Effective: July 1, 2020
Welcome to RELE.AI AG (“RELE.AI”, “we”, “us” and “our”). RELE.AI provides software and services that record the Client’s messages from the Client’s personal instant messaging, and or email in one platform, helping our users interact with, but not limited to, their back office systems like CRM, email servers and or others. The “Websites” means RELE.AI’s websites (including without limitation http://www.rele.ai, app.RELE.AI and any successor URLS, mobile or localized versions and related domains and subdomains), and the “Services” means RELE.AI’s products, applications and services, in each case in whatever format they may be offered now or in the future. As the Client use the Services, we collect and process information from and about the Client in order to provide the Client with access to the Services, enhance the Client’s experience while using the Service, and communicate with the Client.
A separate agreement (the ”Terms and Conditions Agreement or T&C”) is in place between the Client (“the Client”) and RELE.AI that governs delivery, access and use of the Service by users who are authorized by the Client to use its instance of the Service (such Customer-specific instance of the Service is referred to herein as the “Customer Workspace”). The entity who enters into the Customer Agreement with RELE.AI controls the Customer Workspace used by its authorized users and may set certain rules related to the Client’s utilization of the Service, including limitations regarding which third party applications the Client can connect to via the Service. If the Client has questions about the Client’s specific Service settings and practices the Client should contact them directly.
Personal Data We Collect
Account Registration Data That The Client Provide To Us
When the Client registers for a RELE.AI account, the client is required to provide certain personal information (the “Personal Data”), such as its name, and email address, and telephone number, as well as other information that the Client voluntarily chooses to add to its account profile, like a profile photo. If the Client chooses to register for an account utilizing the Client’s credentials from a third party service (such as Google or Microsoft), then the Client’s name and email address will be provided to us as permitted by the Client’s profile settings within that third party services. If the Client is registering for a paid account the Client will also be required to provide payment information, such as payment card details (collected by our payment service provider), and Single Sign On (SSO) SAML 2.0 credentials. We will inform the Client, when requesting the Client’s Personal Data, if certain data must be provided or if it is optional. We will also inform the Client of the consequences should the Client not wish to provide this data. We also collect the information that the Client may choose to submit to our customer support team, for example regarding a question the Client has or a problem the Client is experiencing with our Services. This may include the Client’s contact information, a summary of the problem the Client is experiencing and any other documentation or information that would be helpful in resolving the issue (which, at the Client’s option, may include Personal Data).
Automatically Collected Data
When the Client interacts with RELE.AI through the Services, we automatically collect information about the Client through cookies (small text files placed on the Client’s device), mobile device identifier and other technologies. When the Client visits our Websites, our servers record information (“log data”), including information that the Client’s browser automatically sends whenever the Client visits the Website. This log data includes the Client’s Internet Protocol (“IP”) address (from which we understand the country the Client is connecting from at the time the Client visits the Site), browser type and settings, and the date and time of the Client’s request.
Data From Other Services The Client Link To The Client’s Account
We receive information about the Client when the Client or the Client’s administrator integrate or link a third-party service with our Services (a “Third Party Service”). For example, if the Client creates an account or logs into our Services using the Client’s Google or Microsoft credentials, we receive the Client’s name and email address as permitted by the Client’s Google or Microsoft profile settings in order to authenticate the Client.
Data from Business Partners
If the Client purchases our Services through a reseller or other RELE.AI business partner (a “Business Partner”), that Business Partner may provide certain information to us, such as the Client’s name, email address, company information, and financial information related to the Services the Client purchase.
How We Use The Client’s Personal Data.
We collect Personal Data for the following purposes:
To Provide The Services And Manage The Client’s Access To And Use Of The Services
We use information about the Client to provide the Services to the Client, including to register the Client for the Services, process transactions with the Client, authenticate the Client when the Client log in, provide customer support, and operate and maintain the Services.
To Communicate With The Client About The Services And Provide The Client With Customer Support
We use the Client’s contact information to communicate with the Client about the Services, respond to the Client’s customer support questions and requests, and to provide the Client notices regarding the Services (including notices about the Client’s account, product update announcements, security alerts, administrative notifications and the like).
In connection with providing the Client with customer support, we may also use the information we automatically collect and information that the Client provide to us and consent for us to view and utilize as part of a support request so that we can respond to the Client’s request, analyze information related to the Client’s support request, and to repair or improve the Services.
We may also provide the Client with tailored communications that are based on the Client’s interactions with the Services. For example, certain actions the Client takes may trigger a third-party app suggestion or we may communicate with the Client as the Client begins using the Services to assist the Client as the Client learns to be proficient in the Client’s use of the Services.
These communications are fundamental to the Services and in most cases the Client cannot opt out of them. If an opt out is available, the Client will find information about how to opt out in the communication itself or in the Client’s account settings.
