Privacy Policy

THE FOLLOWING PRIVACY POLICY (THE OR THIS “PRIVACY POLICY”) DISCLOSES THE PRIVACY PRACTICES OF VALOREM REPLY, L.L.C., A MISSOURI LIMITED LIABILITY COMPANY (“VALOREM REPLY,” “US,” “WE,” OR “OUR”), FOR THE WEBSITE LOCATED AT WWW. VALOREMREPLY.COM AND ALL OF THE PRODUCTS AND SERVICES OFFERED FROM TIME TO TIME BY, ON, OR THROUGH THE WEBSITE (COLLECTIVELY, THE OR THIS “WEBSITE”). VALOREM REPLY CREATED THIS PRIVACY POLICY IN ORDER TO COMMUNICATE ITS PRIVACY PRACTICES TO EACH USER OF THE WEBSITE (“USER,” “YOU,” “YOUR”). BY VISITING AND USING THIS WEBSITE AND ANY PRODUCT, SERVICE OR COMPONENT THEREOF, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AS THEY MAY BE AMENDED FROM TIME TO TIME. IN ADDITION TO COMPLYING WITH THIS PRIVACY POLICY AND ANY OF OUR OTHER POLICIES, GUIDELINES, AND OTHER AGREEMENTS YOU HAVE WITH VALOREM REPLY, YOU AGREE TO COMPLY WITH ANY AND ALL APPLICABLE LAWS WITH RESPECT TO YOUR USE OF THE WEBSITE.

By using the Website, each User is deemed to consent to Our privacy practices set forth in this Privacy Policy as amended from time to time. If You do not consent to these privacy practices, do not use the Website or view, access, or download any content from the Website. Valorem Reply may amend this Privacy Policy from time to time and will inform You and other Users by posting the changed Privacy Policy to the Website. The amendments will be effective immediately upon posting the changes to this Website or at the date specified in such amendment. By using the Website after any amendment is posted to the Website, You agree to be bound by the amendments. You should review the Privacy Policy from time to time to ensure that Your use is in compliance with, and that You agree to the terms of, this Privacy Policy. IF YOU DO NOT AGREE TO ANY AMENDMENT TO THIS PRIVACY POLICY, YOU SHOULD IMMEDIATELY CEASE USE OF THE WEBSITE.

1. Types of Information Collected and Manner of UsePersonal Information

We do not generally collect information that personally identifies You (“Personal Information”) unless You choose to provide it to Us through the Website (for example, by completing the online information request form to start a new project or sending an e-mail message). The Personal Information You submit is used to respond to Your question or request, as permitted by this Privacy Policy or by law, and as necessary to comply with law. You can manage Your communication preferences here.

Traffic Data

We may track and collect certain general and non-personal information when You visit the Website, including, without limitation, Your: (a) IP address, mobile device ID or other persistent identifier; (b) referrer information about how You visited the Website (e.g., how You got to the Website – was it by a Google search, by direct navigation, etc.) and how You used the Website (e.g., time of visit, areas of the Website that You visited); (c) Your connection speed and type; (d) type and version of Your web browser or mobile device; and (e) Your operating system and other system parameters and machine configuration (collectively, “Traffic Data”). Traffic Data is information that does not, standing alone, personally identify You but is helpful for marketing purposes or for improving Your experience on the Website. We use Traffic Data to collect information at an aggregate level about the visiting and use of the Website and to make the use of the Website more enjoyable to Our Users. We may combine Traffic Data with Personal Information We obtain from You directly through the Website or otherwise, including from third parties.

Cookies and Web Beacons

Valorem Reply requires the use of cookies. Cookies are small text files a website can use to recognize a repeat visitor to the website. We use cookies for various reasons. Cookies enable Us to provide You with a better experience by allowing Us to understand what areas of this Website are of interest to Our Users. These cookies do not track personal information. If You do not want Valorem Reply to deploy cookies in Your browser, You can set Your browser to reject cookies or to notify You when a website tries to deploy a cookie. If You choose to disable cookies in Your browser, You can still access most of this Website; however, Your ability to use some of this Website may be affected. In addition to cookies, Valorem Reply may use web beacons on this Website from time to time to monitor the number of Users who visit the Website, to deliver a cookie to the web browser of a visitor or User, and for other purposes. “Web beacons” or clear .gifs are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors and users viewing a website. For information regarding how third-party websites or advertisers may use cookies and other similar technologies, please see Section 4 below.

