j) collection of information for creating Profiles; (k) collection of information to update or correct the information on the existing Profiles; (l) and/or system logging services. These service providers will be given access on a need-to-know basis to the information collected by Reo, which may contain personal information about individuals. To ensure the security and privacy of your information, Reo conducts thorough evaluations of the privacy and security practices of its service providers before engaging their services. Additionally, Reo mandates that its service providers enter into agreements that uphold the confidentiality of your information and adhere to data protection obligation sin accordance with applicable privacy laws. Reo’s commitment to maintaining the security and privacy of your information remains a top priority.
• 5.1.4 For Legal Reasons: Reo may disclose information, including, to a third party if it believes in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities ,including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect Reo’s rights or those of Reo’s affiliates, Clients, and Users, or as part of legal proceedings affecting or that may affect Reo or Reo’s affiliates, Clients, or Users; (iv) to allow Reo to exercise its legal rights or respond to a legal claim; and/or (v) to respond to requests for access to information to the extent necessary to comply with applicable laws.
• 5.1.5 To an acquirer of Reo:  If Reo or substantially all of Reo’s assets are acquired, or in the event of a merger or bankruptcy, your personal information that is in Reo’s possession may be among the transferred assets.

6. HOW LONG DOES REO RETAIN PERSONAL INFORMATION?

• 6.1  Reo retains your personal information only for as long as necessary to fulfil the purposes described in this Policy.
• 6.2  Reo retains the information collected from its Clients for the duration required to provide Services to the Client or during the validity of Reo’s agreement with the Client. Information collected from Clients that may be relevant to fulfil Reo’s legal obligations, settle disputes or enforce Reo’s policies, may be retained for longer as required.
• 6.3  Reo retains the personal information it collects from its Users for as long as theUser’s information is likely required for Reo to effectively meet the User’s requests, render Services, or as long as the User’s account remains active on Reo, whichever is later. Reo may retain your information for 3 (Three) years or later, following the last activity in your account, in order to comply with Reo’s legal and contractual obligations or to protect Reo from any potential disputes or as long as required by laws applicable to record-keeping, and to have proof and evidence concerning your relationship with Reo, should any legal issues arise following the termination of your account).
• 6.4 Additionally, Reo retains the information that it collects when an individual exercises their right to opt-out, withdraw consent, or erasure for the duration necessary to ensure information related to such individuals is removed from Reo’s Database.
• 6.5  The retention periods are determined considering the quantity, nature, and sensitivity of the personal information, as well as the purposes for which it was collected. Once the retention period expires, Reo will delete the information. In cases where deletion is not feasible, appropriate measures will be implemented to prevent any further use of the information.

7. YOUR RIGHTS

• 7.1  Reo provides options for managing your information and preferences. Depending on where you reside and the law applicable to you, you may have the choice to opt out of Reo’s database or submit requests to access and update your information.You can reach out to Reo at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.
• 7.2  To the extent provided under applicable laws, individuals may have the following rights (please note that this is not an exhaustive list):
• 7.2.1  The right to access: Individuals may have theright to request access to, and a copy of, their personal information free ofcharge, as well as certain information about Reo’s processing activitiesrelated to their personal information including: the purposes of the processing;the categories of personal data concerned; the recipients or categories ofrecipient to whom the personal data have been or will be disclosed; informationpertaining to the source of data; information regarding automateddecision-making, including profiling.
• 7.2.2 The right to correct: Individuals may request correction or completion of their personal information if it is inaccurate or incomplete. Taking into account the purposes of the processing, the individual may have the right to complete any incomplete or inaccurate personal information, including by means of providing a supplementary statement.
• 7.2.3 The right to restrict processing: Individuals may have theright to obtain from Reo restriction of processing in certain events, such aswhen, the accuracy of the personal data is contested, for a period enabling Reoto verify the accuracy of the personal data or when the data subject hasobjected to processing;
• 7.2.4 The right to data portability: Individuals may havethe right to request a copy of their data in a machine-readable format. They mayalso request that Reo transmit their data to another entity where technicallyfeasible.
• 7.2.5 The right to erasure : Individuals may have the right to have their data erased from Reo’s Database on certain grounds, such as if the personal information is no longer necessary for the purpose for which it was collected, if they withdraw consent and if no other legal basis for processing exists,.
• 7.2.5 The right to object to processing: Individuals may have the right to object to processing by Reo if Reo is processing information based on legitimate interests, and their fundamental rights to data privacy and protection outweigh Reo’s legitimate interest in continuing the processing.Where data is processed for direct marketing (including profiling), data subjects may be able to object to such processing.
• 7.3 If you wish to exercise any of your rights under applicable law, please reach out to Reo at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.