For Research And Development to Improve our Service
So that we can continually improve the functionality of our Services, we utilize our collective learnings about the way users interact with and use the Services, as well as feedback provided directly to us, to troubleshoot issues, fix bugs, enhance functionality, and identify areas for integration and improvement of the Services.
To Market And Promote Our Services
We use the Client’s contact information and information about how the Client uses the Services to communicate directly with the Client, including by sending the Client newsletters, promotions or information about current and future products and services. The Client may opt out of receiving such communications at any time by (i) clicking the unsubscribe link included in all the emails the Client receives or (ii) contacting us as indicated in Section 11 below (“Contact”).
For Safety And Security
We use information about the Client and the way in which the Client uses the Services to verify and authenticate accounts and activity, monitor for suspicious or fraudulent activity and identify violations of our Services policies.
To Protect Our Legitimate Business Interests And Legal Rights
Where required by law, or where we think it is necessary to protect our legal rights and interests or the legal rights and interests of others, we use information about the Client in connection with legal claims, compliance and regulatory functions. If the Client asks us to delete the Client’s data or to be removed from our marketing lists and we are required to fulfill the Client’s request, we will keep basic data to identify the Client and prevent further unwanted processing. As used above, “legitimate interests” means our interests in conducting our business and managing and delivering the best Services to the Client. We will not use the Client’s Personal Data for activities where the impact on the Client overrides our interests, unless we have the Client’s consent or those activities are otherwise required or permitted by law.
With The Client’s Consent
We use Personal Data about the Client where the Client has given us consent to do so for a specific purpose not listed above. For example, with the Client’s permission we may publish testimonials or featured customer stories on our Websites to promote the Services, including names and profile photos of representatives of our customers alongside the testimonial. While providing our Services, we may collect on behalf of our customers information related to our customers’ employees, business partners and other individuals. Our use of such information on behalf of our customers is governed by our Customer Agreement with that customer and the customer’s own privacy policies. We are not responsible for the privacy policies or privacy practices of customers or other third parties.
How We Share The Client’s Personal Data
In order to provide the Client with the Service and operate our business effectively, we may need to share the Client’s Personal Data with certain third parties and service providers. This section explains when and why we share the Client’s information.
We expect that these third parties will usually be already service providers of the Client like the email provider, CRM provider, or similar. We
Sharing With Third Party Service Providers for Business Purposes
We may share the Client’s Personal Data with third party service providers for business purposes (as we have done for the preceding 12 months). This Personal Data may include personal identifiers (such as the Client’s name and email address), and internet or other electronic network activity information (such as the Client’s IP address, type of browser, version of operating system, carrier and/or manufacturer, device identifiers, and mobile advertising identifiers), and location data. We disclose these categories of Personal Data to service providers who assist us in fulfilling the following business purposes:
- Maintaining and delivering the Service (including hosting, back-up and other IT service providers, billing and payment processing services),
- Providing the Client with customer service,
- Detecting and preventing fraud,
- Analyzing and improving the Service (including via website analytics and data science service providers)
These third party service providers are provided only with that Personal Data that is necessary to perform the services we have hired them to provide.
Sharing With Our Subsidiaries And Affiliates
RELE.AI is managed and operates in every country whenever local authorities permit the usage of RELE.AI or/and no international sanctions prohibit doing business with these countries.
For Legal Purposes to Protect RELE.AI and the Service
We may disclose the Client’s Personal Data if required to do so by law or if we have a good faith belief that such action is necessary to (i) comply with a legal obligation or lawful requests by public authorities, including to meet national security or law enforcement requirements, (ii) protect and defend the rights or property of RELE.AI, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
In Connection With a Sale or Merger
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
With The Client’s Consent
We may share Personal Data about the Client with third parties when the Client gives us consent to do so. For example, with the Client’s permission we may publish and display testimonials or featured customer stories on our Websites, including names and profile photos of representatives of our customers alongside the testimonial, subject to the consent of the people mentioned or presented on the photos.
RELE.AI generally retains the Client’s Personal Data for a period of time consistent with the original purpose of collection. For instance, we may retain the Client’s Personal Data during the time the Client has an account to use our Websites or Services, or as agreed in our subscription agreements, and for a reasonable period of time thereafter. We also may retain the Client’s Personal Data as necessary to comply with our legal obligations, to establish proof of a right or a contract, resolve disputes, enforce our agreements, in accordance with the law.
The Client’s credit card information is stored no longer than the time necessary to allow the fulfillment of the transaction, except in the case of a subscription, to facilitate the payment of regular customers. In that case, credit card information is stored for the whole duration of the Client’s subscription and at least until the date at which the Client carries out the Client’s last transaction. Such storage is implemented by our secured payment service provider Stripe or any other reputable and accepted provider. By subscribing to our Services, the Client agrees to this storage. Data relating to the visual cryptogram or CVV2 on the back of the Client’s credit card is not stored. In the case of a payment by credit card, however, data relating to the credit card may be stored as intermediary archives for evidence purpose in the case of possible disputes regarding the transaction, for the duration provided by law in the relevant jurisdiction.
