At ReachBro, we are determined to protect your integrity. It is important to us that you feel safe when submitting your personal information to us. We therefore openly process your data with your integrity in focus.
In this privacy policy (the “Privacy Policy”, “Policy”), which applies to anyone who in any way uses ReachBro’s services or products (the “Service”) and/or otherwise has contact with us, we describe how and why we process your personal data and what rights you have under applicable personal data legislation.
Unless otherwise specified, it is ReachBro, (“ReachBro”, “we”, “us”)) who is responsible for the processing of your personal data.
You are always welcome to contact us with questions regarding this policy or other data protection issues. Contact details can be found at the end of the Policy.
1. What is Personal Data?
Personal Data is all information that can be directly or indirectly attributed to a natural living person. Examples of this are social security numbers, e-mail addresses, but even encrypted data if they can be linked to natural persons.
2. What is the “Processing” of Personal Data?
The concept of processing is broad and covers most things one can do with Personal Data. Everything from collection and storage to modification, use or deletion constitutes “processing”.
3. When do we collect your Personal Data?
We collect information from various sources possible in accordance with applicable data protection regulation.
- Information you submit to us yourself
- Information collected when you use our services
- Data from other sources
4. Why do we process your Personal Data?
For us to provide services to you and other clients, we must process your personal information. We process your information mainly to:
- Manage and provide our services
- Manage customer service issues and other inquiries
- Provide information and promote our partners or client’s services and goods that you may be interested in
- Improve our services, for example by researching and evaluating customer satisfaction or the market
5 On which legal ground are we processing your Personal Data?
To process Personal Data, it is required a legal basis. ReachBro processes Personal Data on the following grounds:
- Because Personal Data processing is necessary for us to fulfill an agreement we have with you, e.g. to provide a service you have purchased
- Because Personal Data processing is necessary to fulfill a legal obligation, e.g. accounting obligations
- Because we have a legitimate interest in processing your Personal Data to communicate to you about goods and services you previously purchased or might be interested in.
- When the Personal Data processing is allowed because you have given your consent to it.
6. How long will we save your information?
Your Personal Data will only be processed for as long as it is necessary for the purposes for which it was collected – for example, as long as we must fulfill the obligations we have as a result of an agreement with you.
We may save the data longer if required by law or to safeguard our legal interests, e.g. whether a legal process is in progress.
Your Personal Data will be deleted or anonymized when they are no longer relevant to the purposes for which they have been collected.
7. Do we share your Personal Data?
Only the people who need to process Personal Data for the purposes mentioned above have access to your Personal Data.
We may share your personal information with companies and suppliers who provide services for us, e.g. for communicating offers and to maintain or support our IT-systems. These companies may only process your Personal Data following our instructions and may not use your Personal Data for their purposes unless specifically agreed with you.
We may also share the personal information necessary to establish, enforce and exercise ReachBro’s legal interests, such as collecting debts.
We may also share your personal information if it is required by law or government regulations, for example if we must submit information to the relevant jurisdictional Tax Agency or Competition Authority.
8. Where is your information processed?
We aim to process your personal information within the EU. If we use service providers that transfer your Personal Data to countries outside the EU and the EEA, we will take steps to protect your data in accordance with applicable legal requirements, for instance by demanding that the supplier protect the data following applicable data protection rules. If you would like to know more about what protective measures we have taken, please contact us.
9. Security measures to keep your Personal Data safe
We employ appropriate technical and organizational security measures to help protect your Personal Data against loss and to guard against access by unauthorized persons. We regularly review our security policies and procedures to ensure that your Personal Data is secure and protected.
10. Google user data
ReachBro provides the ability to integrate with your Gmail account to let our Service help you send e-mails via Gmail API. Since the service is designed to integrate into Gmail it is necessary for the service to connect to your Google account.
To provide the automated service of sending, processing and monitoring messages created by the user and approved to be sent through ReachBro’s service, we need to read, compose, and modify Gmail message bodies (including attachments), metadata, headers, and settings.
To minimize the amount of Personal Data collected and to request the API scope(s) as narrow as possible, but still to provide accurate functioning and statistics from the Service, we will only read specific parts of an incoming email by singling out key words suitable to administrate, identify and query the messages assignable to our Service. We do not read the entire content of any specific message unless expressly agreed to by the Client. Reasons for such approval would be for necessary security purposes such as investigating abuse, to comply with applicable law or for quality improvements in internal operations. Operations for quality improvements will be set forth only when the data is aggregated and anonymized.
The only information we store is your e-mail address of the Gmail account connected to the Service, the authentication tokens, and identifiers for messages and conversations sent through the Service. We only use this information to provide the following services:
- Creating and sending e-mail through ReachBro’s services on behalf of the Client
- Tracking of replies to messages sent through our services
11. LinkedIn
ReachBro allows us only to receive access to your session cookie to perform personalized connections and messaging access on LinkedIn
12. Your rights
Access to, and correction of your data
As a registered client, you have the right to request the correction of incorrect information at any time or change the personal information you have provided. You also have the right to see what personal information we have recorded about you. You do this by requesting an extraction from registers.
