1. INTRODUCTION AND OVERVIEW

1.1  We are very pleased that you are interested in our website https://www.revreply.com/ (“Site”) and thus in our company namely, RevGen Labs, www.revreply.com, https://app.revreply.com, as well as any other subdomains forrevreply.com. The purpose of the Site is to act as a comprehensive online platform with respect to correspondence and communication (as detailed out in the Site) through the integration of artificial intelligence(“Services”). Our paramount commitment lies in ensuring privacy and trust, specifically in the handling of sensitive and confidential information. In this comprehensive privacy policy, we detail our approach to data security and confidentiality.

1.2  Our privacy policy intends to provide a transparent overview of our data practices. This includes a detailed breakdown of the types of data we collect, the explicit purposes for which it is utilized, and the duration for which it is retained. We also outline your rights in relation to the data you entrust to us, offering avenues for access, correction, and deletion in alignment with regulatory frameworks.

1.3  The following sections of this privacy policy stipulate, the intricacies of our privacy measures, elucidating the specific protocols in place to safeguard your information. These encompass a thorough examination of encryption methodologies, stringent access controls, and the precise limitations applied to data sharing practices. Recognizing the critical nature of information, we have implemented and outlined these measures to ensure your sensitive information receives the utmost care and discretion throughout its lifecycle.

2. ACCEPTANCE OF TERMS

By using or accessing the Site and Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy (the “Policy”), and that we may collect, use, and share your information as detailed out herein this Policy. If you do not agree to the terms of the Policy, then you should refrain from use of our Site and/or Services. By visiting and using the Site and/or Services, you agree that your use of the Services or Site and any disputes over privacy shall be governed by this Policy. Any new changes or modifications which are added to the current Services shall also be subject to this Policy or as otherwise determined by us.

3. COLLECTION OF INFORMATION

The Site collects various types of information, such as:

3.1 Voluntarily provided information which may include your name, address, email address, billing and/or credit card information, etc. and other relevant details which may be used when you purchase products and/or services and to deliver the services or products you have requested. Additionally, if you consent to have your email accounts monitored by our Site, the content of these email communications will also be considered as voluntarily provided information. This information is used to facilitate the purchase and delivery of products and/or services you have requested, and to enhance the overall service we provide.

3.2 Information automatically collected when visiting our Site, which may include cookies, third party tracking technologies and server logs.

3.1 For better experience, while using our Site, we may send one or more cookies (which are small text files containing a string of alphanumeric characters) to your computer or mobile device. We may use both Session Cookies and Persistent Cookies. A “Session Cookie” disappears after you close your browser. A “Persistent Cookie” remains after you close your browser and may be used by your browser on subsequent visits to the Site. User has the right to remove the Persistent Cookies from its browser. If you delete, or choose not to accept, Cookies from the Site, you may not be able to utilize the features of the Site to their fullest potential. 

3.1 When you visit the Site, use the services provided therein, we may automatically receive and record certain information from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the services through the Site. When you use the Site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals. 

3.5 We may implement third party advertising or other content on the Site that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your web browser in connection with your viewing of the third party content on the Site. Additionally, we may implement third party buttons(such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser cookies, even when you do not interact with the button.

3.6 We may implement third party advertising or other content on the Site that may use clear gifs or other forms of web beacons, which allow the third-party content provider to read and write cookies to your web browser in connection with your viewing of the third party content on the Site. Additionally, we may implement third party buttons(such as Facebook “like” or “share” buttons) that may allow a third party to collect information about you through their browser cookies, even when you do not interact with the button.

3.7  We may collect anonymous demographic information that is relevant to our services. This may include age and gender. We may also gather information about the type of browser you are using, IP address or type of operating system to assist us in providing and maintaining superior quality service. We are committed to respecting your privacy and ensuring that the collection of this data is transparent and used solely for the purpose of improving our services and tailoring them to our user base.

4. USE OF INFORMATION COLLECTED

4.1  We may collect and may make use of personal information to assist in the operation of our Site and to ensure delivery of the Services you need and request. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you. We may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.