Privacy Shield and EU rules
RELE.AI will regularly revise the legal situation to evaluate the necessity to comply with legal frameworks like the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce.
RELE.AI is responsible for the processing of Personal Data it receives, under the Privacy Shield Framework, and subsequently transfers to service providers. RELE.AI complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and Switzerland, including the onward transfer liability provisions. Legal changes could result in a necessity to adapt the policy,
Subject to EU data protection law, the Client have the following rights in relation to the Client’s Personal Data:
- Right Of Access: If the Client asks us, we will confirm whether we are processing the Client’s Personal Data and, if so, provide the Client with a copy of that Personal Data along with certain other details. If the Client requires additional copies, we may need to charge a reasonable fee.
- Right To Rectification: If the Client’s Personal Data is inaccurate or incomplete, the Client is entitled to ask that we correct or complete it. If we share the Client’s Personal Data with others, we will tell them about the correction where possible. If the Client asks us, and where possible and lawful to do so, we will also tell the Client with whom we shared the Client’s Personal Data so the Client can contact them directly.
- Right To Erasure: The Client may ask us to delete or remove the Client’s Personal Data, such as where the Client withdraws the Client’s consent. If we share the Client’s data with others, we will alert them to the need for erasure where possible. If the Client asks us, and where possible and lawful to do so, we will also tell the Client with whom we shared the Client’s Personal Data with so the Client can contact them directly.
- Right To Restrict Processing: The Client may ask us to restrict or ‘block’ the processing of the Client’s Personal Data in certain circumstances, such as where the Client contest the accuracy of the data or object to us processing it (please read below for information on the Client’s right to object). We will tell the Client before we lift any restriction on processing. If we share the Client’s Personal Data with others, we will tell them about the restriction where possible. If the Client asks us, and where possible and lawful to do so, we will also tell the Client with whom we shared the Client’s Personal Data so the Client can contact them directly.
- Right To Data Portability: The Client has the right to obtain the Client’s Personal Data from us that the Client consented to give us or that was provided to us as necessary in connection with our contract with the Client where we process that Personal Data in an automated way. We will give the Client the Client’s Personal Data in a structured, commonly used and machine-readable format. The Client may reuse it elsewhere.
- Right To Object: The Client may ask us at any time to stop processing the Client’s Personal Data, and we will do so:
- If we are relying on a legitimate interest to process the Client’s Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing the Client’s Personal Data for direct marketing (the Client can always object using the unsubscribe link in our marketing communications).
- Right To Withdraw Consent: If the Client have consented to our use of the Client’s Personal Data for a specific purpose, the Client have the right to change the Client’s mind at any time, but this will not affect any processing of the Client’s data that has already taken place.
- Right To Make A Complaint With The Data Protection Authority: If the Client has a concern about our privacy practices, including the way we handled the Client’s Personal Data, the Client can report it to the data protection authority that is authorized to hear those concerns.
Cookies and Similar Technologies
Cookies are small text files that are placed on the Client’s computer or mobile device when the Client visit a website, mobile app or use an online platform. Cookies and similar technologies are widely used by online service providers to facilitate and help to make the interaction between users and websites, mobile apps and online platforms faster and easier, as well as to provide reporting information. For more information about cookies and their impact on the Client and the Client’s browsing visit www.aboutcookies.org
We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites and/or App and/or platform to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites and/or App and/or platform. Third parties serve cookies through our Websites and/or App and/or platform for analytics and to help us deliver ads, measure the performance of those ads, and make them more relevant to the Client. This is described in more detail below.
Our Websites Cookies
Essential website cookies:
These cookies are strictly necessary to provide the Client with services available through our Websites and to use some of its features.
- Vendor: RELE.AI AG
- How to refuse: Because these cookies are strictly necessary to deliver the Websites and the Services to the Client, the Client cannot refuse them.
Analytics and customization cookies:
- Purpose: These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective marketing campaigns are, or to help us customize our Websites for the Client.
- Vendor: Google Analytics
Most internet browsers allow the Client to erase cookies from the Client’s computer hard drive, block all cookies (or just third-party cookies), or warn the Client before a cookie is stored on the Client’s device. Please note, if the Client chooses to block all cookies, our Services will not function as intended and the Client will not be able to use or access many of the features of the Services we provide. If the Client has blocked all cookies and wishes to make full use of the features and Services we offer, the Client will need to enable the Client’s cookies. The Client can do this in the Client’s browser. Rather than blocking all cookies, the Client can choose to only block third-party cookies which will still allow our website to function as intended.
How We Respond to Do Not Track (DNT) Signals
Some internet browsers have incorporated “Do Not Track” features which, when enabled, causes the Client’s browser to send a do not track HTTP header file or “signal” to each site the Client visits. At present, the Services do not respond to this type of signal.
Have questions or concerns about RELE.AI and privacy? Contact us by email at privacy@RELE.AI