Reply Pro Privacy Policy

Privacy Policy for Customer Surveys January 01, 2020

This Privacy Policy applies to Reply Pro’s processing of Personal Data collected through this survey collection service where Survey Privacy Policy is posted, linked or referenced (collectively, the “Reply Pro Services”). “Personal Data” is information relating to an identified or identifiable natural person. Reply Pro Services are owned and/or operated by Basedin, Inc. (D.B.A. Reply Pro).  This Privacy Policy addresses how we collect and process your Personal Data. 
REVIEW THIS PRIVACY NOTICE CAREFULLY. Your Personal Data will be collected and processed as described in this Privacy Policy.

If you have not done so, review Reply Pro Terms of Service, which sets forth the terms governing your use of our websites, applications, services and mobile applications (“Reply Pro Services”).
IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR TERMS OF SERVICE, DO NOT USE ANY OF THE REPLY PRO SERVICES.

1. CHANGES TO PRIVACY POLICY 
2. CATEGORIES OF PERSONAL DATA PROCESSED BY Reply Pro
3. HOW WE COLLECT INFORMATION AND PURPOSES OF PROCESSING 
4. LEGAL GROUNDS FOR PROCESSING 
5. HOW WE USE AND SHARE PERSONAL DATA 
6. RETENTION AND DISPOSAL OF PERSONAL DATA 
7. YOUR RIGHTS AND CHOICES CONCERNING PERSONAL DATA PROCESSING 
8. CONSEQUENCES OF NOT PROVIDING PERSONAL DATA
9. MANAGING YOUR ACCOUNT INFORMATION 
10. CHILDREN’S PRIVACY
11. LINKS TO THIRD PARTY SERVICES 
12. INFORMATION SECURITY
13. GEOGRAPHIC CONSIDERATIONS AND CROSS-BORDER TRANSFERS OF PERSONAL DATA 
14. HOW TO CONTACT US
15. DATA CONTROLLER AND DATA PROTECTION OFFICER
16. SOCIAL MEDIA AND TECHNOLOGY INTEGRATIONS

BUSINESS TO BUSINESS SECTION 
1B: FACEBOOK CONNECT
2B: SOCIAL NETWORKS AND THIRD_PARTY SERVICES
3B  INFORMATION WE COLLECT 
4B: REFRESHING TOKENS 

1. CHANGES TO THIS PRIVACY POLICY 
We will update this Privacy Policy from time to time when we make changes impacting the Privacy Policy, such as adding new services and applications, improving our services, and addressing changes in technologies and laws. The Effective Date of this Privacy Policy, which is set forth at the top of this webpage, reflects the date the Privacy Policy was last updated. Reply Pro will provide notice to you if these changes are material, and where required by applicable law, we will obtain your consent. This notice will be provided by posting notice of the changes on our website or through our applications. 

2. CATEGORIES OF PERSONAL DATA PROCESSED BY REPLY PRO
Reply Pro conducts market research on behalf of companies who wish to better understand consumer preferences about their goods and services. These companies are our “Clients.” 
We conduct surveys on behalf of our Clients (collectively, “Surveys”) and use that information to derive consumer insights, such as where, when and how often consumers visit retail locations and their experiences during the visits. When you take a Survey or use Reply Pro Services, we collect Personal Data that you voluntarily provide to us. 
The Personal Data we collect may include: (1) contact data (such as e-mail address, telephone number, and employer); (2) demographic data (such as gender, date of birth, and zip code); (3) your responses on surveys to the extent the information identifies you or is linked to you as an individually identifiable person.

3. HOW WE COLLECT INFORMATION AND PURPOSES OF PROCESSING 
We collect and process information you provide to us and from your use of Reply Pro Services. The information we collect and how we process it depends on how you access and use Reply Pro Services.