4.2  We may feel it necessary, from time to time, to contact you with regards to a potential new offer which may be of interest to you. If you consent or show interest in presented offers, then, at that time, specific identifiable information, such as name, email address and/or telephone number, may be shared with the third party.   

4.3 We may find it beneficial to share specific data with our trusted partners to conduct statistical analysis, provide you with email and/or postal mail, deliver support and/or arrange for deliveries to be made. Those third parties shall be strictly prohibited from making use of your personal information, other than to deliver those services which you requested, and as such they are thus required, in accordance with this agreement, to maintain the strictest of confidentiality with regards to all your information.

4.4 We retain the right disclose your personal information or any other information, without prior notice to you, only if required to do so in accordance with applicable laws and/or in a good faith belief that such action is deemed necessary or is required to:

· Remain in conformance with any decrees, laws and/or statutes or to comply with any process which may be served upon our Site;

· Maintain, safeguard and/or preserve all the rights and/or property; and 

· Perform under demanding conditions to safeguard the personal safety of users or other visitors of Site and/or the general public.

4.5 You agree and acknowledge that we shall not be liable for any harm, loss or damage of any nature caused to you due to disclosure of information in above mentioned circumstances.

5. INFORMATION COLLECTED AUTOMATICALLY

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. Additionally, we, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies to collect information automatically through our Services. These technologies are small data files that we transfer to your browser or device that allows us to provide and enhance our Services. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of these technologies, but this may prevent you from taking advantage of some of our features.

6. ANALYTICS

We may use analytics service providers, including Google Analytics, to collect information regarding visitors to our Services, such as their behavior on our Services or information about their demographic. For more information about Google Analytics, see https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

7. DO-NOT-TRACK

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. At this time, we do not respond to nor honor Do-Not-Track signals from web browsers.

8. INFORMATION COLLECTED FROM THIRD PARTIES

8.1 We may collect information about you through a referral program, such as when an exporter or importer refers one of their existing customers, leads, or partners to us. If you have been referred to us but wish to opt out of emails from us, please contact us as explained below.

8.2 If you access our Services through a third party or social networking site, we may collect information about you from that third-party application if that information has been made public via your privacy settings with that third party. For example, if you register via Facebook, we may collect your name, profile ID, location, gender, profile picture, and list of your friends. We may receive information about you from other sources, including to supplement the information we have collected about you.

8.3 We offer third-party integrations. If you choose to integrate third-party applications with us, we will collect personal information as part of that integration. Because each third-party service you may choose to integrate collects different personal information, the detail in which information will be collected will be explained during the integration setup process. For more information on integrations, please contact us as described below.

9. USE OF INFORMATION COLLECTED

9.1 We use the information we collect about you for various business purposes as described below.

· To provide you with our Services

· Enter into a contract with you

· Allow you to set up a user account and profile

· Fulfil your requests for products and services

· Allow you to create and share content with others

· Communicate with you about your account and updates to our Services

· Determine your order or account limits and eligibility for extended payment terms

· Process applications, transactions, and payments

· Allow you to register for events

· Facilitate communications between you and other users

· For our legitimate business interests

· Analyze how you use the Services

· Understand user interest and engagement on the Services

· Engage in marketing or sales outreach

· Provide customized content, offers, or Services, including marketing content via email, postal mail, social media, SMS, or other channels, subject to applicable laws

· Research and develop Services

· Improve and streamline our Services

· Verify your identity and prevent fraud

· Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity

· Ensure quality control

· Debug to identify and repair errors

· Enforce our Terms and policies

· Audit or other compliance activities

· To comply with our legal obligations

9.2 We retain and use your information in connection with potential legal claims, and for compliance, regulatory and auditing purposes. For example, we retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal information, we may request identification and verification documents from you for the purpose of confirming your identity.

9.3 We may collect and use personal information based with your consent. You can revoke your consent at any time (either through our Services directly or by contacting us via email:support@revreply.com, though note that you might not be able to use any Service or feature that requires collection or use of that personal information. Furthermore, note that this includes that you may opt-out from the use of your personal information for advertising purposes (either through our Services directly or by contacting via email: support@revreply.com.