2. Confidentiality and Security of User Personal Information

Except as otherwise provided in this Privacy Policy (including Sections 3 and 4 below), We will keep all of Your Personal Information as private and will not share it with third parties, unless such disclosure: (a) is necessary to comply with a law (or based upon the good-faith belief that disclosure is necessary to comply with a law); (b) is necessary to protect Our rights or property; (c) is necessary to enforce this Privacy Policy, any of Our other policies and guidelines, or any other agreement that Valorem Reply has with You; (d) is specifically authorized by You; or (e) is in connection with the sale of a portion or all of Our business or assets. Valorem Reply will use a variety of commercially reasonable security technologies to help protect Your Personal Information from unauthorized access, use, or disclosure. However, the use of such security technologies by Valorem Reply is not, and shall not be considered to be, any type of guarantee or warranty by Valorem Reply that the Personal Information of Users of this Website will not be accessed by third parties, or that Valorem Reply will use all available security technologies to prevent unauthorized access to, use, or disclosure of Your Personal Information.

3. Limited Sharing of Information

We share Your Personal Information and Traffic Data with Our affiliates, subsidiaries, suppliers, vendors, and/or our or their employees, contractors, and agents as necessary or convenient in connection with the provision of the Website to You. Without limiting the generality of the foregoing, We share Your Personal Information and/or Traffic Data (a) with those people, including Our and Our affiliates’ and subsidiaries’ employees, agents, and contractors, who need this information to respond to Your online information request form to start a new project, Your e-mail message, or any other inquiry or question You submit; (b) with third parties that provide support, marketing advertising, or other services to or on behalf of Valorem Reply; and (c) as otherwise permitted by law from time to time. In the event that all or substantially all of Our business or assets are sold or transferred to another party, all Personal Information that has been collected and saved may be one of the business assets We transfer. While Valorem Reply uses commercially reasonable efforts to safeguard Your Personal Information transmitted to third parties, Valorem Reply does not warrant that Your Personal Information will be transported without unauthorized interception or modification or that Your Personal Information will not be accessed or compromised by unauthorized third parties. We may share aggregate or de-identified information, such as demographics and usage statistics, with advertisers, sponsors or other organizations or parties that We partner with from time to time. When this type of information is shared, the other parties do not have access to Your Personal information.

4. Collection of Your Information by Third-Party Websites or Advertisers

The Website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites. We also have third-party advertisers that may appear on the Website. These third-party advertisers may use cookies or similar technologies to help present the advertisements to You or to help measure the effectiveness of their advertisements. The use of such technologies is subject to the privacy policies of the third-party advertisers and is not covered by this Privacy Policy. As a result, if You respond to any such third-party advertisers by clicking on the advertisements and/or visiting their websites or the websites of any other third party, be sure You evaluate their privacy policies before providing them any of Your information.

5. Updates and Changes to Privacy Policy

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy by posting such change, update, or modification on the Website. Any such change, update, or modification will be effective immediately upon posting on the Website or upon the date specified in such amendment.

6. Child Privacy Issues

The Website is not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If You are under 13, do not use or provide any information on this Website or on or through any of its features. If We learn We have collected or received Personal Information from a child under 13 without verification of parental consent, We will delete that information. If You believe We might have any information from or about a child under 13, please contact Us as set forth below in Section 7.

7. Your California Privacy Rights; How to Contact Us

California Civil Code Section 1798.83 permits Our Users who are California residents to request certain information regarding Our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@valorem.com or contact Us at the mailing address set forth on the Website. Should You have any other questions or concerns about this Privacy Policy, please contact Us as provided in the preceding sentence.

Privacy notice for recruitment candidates

According to Section 13 of EU Regulation no. 679/2016, concerning the protection of individuals with regard to the processing of personal data, Reply S.p.A., Reply AG, Reply LTD (hereinafter, “Reply”), hereby provides you with the Privacy notice regarding the processing of your personal data.

Reply together with one or more Reply group companies are the Joint Controllers of this processing activity, as specified by Art. 26 of the GDPR Process. You may require details on Reply group companies contacting Reply as specified hereinafter.

We may obtain your personal data either directly from you or from third parties for recruitment purposes. Such third parties may include recruitment agencies, job boards and publicly available websites such as Linked-In, as well as specialist companies that facilitate the entrance of recent graduates into the working life. The data we collect may include your contact details, employment and education history, skills and professional qualifications, as well as records of any interactions with us including interviews and tests.

