This Privacy Notice explains how RepSky (“RepSky,” “we,” “us,” or
“our”) collects, uses, and shares your personal information when you
use RepSky, and how you can exercise your privacy rights.
This Privacy Notice applies to the personal information we process in
connection with our website rsky.ai and RepSky. In this Privacy
Notice, we refer to the Sites and RepSky as the
“RepSky Services”.
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PROFILES AND POSTS ARE PUBLIC
If you create an account on RepSky, any information you add to your
public profile and the information you post on RepSky will be
public.
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DIRECT MESSAGES ARE PRIVATE
Content you sent to another RepSky user through Direct Messages is
private between you and the user(s). If you’ve shared this
information through a third-party service, the information may be
visible to them. DMs may be accessed by moderators when reported
in-app, or by RepSky Trust and Safety staff investigations into
significant violations of the Community Guidelines.
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UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time at our sole
discretion. If we do, we’ll let you know by posting the updated
Privacy Notice on the Site, to RepSky, and we may also send other
communications.
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PERSONAL INFORMATION WE COLLECT
The types of personal information we collect depend on how you
interact with us, RepSky Services, and the requirements of
applicable law.
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Personal Information You Provide to Us Directly
We collect personal information that you provide to us.
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Account Creation. We collect personal
information such as your email address, phone number, and
username when you create an account with RepSky.
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Your Communications with Us. We may collect
personal information, such as your name, email address, or
phone number when you contact us.
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Your Posts. RepSky is a microblogging service
that lets you post content and comment on other users’ posts.
We collect your posts. Your posts and comments are public, so
exercise care when deciding what to share.
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Your Direct Messages. We store and process
your direct messages in order to enable you to communicate
directly and privately with other users on RepSky. These are
unencrypted and can be accessed for Trust and Safety purposes.
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Payment Information. When you make a
purchase, a third party service provider that handles payments
for us will receive your payment card information.
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Personal Information We Collect Automatically
We may collect personal information automatically when you use
RepSky Services.
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Usage Information. When you use RepSky
Services, we collect certain information automatically,
including your Internet protocol (IP) address (which can be
used to derive your general location), user settings, cookie
identifiers, mobile carrier, other unique identifiers, browser
or device information, and Internet service provider (ISP). We
may also collect personal information about your use of the
RepSky Services, such as the posts you view on RepSky, the
links you click within RepSky, the frequency and duration of
your activities, and other similar information.
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Cookie Policy (and Other Technologies). We
and third parties that provide content or other functionality
on the Sites and RepSky may use cookies, pixel tags, and other
technologies (“Technologies”) to
automatically collect information when you use the Sites. You
can block cookies by setting your internet browser to block
some or all cookies. However, if you use your browser settings
to block all cookies (including strictly necessary cookies)
you may not be able to access all or parts of the Sites and
RepSky. You can change your browser settings to block or
notify you when you receive a cookie, delete cookies or browse
our Sites using your browser’s anonymous usage setting. Please
refer to your browser instructions or help screen to learn
more about how to adjust or modify your browser settings. If
you do not agree to our use of cookies or similar technologies
which store information on your device, you should change your
browser settings accordingly. Where required by applicable
law, you will be asked to consent to certain cookies and
similar technologies before we use or install them on your
computer or other device.
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Cookies. Cookies are small text files
placed on device browsers. Cookies store preferences and
enable and enhance your experience. Below is an overview of
the types of cookies we and third parties may use to collect
information:
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Strictly Necessary Cookies. Some cookies
are strictly necessary to make our RepSky Services
available to you. We cannot provide you with our RepSky
App Services without this type of cookies.
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Analytical or Performance Cookies. We may
also use cookies for website analytics purposes in order
to operate, maintain and improve our RepSky Services. We
may use our own analytics cookies or use third-party
analytics providers.
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Personal Information We Collect from Other Sources
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Third Parties. We may collect personal
information from third parties. For example, you may direct a
Developer Application or other third-party social networking
application to share personal information with us.
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HOW WE USE PERSONAL INFORMATION
We use your personal information for a variety of business
purposes, including to provide RepSky Services, for administrative
purposes, and to market RepSky Services, as described below.
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Provide Our Services
We use personal information to fulfill our contract with you
and provide you with RepSky Services, such as:
- Managing your account;
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Providing access to certain areas, functionalities, and
features of RepSky Services;
- Answering support requests; and
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Communicating with you about your account, activities on
RepSky Services, and policy changes.