10. EXCEPTIONAL CIRCUMSTANCES

In exceptional cases we may further process your personal information to protect your vital interests or as further required for the public good, in accordance with applicable laws.

11. DE-IDENTIFIED AND AGGREGATED INFORMATION

We use personal information to create, in accordance with applicable laws, de-identified, anonymized, and aggregated information such as: information about demographics, de-identified location information, information about devices used to access our Services, and de-identified, anonymized, and aggregate information on transactions on our Services that help our users understand and optimize sales.

12. AUTOMATIC COLLECTION TECHNOLOGIES

Our use of automatic collection technologies such as cookies, pixel tags, and local storage objects (together “Cookies”) fall into the following general categories:

· Strictly Necessary: Technologies that allow you to access our Services and use our features, and tools that help us identify irregular site behavior and prevent fraudulent activity or improve security.

· Personalization: Technologies that help us personalize advertising and content for you, such as by making inferences about your interests based on the content you interact with on our Services, which informs future selections of content or advertising.

· Measurement: Technologies that collect information about your use of our Services, including measuring, understanding, and reporting on your usage of the Services.

· Information Storage and Access: Technologies that store information or provide access to information that is already stored on your device, such as your shopping cart.

· Content Selection, Delivery, and Reporting: Technologies that select and deliver content for you, and measure the effectiveness of that content, including information about what content was shown, how often or how long it was shown, when and where it was shown, and what actions, if any, you took on the content.

· Ad Selection, Delivery, and Reporting: Technologies that select and deliver advertisements for you, and measure the effectiveness of those advertisements, including information about what advertisements were shown, how often or how long they were shown, when and where they were shown, and what actions, if any, you took on the advertisements.

13. THIRD-PARTY WEBSITES

We may offer links to third-party websites or Services, which are not controlled by us and not subject to the protections laid out in this Policy. We do not endorse nor approve any third-party website and we encourage our users to read the privacy policy of each third party service they interact with.

14. APIS AND SDKS

We may use third-party APIs and software development kits (“SDKs”), which may allow third parties to collect personal information about you for various purposes, such as to conduct analytics, verify your business when you register with us as a retailer or brand, provide customized content, or otherwise streamline the Services. For more information about our use of APIs and SDKs, contact us as described below.

15. CHILDREN’S PRIVACY (UNDER THE AGE OF MINOR)

We do not knowingly collect personal identifiable information from children under the age of minor without verifiable parental consent. By agreeing to these terms, you affirmatively represent and warrant that the email accounts you link to our Site are strictly for business purposes and will not contain any data or information regarding individuals who are minors. If it is determined that such information has been inadvertently collected on anyone under the age of minor, we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database. Furthermore, anyone under the age of minor must seek and obtain parent or guardian permission to use this website. Failure to comply with these terms may result in immediate termination of your account and access to our services.

16. UNSUBSCRIBE OR OPT-OUT

All users and/or visitors to our Site have the option to discontinue receiving communication from us and/or reserve the right to discontinue receiving communications by way of email or newsletters. In the event that a user discontinues our services or opts out of communications after a period of engagement (e.g., three months), we maintain the right to retain the data previously collected for analytical and training purposes. This data will be deidentified to ensure privacy. However, from the point of opting out or service discontinuation, the user's data will no longer be actively used for analytics or included in future data assessments. Should a user decide to terminate their relationship with our Site, they can request the deletion of their personal data from our database. We comply with such requests in accordance with applicable data protection and privacy laws. However, non-personal, deidentified data may be retained for our internal analysis and training purposes, to improve our services.

17. SECURITY

17.1 We utilize industry-standard safeguarding methods, including implementing prevention software and regular monitoring and scanning of systems, to ensure the security of your data. We are committed to doing everything reasonably possible to protect your data and privacy. These efforts are designed to maintain the integrity and security of your information, providing peace of mind about the safety of your data. We cannot, however, ensure or warrant the security of any information you transmit to us through the use of Site, services or store on the Site and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

17.2 You will have the right to adjust your privacy settings to limit access to your information, however we cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you post through the services and on the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.