From You:
We collect information from you when you:
Complete a Survey: We collect the information you submit in Survey responses about your consumer experiences and preferences. We may combine information received in your Survey responses with information we receive from our Clients, such as information about your involvement in our Clients’ loyalty programs, to better understand your consumer experiences. We also may combine information received in your Survey responses with information received in Survey responses from other users to better understand overall consumer experiences. When you complete a Survey, the information you choose to provide us will be used in reports and other analyses of consumer experiences and preferences for our Clients or for any other uses we disclose to you at the time the information is collected. If you do not wish to have your information used in reports, analyses or as otherwise disclosed to you, you may choose not to complete a Survey.

From our Clients:
For some of our products and services, our Clients may send us information about your interactions with their brands, products, and services, which may include information relating to any loyalty programs in which you are enrolled and information about your transactions with our Clients. We may combine this information with other information we collect to enhance the market research we conduct and services we provide for our Clients

4. LEGAL GROUNDS FOR PROCESSING 
4.1. We process your contact data, demographic data, and responses on Surveys when you complete a Survey or use Reply Pro Services. We process such Personal Data based on our Clients’ legitimate interests in obtaining feedback from their customers to help them improve their products and services for the benefit of their customers and their businesses, and based on Reply Pro’s legitimate interests in enhancing Reply Pro’s products, services and market research and in responding to users’ requests for assistance or information. 
4.2. We process information received from our Clients concerning your interactions with their brands, products and services. We process such information based on Reply Pro’s and Reply Pro’s Clients’ legitimate interests, including improving and enhancing Reply Pro’s and our Clients’ products and services and enhancing Reply Pro’s market research. 

5. HOW WE USE AND SHARE PERSONAL DATA 
How we use and share information that we collect or that you provide to us depends on how you use or access the Reply Pro Services. Where required by law, Reply Pro will comply with your request that we cease providing personal data to third parties:

Communicating with You: Your Personal Data will be used, as needed, to manage our relationship and communicate with you by mail, telephone, e-mail, mobile alerts, and SMS text messaging. Unless a survey respondent expressly requests communication, Reply Pro will not contact a survey respondent other than necessary contact to verify the integrity of a survey, to deliver Surveys, to provide rewards or benefits earned as a result of taking a survey, or to provide customer service. Although Reply Pro does not use your Personal Data for direct marketing purposes, you should review the Privacy Policy of the client for which we are collecting your Personal Data to determine if such client does so. We may share your Personal Data with service providers that assist us in managing our relationship with you. 

Performing Services You Request: We may use and share your Personal Data in order to perform services you request or functions you initiate, such as when you post information and materials on message boards, forums, or on our Social Media pages. In addition, when you give us permission, we may disclose your Personal Data in order to identify you to anyone to whom you send communications through the Reply Pro Services. Further, we may use and share your Personal Data with third parties in order to provide rewards and fulfill benefits you have requested and earned by taking Surveys. If you elect to participate in a sweepstakes or other promotion, we send your information to third party administrators of those promotions, so they can answer your questions or contact you about a prize you won or other issues related to the promotion. 

Complying with Legal Obligations and Enforcing Legal Rights: We may also share the information we collect from you, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance, and corporate governance functions. We will disclose Personal Data as we deem necessary to respond to a subpoena, binding order of a data protection authority or judge, legal process, governmental request or any other legal or regulatory obligation, in each case this may be an entity outside your country of residence. We may also share Personal Data as required to pursue available remedies or limit damages we may sustain.

Transferring Data in Connection with Corporate Changes: We may transfer information about you, including Personal Data, in connection with any actual or impending reorganization, merger, sale, joint venture, assignment, transfer, acquisition or other change of ownership or control by or of Reply Pro or any affiliated company (in each case whether in whole or in part), including, without limitation, in connection with any bankruptcy or similar proceeding. Any such entity to which we transfer Personal Data will be required to provide you with notice of any purposes of processing not compatible with the purposes set forth in this Privacy Policy, as well as any privacy practices that are materially different than the practices set forth in this Privacy Policy. Where required by law, such entity also will be required to obtain your consent.