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Administrative Purposes
We use personal information for various administrative
purposes, such as:
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Pursuing our legitimate interests such as direct marketing,
research and development (including marketing research),
network and information security, and fraud prevention;
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Detecting security incidents, protecting against malicious,
deceptive, fraudulent or illegal activity, and taking
appropriate actions against malicious actors;
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Measuring interest in, and engagement with, RepSky Services;
- Creating de-identified and/or aggregated information;
- Carrying out analytics;
- Improving, upgrading, or enhancing RepSky Services;
- Developing new products and services;
- Ensuring internal quality control and safety;
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Sharing personal information with third parties as needed to
provide RepSky Services;
- Enforcing our agreements and policies; and
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Carrying out activities that are required to comply with our
legal obligations.
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Marketing
We may use personal information to provide you with marketing.
If you have any questions about our marketing practices, you
may contact us using the information provided below.
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With Your Consent
We may use personal information for other purposes that are
clearly disclosed to you at the time you provide personal
information or with your consent.
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Other Purposes
We also use your personal information for other purposes as
requested by you or as permitted by applicable law.
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HOW WE SHARE PERSONAL INFORMATION
We may disclose personal information to third parties for a
variety of business purposes, including to provide RepSky
Services, to protect us or others, or in the event of a corporate
transaction, as described below.
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Sharing to Provide RepSky Services
The categories of third parties with whom we may share
personal information are described below.
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Your Posts and Public Profile. As noted
above, RepSky is a microblogging service. Your posts and
profile are public.
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Other Users You Share or Interact With.
RepSky may allow you to share personal information,
messages, or interact with other users.
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Third-Party Services You Share or Interact With
. RepSky may link to or allow you to interface, interact,
share information with, direct us to share information with,
access and/or use third-party websites, applications,
services, products, and technology (each a “
Third-Party Service”). If you do, the
information you share will be subject to the Third-Party
Service’s privacy policy.
For example, if you request that your personal information
be shared with another Developer Application, we may help
facilitate that request.
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Service Providers. We may share personal
information with our third-party service providers and
vendors. This includes service providers and vendors that
provide us with IT support, hosting, payment processing,
customer service, and related services.
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Business Partners. We may share your
personal information with our business partners to provide
you with a product or service you have requested. We may
also share your personal information with business partners
with whom we jointly offer products or services.
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Sharing to Protect Us or Others
We may access, preserve, and disclose any information we store
if we, in good faith, believe doing so is required or
appropriate to: (i) comply with law enforcement or national
security requests and legal process, such as a court order or
subpoena; (ii) protect your, our, or others’ rights, property,
or safety; (iii) enforce our policies or contracts; (iv)
collect amounts owed to us; or (v) assist with an
investigation or prosecution of suspected or actual illegal
activity.
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Sharing in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing,
reorganization, bankruptcy, receivership, purchase or sale of
assets, transition of service to another provider, or other
similar corporate transaction, your personal information may
be sold or transferred as part of such a transaction.
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YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you
have about your personal information are determined by applicable
law and are described below.
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Email Communications. If you receive a
marketing email from us, you may opt out by using the
unsubscribe link at the bottom of such email. You will continue
to receive transaction-related, non-promotional emails related
to RepSky Services. You will not be opted out of those
communications.
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Mobile Devices. We may send you push
notifications through our App when you enable them. You may opt
out from receiving these push notifications by changing the
settings on your mobile device. We may collect precise
location-based information via our App, but only if you permit
us to do so. You may opt out of this collection by changing the
settings on your mobile device.
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“Do Not Track.” Do Not Track
(“DNT”) is a privacy preference that users can
set in certain web browsers. Please note that we currently do
not respond to or honor DNT signals or similar mechanisms
transmitted by web browsers, as there is no consistent industry
standard for compliance.
Your Privacy Rights. Depending on what laws apply
to your personal information, you may have the right to:
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Request Access to and Portability of Your Personal Information
, including: (i) obtaining access to or a copy of your personal
information; and (ii) receiving an electronic copy of personal
information that you have provided to us, or asking us to send
that information to another company in a structured, commonly
used, and machine-readable format (also known as the “right of
data portability”);
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Request Correction of your personal information
where it is inaccurate, incomplete, or outdated. In some cases,
we may provide self-service tools that enable you to update your
personal information;
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Request Deletion, Anonymization or Blocking of
personal information including when processing is based on your
consent, or when processing is unnecessary, excessive or
noncompliant (also known as the “right to be forgotten”).