18. ASSIGNMENT

We reserve the right to transfer or assign the information that we have collected from users, in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

19. CHANGES TO PRIVACY POLICY AGREEMENT

We reserve the right to update and/or change the terms of the Policy, and as such we will post those change to our Site’s homepage, so that the users and/or visitors are always aware of same. If at any point in time the we decide to make use of any personally identifiable information on file, in a manner significantly different from that which was stated when this information was initially collected, the user or users shall be notified of same. Users at that time shall have the option as to whether or not to permit the use of their information in this separate manner.

20. CCPA AND GDPR COMPLIANCE

20.1 We ensure compliance with the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR) and will provide California and EU consumers with the rights granted under these applicable laws. For more information on these rights, please contact us via details mentioned herein below.

20.2 When processing personal data, we strictly adhere to the requirements of the EU Data Protection Regulation (GDPR) and, if necessary, other data protection regulations as applicable.

i. The rights of data subjects: Chapter III of the EU Data Protection Regulation (GDPR) provides for extensive rights for data subjects, which we will explain to you below with regard to the processing of your personal data:

ii. The right to be informed: This specification applies in particular to the following data processing details:

· The purpose of the processing operation

· Categories of data

· If necessary, recipient or categories of recipients

· If necessary, the planned storage duration or the criteria for determining this duration

· Information on the respective right to correction, deletion, restriction or objection

· Existence of a right of appeal to a supervisory authority

· If necessary, origin of the data (if not collected from you)

· If necessary, existence of automated decision making including profiling, and including meaningful information about the logic involved, the scope and the expected effects

· If necessary, (planned) transfer to a third country or international organization

iii. The right of rectification: If necessary, we will correct faulty data immediately if you inform us about the circumstance accordingly.

iv. The right to deletion: If the processing is no longer necessary and one of the following conditions is fulfilled:

· Expiry of the purpose of processing

·  Withdrawal of your consent and the absence of any other legal basis for processing

· Opposition to processing without an important reason to the contrary

·  Illegal processing

· Required to fulfill a legal obligation

· Data collection in accordance with Art. 8 para. 1 GDPR

· As part of the deletion request, we may pass on your request to those third parties to whom your data was previously transferred.

v. The right to restriction of processing: Provided one of the following conditions is met:

· You dispute the accuracy of your data (restriction may be made on our site for the duration of the verification)

· In the event of unlawful processing and provided that the data is not to be deleted, deletion shall be replaced by restriction of processing

· If the processing purposes expire, at the same time you need your data to assert, exercise or defend legal claims

· After your objection pursuant to Art. 21 para. 1 GDPR and for the duration of the examination, whether our justified reasons outweigh yours.

vi. The right to data portability: As long as it is technically possible and the rights and freedoms of other persons are not affected, we will – at your request – transfer your data to another recipient (data controller).

vii. Right to object: If we collect personal data from you or have it collected and process it (on the basis of Art. 6 Para. 1(e) or (f) or Art. 9 Para. 2(a) GDPR), you have the right to object to data processing (including profiling) at any time (with effect for the future). In exceptional cases, the objection may be invalid, e.g. if we can prove compelling legitimate interests for processing that outweigh your interests, or processing serves to assert, exercise or defend legal claims. If we process your personal data for direct marketing purposes, you have the right to object to such processing at any time. This also applies to any profiling connected with such direct advertising. You also have the right to object to the processing of the data we hold about you, which is carried out by us for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR unless such processing is necessary to fulfill a task in the public interest.

viii. Automated individual decision-making including profiling: If we collect personal data from you or have it collected and processed, you have the right not to be subject to decision based exclusively on automated processing – including profiling – which has a legal effect on you or significantly impairs you in a similar manner. Exceptions to this requirement apply if the decision to conclude or fulfill a contract between you and us is necessary or if you have expressly consented to the processing. In any event, we will take reasonable measures to protect your rights and freedoms and your legitimate interests, including at least the right on our part to obtain the intervention of a person to express our position and to challenge the decision.