Revoke consent with future effect
If we process your Personal Data on the basis that you have the right to withdraw your consent regarding future processing at any time.
Oppose processing
You have the right to oppose our processing of your Personal Data we carry out with a balance of interest as a legal ground. You can opt-out advertising and communication at any time. You can unsubscribe by clicking on a link in the current mailing or contact us (see contact details below).
Deletion
In some circumstances, you have the right to have your Personal Data deleted. However, this does not apply if, for example, we are required by law to preserve the information.
Limitation of processing
You may also be entitled to request that the processing of your Personal Data to be restricted. However, if you request the processing of your data to be restricted, it may mean that we no longer can fulfill our possible obligations to you during the time the processing is limited.
Data portability
In the event that you wish to transfer your data from us, you also have the right to receive a copy of the Personal Data relating to you collected in a structured, machine-readable format (right to data portability). This right only covers the information that you have shared with us.
13. About cookies
When you visit our website, we use cookies. We will soon be updating our cookie policy.
14. Complaints
Should you be dissatisfied with our way of processing your Personal Data, please first contact us at [email protected]. If you are not satisfied with our way of handling your complaint, you can submit your complaint to the competent supervisory authority.
15. Contact
information to Personal Data controller If you have further questions about our data protection or if you wish to exercise our rights as above, you can easily reach us at [email protected].
16. Changes to the Privacy Policy
We reserve the right to make changes to our privacy policy. You will always find the latest version on the site. This will be communicated to you in case of updates that are crucial to our processing of Personal Data (for example, modification of stated purposes).
17. Third party disclosures
Personal data relating to you collected on our website are destined for ReachBro’s own use and may be forwarded to ReachBro’s partner companies so that we may obtain assistance and support in the context of carrying out our services. ReachBro ensures that it has in place clear data protection requirements for all of its third party providers. ReachBro does not sell or rent your personal data to third parties for marketing purposes whatsoever. In addition, ReachBro does not disclose your personal data to third parties, except if: (1) you (or your account administrator acting on your behalf) requests or authorized disclosure thereof; (2) the disclosure is required to process transactions or supply services which you have requested (i.e. to check you are employing best practices in your mailings or for the purposes of processing an acquisition card with credit-card issuing companies); (3) ReachBro is compelled to do so by a government authority or a regulatory body, in the case of a court order, a summons to appear in court or any other similar requisition from a government or the judiciary, or to establish or defend a legal application; or, (4) the third party is a subcontractor or sub-processor of ReachBro in the carrying out of services (for example: ReachBro uses the services of an Internet provider, a telecommunications company, a host provider, CRM tools, customer support client tools, invoices tools, payment tools, analytics tools).
GOOGLE COMPLIANCE
ReachBro’s use and transfer to any other app of information received from Google Accounts will adhere toGoogle API Services User Data Policy, including the Limited Use requirements.
SECURITY
Within the framework of its services, ReachBro attributes the very highest importance to the security and integrity of its customers’ personal data.
Thus and in accordance with the GDPR, ReachBro undertakes to take all pertinent precautions in order to preserve the security of the data and, in particular, to protect them against any accidental or unlawful destruction, accidental loss, corruption, unauthorized circulation or access, as well as against any other form of unlawful processing or disclosure to unauthorized persons.
To this end, ReachBro implements industry standard security measures to protect personal data from unauthorized disclosure. Using industry recommended methods of encoding, ReachBro takes the measures necessary to protect information connected with payments and credit cards.
Moreover, in order to avoid in particular all unauthorized access, to guarantee accuracy and the proper use of the data, ReachBro has put the appropriate electronic, physical and managerial procedures in place with a view to safeguarding and preserving the data gathered through its services.
There is no absolute safety from piracy or hackers. That is why in the event a breach of security were to affect you, ReachBro undertakes to inform you thereof without undue delay and to use its best efforts to take all possible measures to neutralize the intrusion and minimize the impacts. Should you suffer any loss by reason of the exploitation by a third party of a security breach, ReachBro undertakes to provide you with every assistance necessary so you are able to assert your rights. Moreover if, by some exceptional case, the direct loss incurred arose due to fault or gross negligence by ReachBro, you will be able to seek compensation within the limit of liability referred to in our Terms.
You should keep in mind that any user, customer or hacker who discovers and takes advantage of a breach in security renders him or herself liable to criminal prosecution and that ReachBro will take all measures, including filing a complaint and/or bringing court action, to preserve the data and the rights of its users and of itself and to limit the impacts.