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Request to Opt-Out of Certain Processing Activities
if we engage in certain data processing activities that give you
a right of opt-out under applicable privacy laws;
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Request Restriction of or Object to our
processing of your personal information;
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Withdraw your Consent to our processing of your
personal information. Please note that your withdrawal will only
take effect for future processing and will not affect the
lawfulness of processing before the withdrawal.
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Be Informed about third parties with which your
personal information has been shared; and
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Request the Review of Decisions Taken Exclusively Based on
Automated Processing
if these decisions could affect your rights under applicable
data protection laws.
Please
contact us
using the information below if you would like to exercise any of
these rights. We will process your requests in accordance with
applicable laws. Before fulfilling your request, we may ask you to
provide reasonable information to verify your identity. Please
note that there are exceptions and limitations to each of these
rights, and that while any changes you make will be reflected in
active user databases instantly or within a reasonable period of
time, we may retain information for backups, archiving, prevention
of fraud and abuse, analytics, satisfaction of legal obligations,
or where we otherwise reasonably believe that we have a legitimate
reason to do so. Some laws may allow you to appeal our decision if
we decline to process your request. If applicable laws grant you
an appeal right, you may send us your appeal using the contact
information below.
If your personal information is subject to the applicable data
protection laws of Brazil, the European Economic Area,
Switzerland, or the United Kingdom, and you believe our processing
of your personal information violates applicable law, you have the
right to lodge a complaint with the competent supervisory
authority.
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INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We may transfer, process, and store all personal information we
collect anywhere in the world. Some countries may have data
protection laws that are different from the laws where you live.
If we transfer personal information from the European Economic
Area, Switzerland, and/or the United Kingdom to a country that
does not provide an adequate level of protection under applicable
data protection laws, we will do so based on safeguards such as
the European Commission-approved or UK Government-approved
Standard Contractual Clauses, or otherwise in accordance with
applicable data protection laws.
For more information about the safeguards we use for international
transfers of your personal information, please contact us as set
forth below.
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HOW LONG WE KEEP PERSONAL INFORMATION
We keep the personal information we collect for as long as you use
RepSky Services, or as necessary to fulfill the purpose(s) for
which we collected it. There are also other reasons why we may
keep personal information. They may include, but are not limited
to, providing RepSky, resolving disputes, establishing legal
defenses, conducting audits, pursuing legitimate business
purposes, enforcing our agreements, and complying with applicable
laws. When determining the retention period, we take into account
various criteria, such as the type of products and services
requested by or provided to you, the nature and length of our
relationship with you, the impact on RepSky Services we provide to
you if we delete some personal information from or about you,
mandatory retention periods provided by law, and any relevant
statute of limitations.
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SUPPLEMENTAL NOTICE FOR CERTAIN JURISDICTIONS
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Supplemental Notice for EU/UK GDPR
This Supplemental Notice for EU/UK GDPR only applies to our
processing of personal information that is subject to the EU
or UK GDPR. Personal information means any information
relating to an identified or identifiable individual. If you
do not provide your personal information when requested, you
may not be able to use our RepSky Services if that personal
information is necessary to provide you with our RepSky
Services or if we are legally required to collect it.
We process personal information when we have a valid legal
basis, including as set forth below:
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Performance of a Contract: RepSky may need
to process your personal information where required to
perform our contract with you, namely the Terms of Service,
and for the purposes described in Section 4(A) of this
Privacy Notice.
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Legitimate Interest: RepSky may process
your personal information where we or a third party have a
legitimate interest, including the purposes in Section 4(B)
of this Privacy Notice. We only rely on our or a third
party’s legitimate interest to process your personal
information where these interests are not overridden by your
interests or fundamental rights and freedoms.
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Consent: In some cases, RepSky may also
rely on your consent to process your personal information.
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Compliance with our Legal Obligations:
RepSky may process your personal information to comply with
our legal obligations. For example, we may process your
personal information to comply with tax, labor, and
accounting obligations.
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SECURITY
We make reasonable efforts to protect your information by using
physical and electronic safeguards designed to improve the
security of the information we maintain. However, as our Services
are hosted electronically, we can make no guarantees as to the
security or privacy of your information.
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CHILDREN’S PERSONAL INFORMATION
RepSky Services are not directed to children under 13 (or other
age as required by local law outside of the United States). We do
not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has
uploaded personal information to our site without your consent,
you may contact us using the information provided below.
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CONTACT US
RepSky is the controller of the personal information we process
under this Privacy Notice.
If you have any questions about our privacy practices or this
Privacy Notice, or to exercise your privacy rights listed in this
Privacy Notice, please contact us at
support@bsky.app
.