Using Personal Data for Other Business Purposes: We also use your Personal Data for other legitimate business purposes, such as product and service development and administration of Reply Pro Services.
 
6. RETENTION AND DISPOSAL OF PERSONAL DATA 
We will retain your Personal Data in our records for no longer than is necessary for the purposes for which it was originally collected. When such information is no longer needed for the purposes for which it was originally collected, we will securely delete all of your electronic Personal Data, and securely shred any hard copy Personal Data, except for what is needed to comply with our legal obligations. 

7. YOUR RIGHTS AND CHOICES CONCERNING PERSONAL DATA PROCESSING
You may discontinue participating in Surveys at any time by no longer accessing the Reply Pro Services.
If you reside in a location with laws or regulations granting you rights to request specific actions relating to your Personal Data, you will have the specific rights granted to you by such law[s] or regulation[s], which may include the right to request access to and rectification (e.g., amendment or supplementation) or erasure of your Personal Data, the right to transfer your data (i.e., data portability), restriction of processing of your Personal Data, as well as the right to object to processing of your Personal Data, the right to withdraw your consent, the right to cancel your account, and the right to lodge a complaint with a supervisory authority. All such requests will be handled in accordance with the parameters set forth in applicable laws and regulations. 
If you reside in the European Union, you have the right under the General Data Protection Regulation to request from Reply Pro access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, the right to withdraw your consent, and the right to lodge a 6 complaint with a supervisory authority. If you reside outside of the European Union, you also may have certain data subject rights under your local laws. 
To make such a request, contact our Data Protection Officer by email at privacyofficer@replypro.io or by writing to Data Protection Officer, Reply Pro, 301 S. Capitol Blvd. Boise, ID 83702

8. CONSEQUENCES OF NOT PROVIDING PERSONAL DATA
Although participation in our Surveys is voluntary, you may not qualify for certain incentives, rewards, or benefits if you do not provide all information requested by a Survey. 

9. COOKIES POLICY
Reply Pro does not use cookies for surveys.

10. MANAGING YOUR ACCOUNT INFORMATION
You can visit the account section of the applicable Reply Pro Service to manage and correct factual inaccuracies in the information we have about you. If you have questions about how to access or correct your Personal Data, contact our Data Protection Officer  by email at privacyofficer@replypro.io or by writing to Data Protection Officer, Reply Pro, 301 S. Capitol Blvd. Boise, ID 83702

11. CHILDREN’S PRIVACY 
Reply Pro Services are intended for general audiences and are not directed to children who are under the age at which they may provide consent for the processing of their Personal Data in any jurisdiction where we operate. We do not knowingly collect Personal Data from such persons. If you become aware that a child under the age at which [s]he may legally provide consent to the processing of his/her Personal Data has provided us with Personal Data without parental consent, contact our Data Protection Officer by email at privacyofficer@replypro.io or by writing to Data Protection Officer, Reply Pro, 301 S. Capitol Blvd. Boise, ID 83702. If we become aware that a child under the age at which [s]he may provide consent to Personal Data processing in his or her jurisdiction has provided us with Personal Data without parental consent, we take steps to remove such information and terminate the child's account as soon as possible.

12. LINKS TO THIRD PARTY SERVICES 
Reply Pro Services may contain links to third party websites and services (“Third Party Services”) with which Reply Pro has no affiliation. A link to any Third Party Service does not mean we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy practices and not the privacy practices set forth in this Privacy Policy.  

13. INFORMATION SECURITY
Reply Pro has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure. 

However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical, physical, and organizational measures that Reply Pro has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data. If you believe that your Reply Pro account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at privacyofficer@replypro.io or or by writing to Data Protection Officer, Reply Pro, 301 S. Capitol Blvd. Boise, ID 83702.