8. INFORMATION FOR INDIVIDUALS RESIDING IN THE EUROPEAN ECONOMIC AREA

• 8.1   Reo strives to comply with the provisions of the General Data Protection Regulation(the “GDPR”) concerning any personal information it possesses about individuals based in the European Economic Area (for the purpose of thisSection 8, referred to as “Data Subjects”). Reo only processes personal information of Data Subjects when Reo  a lawful basis to do so, which may include the following:
• 8.1.1  Consent;
• 8.1.2 Performance of Reo’s agreement to provide Services or other applicable agreements;
• 8.1.3 Compliance with a legal obligation to which Reo is subject; and/ or
• 8.1.4  Legitimate interests of Reo in: (a) operating a successful business; (b) providing accurate and up-to-date Profiles, allowing Clients to engage with other businesses in effective online and offline interactions; (c) direct marketing and sales; d) ensuring the safety and proper functioning of Services; (e) fraud prevention, network and information security; (f) ensuring that Reo’s policies and agreements are complied with; (g) exercise of Reo’s rights, the defense of Reo’s legal rights and compliance with Reo’s legal obligations.
• 8.2  Reo respects the rights of Data Subjects outlined in Articles 12-23. Data Subjects have the right to access and correct their personal information, to data portability, to request data erasure, to restrict processing and to object to processing.
• 8.3 To make opt-out requests, inquiries related to privacy, or exercise your rights under GDPR, please reach out to Reo at the contact information listed under Section 12 (ContactUs) at the end of this Policy
• 8.4 Depending on Reo’s activity, Reo may act as a controller and processor under the GDPR, as explained below:
• 8.4.1 Reo acts as controller: When Reo collects and uses information about Data Subjects who are Clients, Users or Visitors, Reo acts as a controller. Reo also acts as a controller when Reo directly collects information about Data Subjects to create and maintain Profiles to provide Services
• 8.4.1 Reo acts as a processor: When Clients use Services, they act as the controller and are responsible for ensuring lawful processing of personal information collected about Data Subjects. In those cases, Reo acts as the processor and receives personal information as agents of Clients solely for processing purposes instructed by them. Clients are solely responsible for determining whether and how they wish to use Services and for ensuring that all necessary legal requirements are met, including providing adequate notice to third-party individuals and obtaining informed consent where necessary. Clients are also responsible for handling Data Subject rights requests under GDPR. Reo’s obligations regarding personal information for which Reo is solely a processor are defined in Reo’s agreements with Clients and are not covered by this Policy.

9. INFORMATION FORINDIVIDUALS RESIDING IN CALIFORNIA

• 9.1  TheCalifornia Consumer Privacy Act of 2018 (the “CCPA”) grants specific rights to residents of California (for the purpose of this Section 9, referred to as “Consumers”)regarding their personal information.
• 9.2  Subject to the exceptions, limitations and restrictions in the CCPA, a Consumer has the right to access information, data portability, data correction and data deletion.
• 9.3 To exercise any of your rights, please reach out to us at the contact information listed under Section 12 (Contact Us) at the end of thisPolicy.

11. CHANGES TO THIS POLICY

• 11.1 Reo may update this Policy periodically in order to accommodate any changes in Reo’s information processing practices. If there are significant changes to this Policy, such as modifications to Reo’s processing purposes, or the methods for exercising your rights in relation to Reo’s processing activities, Reo will notify you accordingly, through email or by posting a notice on the homepage ofReo’s Website prior to the changes taking effect. Continued use of the Reo’sWebsite or the Services after any updates to this Policy constitutes acceptanceof the updated Policy

12. CONTACT US

• 12.1 For questions, concerns or complaints, please contact us at:contact@reo.dev 
• 12.2 If you have not received a satisfactory response to any of your questions, concerns or complaints that were sent to the aforementioned emails/ addresses, we apologize for the inconvenience. We encourage you to reach out to our Founders at: founders@reo.dev
• 12.3   We value your feedback and strive to address any issues promptly and effectively.
• 12.4   Please note that in order to verify an individual's identity, Reo may require them to provide Reo with personal information before accessing any records containing information about them or giving effect to any rights they may have under the applicable law

13. COMPLAINTS

• 13.1  If       you believe that your information has been mishandled or if you are dissatisfied with Reo’s response to your requests concerning the use of your personal information, you have the option to file a complaint.  
• 13.2  Please send the details of your complaint to:
  13.2.1   In the European Economic Area: contact details of EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
  13.2.2.       In the UK: you can contact theInformation Commissioner's Office at https://ico.org.uk/.
  13.2.3.       For residents of other countries: you have the right to submit your complaint to the appropriate data protection regulator inyour country of residence.