ix. Right to withdraw consent under the data protection laws: You have the right to revoke your consent to the processing of personal data at any time.

x. Information on data security: We secure your personal data processed by us against loss, destruction, access, modification or distribution of your data by unauthorized persons by appropriate technical and organizational measures. However, despite regular checks, complete protection against all risks is not possible.

xi. Legal basis for processing: We process personal data according to the specifications of the GDPR, depending on the type and purpose of processing, as follows:

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21. GENERAL DEADLINES FOR DATA DELETION

After elimination of the storage purpose, the retention periods are generally ten years. As a rule, the deletion of data generally takes place without delay in accordance with our deletion plan, insofar as it does not preclude any obligation to retain data, the need to fulfil a contract or a legitimate interest.

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22. DELETION OR BLOCKING OF PERSONAL DATA

We store your personal data only for the period necessary to fulfill the intended purpose. However, certain types of data, such as email logs, may be retained for an extended period as part of our ongoing analysis and service improvement efforts. This retention will be in compliance with applicable laws and regulations. For data types that are not subject to extended retention, such as specific personal details no longer required for our service delivery, we will ensure their deletion immediately after the elimination of the purpose and expiration of any existing retention periods. If deletion is not possible, the data will be blocked instead.

‍23. COLLECTION OF GENERAL DATA AND INFORMATION

As soon as you visit our website, our web server collects some general data and technical information which includes but is not limited as to as shown in the table below:

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24. LIMITATION OF LIABILITY

To the fullest extent permitted by the State of California law, we and our affiliates, directors, employees, agents, or licensors shall not be liable for any direct, indirect, punitive, incidental, special, consequential, or exemplary damages, including without limitation damages for loss of profits, goodwill, data, or other intangible losses, arising out of or related to the use of, or the inability to use, this website, its services, or any information provided therein. We shall not be responsible for any loss, destruction, alteration, or disclosure of your data caused by any third party. Users are responsible for maintaining backup copies of all data they provide to us.

25. NO WARRANTIES

The Site, Services, and all related components and information are provided on an "as is" and "as available" basis without any warranties of any kind. We expressly disclaim all warranties, whether express or implied, in accordance with applicable law, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

26. INDEMNIFICATION

You agree to defend, indemnify, and hold harmless us and our affiliates, and their respective officers, directors, employees, and agents from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to your violation of this Privacy Policy or your use of the Site.

‍27. MAXIMUM LIABILITY

Notwithstanding any other provision of this Privacy Policy, in no event shall our aggregate liability, whether in contract, warranty, tort (including negligence, whether active, passive, or imputed), product liability, strict liability, or other theory, arising out of or relating to the use of or inability to use the Site and/or Services exceed any compensation you pay, if any, to us for access to or use of the Site and/or Services.

28. DATA MANAGEMENT AND LIABILITY

28.1 Users of RevReply acknowledge and agree that RevGen Labs and its services, including but not limited to RevReply, shall not interfere with, delete, alter, or otherwise manipulate the email data in the accounts provided for use with RevReply. The integrity and preservation of email data within user accounts shall be maintained at all times during the use of our services.

28.2 While RevGen Labs commits to the non-interference of email data, it is hereby stated that RevGen Labs shall not bear responsibility for any negative outcomes that may arise from the use of email communications facilitated through RevReply. This includes, but is not limited to, misunderstandings, miscommunications, data breaches originating from user actions, or any other form of dispute or loss that may occur in the course of email communications.

28.3 By using RevReply, users agree to indemnify and hold harmless RevGen Labs from any claims, losses, liabilities, damages, or expenses (including attorney's fees) arising from the user's email communications or data management within the email account linked to our services.

28.4 The use of RevGen Labs' services, including RevReply, constitutes an acknowledgment and acceptance of these terms. Users are advised to use email communications responsibly and in compliance with all applicable laws and regulations.

29. HOW TO CONTACT US

If you have any questions or concerns regarding the Policy or related to our Site and/or Services, please feel free to contact us at the following email..Email:  support@revreply.com