14. GEOGRAPHIC CONSIDERATIONS AND CROSS-BORDER TRANSFERS OF PERSONAL DATA 
Reply Pro controls and operates Reply Pro Services from the United States of America. Reply Pro may transfer, store and process your Personal Data in the United States, the United Kingdom, Japan, or another location in Asia or in the European Union. Note that data protection and privacy laws of the country to which your Personal Data is transferred may not be as comprehensive as the laws in your country. For example, Personal Data transferred to the 8 United States may be subject to lawful access requests by federal and state authorities in the United States.

Any transfers of Personal Data from the European Economic Area (“EEA”) to the United States are done pursuant to the EU-US Privacy Shield. Reply Pro participates in and complies with the EU-U.S. Privacy Shield principles regarding the collection, use, sharing, and retention of Personal Data from the EEA, as described in our EU-US Privacy Shield certification. View the Privacy Shield list here. Learn more about the Privacy Shield here. Reply Pro is subject to the oversight of the US Federal Trade Commission, and will remain responsible for processing of Personal Data in a manner inconsistent with the Privacy Shield Principles by third parties to which Reply Pro has transferred personal data unless Reply Pro proves it is not in any way responsible for the event giving rise to the damage. Any and all such transfers of Personal Data outside the EEA shall be in accordance with this Privacy Policy and all applicable laws. If you have a complaint about our Privacy Shield compliance, contact our Data Protection Officer by email at privacyofficer@Reply Pro.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. You can also refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association, and in certain circumstances, invoke the Privacy Shield binding arbitration process.

This English-language Privacy Policy is Reply Pro’s official statement of its privacy practices relating to Reply Pro Services. In case of any inconsistency between this English-language Privacy Policy and any translation into another language, this English-language document prevails. You can also refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association (http://go.adr.org/privacyshield.html), and in certain circumstances, invoke the Privacy Shield binding arbitration process.

15. HOW TO CONTACT US 
If you have questions about privacy, need assistance with accessing or updating your Personal Data or have complaints relating to the processing of your Personal Data, contact our Data Protection Officer by email at privacyofficer@replypro.io
You can also write to us at: 
Reply Pro, 301. S. Capitol Blvd. Boise, ID 83702

BUSINESS TO BUSINESS SECTION 

1B. FACEBOOK CONNECT
You can log in to our site using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to grant the Reply Pro App permissions. You are free to accept or deny said permissions at any time, including revoking permissions once given.

2B. SOCIAL NETWORKS AND THIRD_PARTY SERVICES
Any collection, use, and management of personal information by the social networks, including Facebook, Instagram, and Twitter are governed by their respective privacy policy and terms. When using social networks, you are required to comply with their privacy policy and terms.

Where you are using our Services and have chosen to connect your Social Networks to the Services, or if you authorize a Third-Party Service to access your account, you are agreeing to provide information about you to the Social Networks and the Third-Party Services under their respective terms and privacy policies. For example, if you choose to connect your Google account, their Privacy Policy located at http://www.google.com/policies/privacy will apply to you.

3B. INFORMATION WE COLLECT 
All information collected is by your consent. In general, when you connect Reply Pro to your business profile(s), we ask for the following permissions: 
Instagram Basic Access: Allows Reply Pro to gather posts that your business is tagged in, establish web-hooks to gather mentions, and posting replies as your business.
Publish Pages (Facebook): Allows Reply Pro to post as the page so you can comment, respond to reviews, etc. from Reply Pro's app.
Manage Pages: This allows allows you to update your Facebook Page's business info within Reply Pro.
Messenger Basic: This allows Reply Pro to aggregate and respond to your direct messages on Messenger within the Reply Pro app.
Ads Management: Allows you to create, publish, and monitor Facebook's ads within Reply Pro.
Google My Business: Allows you to respond to Google reviews, edit business information, and respond to Q&A, all within Reply Pro.
Twitter: Allows you to monitor hashtags, track and reply to mentions, and post new tweets.

4B. REFRESHING TOKENS 
Unless you have added Reply Pro as an Agency Partner, you will need to login to Facebook and/or Instagram each time you use Reply Pro. This will refresh your authentication tokens and allow you to use Reply Pro as intended.