1. Purpose and processing activity. Legal basis
Your data are stored and processed solely for the following purposes:

a) carry out the necessary evaluations in order to possibly establish a job or contract relationship with one of the companies in the Reply group. Legal basis for the processing: execution of pre-contractual activities.

b) following a successful evaluation, arrange any documentation needed to establish the job or contract relationship, such as passport, work permit, driving licence, etc. Legal basis for the processing: execution of pre-contractual activities.

c) comply with specific obligations required by law or other binding regulations (e.g. fiscal legislation, social security and social protection law, health and safety at work, protection of health, public order and public security law). Legal basis for the processing: legal obligations.

To achieve the abovementioned purposes, it may be necessary to collect and process data defined as “particular” by GDPR art. 9 comma 2.b. In particular, this may include information about health status and disability, subject to any relevant employment legislation.

2. Provision of data
If you are unwilling to provide sufficient data to support the recruitment and evaluation process, we shall be unable to consider you for setting up the job or contract relationship.

3. Method of processing activity. Data retention period
Your data are stored electronically and will be subject to strict information security measures to protect your privacy. Your data will only be accessed by those directly involved in the evaluation and recruitment process.

If you subsequently join Reply, as an employee or as a freelance, you will be given a separate Privacy Notice to cover our storage and use of your personal data during your employment.

Otherwise, your data will be held for up to three years from the most recent update unless you specifically request deletion.

4. Data Recipients
The personal data collected to achieve the purposes indicated in section 1, could be used by any of the Reply companies as Joint Controller of the processing activity according to art. 26 GDPR.

Within the organization of each Joint Controller, personal data will be processed by subjects specifically appointed and interested to the applicant’s profile and that intend to conduct an evaluation of the applicant, or by all subjects to whom the communication is due in base of specific law obligations.

In some cases, we may share an anonymized profile with a potential Reply client as part of your evaluation.

The Joint Controllers may use external companies to provide services for the achievement of the purposes on point 1. Any such company will be designated as a Data Processor according to art. 28 of GDPR.

If you are being considered for a position with a Reply group company outside the European Union, please be aware that these companies may be subject to different data protection legislation, and this may require additional protections and consents. We will inform you of these if necessary.

Whenever personal data are transferred from an EU member state to a third country, this transfer will be protected by standard contractual clauses according to Art. 46 par. 2.c of GDPR.

5. Dissemination of data
Apart from the third parties identified above your data will not be subject to any wider dissemination.

6. Data subjects’ rights
You have the right to require to each Joint Controller the access to your personal data and, where the conditions are met, to require the amendment or erasure of the same or restriction of the processing that refer to You, or to oppose to the processing.

Where the conditions are met, You have the right to data portability.

For the abovementioned communications, you may use the contact details reported in section 8 below.

You have the right to lodge a complaint to the competent Supervisory Authority.

7. Data Controller. Data Protection Officer and Privacy Lead
The Reply Group Companies are Joint Controllers of the processing ex art. 26 GDPR.

Reply together with one or more Reply group companies are the Joint Controllers of this processing activity, as specified by Art. 26 of the GDPR Process.

The contact details of the Data Protection Officers are:
• BR Privacy Lead: gdpr.br@reply.com
• Italy DPO: dpo.it@reply.it
• Germany DPO: dpo.de@reply.de
• UK DPO: dpo.uk@reply.com
• US Privacy Lead: gdpr.us@reply.com

8. Other Contact Details for data subjects’ rights

ITALY:
Data Subjects can send an email to privacy@reply.com, or a mail by postal service, to Reply S.p.A., Corso Francia 110, Turin.
 
UK:
Data Subjects can send an email to privacy@reply.com or a mail by postal service to the HR Department, Reply Ltd, 38 Grosvenor Gardens, London SW1W 0EB.

GERMANY
Data Subjects can send an email to DSB@reply.de, or a mail by postal service to Reply AG with registered office at Bartholomäusweg 26 D-33334 Gütersloh

POLAND
Data Subjects can send an email to privacy@reply.com or a mail by postal service to Hermes Reply Polska Sp. z o.o. with registered office at Ul. Gliwicka 6/2 44-079 Katowice

Document update date: 10 July 2020