Privacy policy
Last updated on August 20, 2018
This website is operated by Separo, a division of Represent Holdings LLC (“Separo” or “we”).
This Privacy Policy covers how Separo collects, uses, retains, discloses and transfers (“processes”) your personal information (“Personal Information”) through the website www.separo.io (the “Site”) and the services made available through the Separo Platform and API (together the “Separo Services”). This Privacy Policy applies to information we collect online and offline.
Personal Information includes information about you that is personally identifying such as your name, email address, phone number, location data and payment information and which is not otherwise publicly available. Personal Information may include specific types of information depending on the legal definition that applies in your physical location. Only the legal definition of Personal Information that applies in your location will apply to you under this Privacy Policy.
Agreement
By accessing or providing information to the Site or Separo Services, you accept and hereby expressly consent to our processing, including but not limited to international disclosure and transfer, of your Personal Information in accordance with the terms of this Privacy Policy. You also consent and opt in to receive direct marketing emails from Separo and understand that you may opt out by clicking “unsubscribe” on the emails you receive from us. You agree that your consent is voluntary, explicit and unambiguous and is free and informed.
Information Collection and Use; Choice and Consent
You may browse the Site without providing Personal Information, although your IP address will be collected. We collect Personal Information when you access the Separo Services as described below.
In most cases, your employer or the company that engages you (“Company”) has established an account with us. Your Company may provide your Personal Information to us, such as your name, email address or phone number, in order to enable you to access the Separo Services. Prior to authorizing you to become a user of the Separo Services, your Company is responsible for obtaining your consent to disclose your Personal Information, in accordance with applicable laws. Even though your Company has your consent to provide us with your Personal Information, when you begin using the Separo Services, you are also providing your express consent to the terms in this Privacy Policy.
When you set up an account, we collect your first and last name, work email address, telephone number, Company name and password, and additional information. We use this information to create and manage your account, to track your use of the Separo Services, to create your user profile, to send you information related to your account, and to send you promotional emails, updates and other information we think may be of interest to you. When you log in we collect your email address and password to enable you to use your account.
When you sign up for the Separo Services, we collect your email address and business address. We collect this information in order to process and track your transaction. When you pay for the Separo Services, you will be automatically directed to our third party payment processor, Braintree, which will collect you information in accordance with their terms of use and privacy policy. We do not collect or process your payment information.
If you contact us by phone or email for support or other reasons, we collect your first and last name, email address, phone number and order number in order to respond to you.
If you provide your email address to us at any time, we will add you to our email list in order to send you promotional emails about our products and services. You can opt out of promotional emails at any time by clicking “unsubscribe” at the bottom of the emails you receive from us.
If Separo intends on using Personal Information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to a change in the use of your information, in accordance with applicable law.
It is always your choice whether or not to provide us with Personal Information. If you do provide Personal Information to the Site or Separo Services, you are giving your voluntary and express consent to the processing, including but not limited to international transfer and disclosure, of your Personal Information as described in this Privacy Policy. If you choose not to provide the requested information, you may not be able to access certain features or functions of this Site or Separo Services. You may access, change, modify or delete your information, at any time, as described below.
You may opt out from receipt of our emails by clicking “unsubscribe” at the bottom of the emails you receive from us. You have the right to object to the use of your Personal Information for direct marketing purposes by email, on a going forward basis, by emailing us at support@separo.io. We will respond to your objection in accordance with the law that applies to you.
You may revoke your consent, and/or object to or block processing of your Personal Information by emailing a request to us at support@separo.io. We will respond to your request in accordance with the law that applies to you. Your Personal Information which we processed prior to your request may not be deleted from our Site system records but will be blocked from further processing without your permission. A request to revoke consent or block processing of your Personal Information may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Site, or to information we may keep to comply with legal requirements.
Non-Personal Or Aggregate Information That We Collect
When you visit the Site or use the Separo Services, we may automatically collect certain non-identifying information about you, such as the type of browser or device operating system you use, the domain name of the website from which you linked to us, the amount of time you spend on the Site and the pages on the Site that you view. We may also aggregate information collected from our users (such as the number of users in a particular region or having particular characteristics). This information is not Personal Information and is not covered by this Privacy Policy.
Cookies
When you visit the Site or use the Separo Services, we use session “cookies” — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are logged in and to enable us to process your online transactions. Session cookies also help us confirm your identity and are required in order to login into your account. We also use persistent cookies which may remain active on your device for up to 1-3 years (depending upon the purpose of the cookie) or until you delete them manually. We set a persistent cookie to enable us to track and target the interests of users to enhance the services we provide.
We may also use and place cookies on your device from our third party service providers in connection with the Site, such as an analytics provider that helps us manage and analyze Site usage. You may delete cookies, but that may limit your ability to access the Site and Separo Services. To find out more about cookies, including how to delete them, visit www.allaboutcookies.org.
Protection of Your Information
We will take appropriate technical and organizational safeguards to protect Personal Information from theft, other loss, misuse, and any unauthorized access, copying, collection, use, disclosure, alteration or destruction. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We will retain Personal Information for as long as necessary to provide our services. However, we may retain and use Personal Information for longer periods to the extent necessary to comply with our legal (including tax and accounting) obligations, resolve disputes, and enforce our agreements.
Information Sharing and Disclosure
We share your Personal Information with third parties as necessary to enable us to provide the Separo Services (our “Subcontractors“). Our Subcontractors are contractually obligated to maintain the confidentiality of your Personal Information consistent with the terms of this Policy and to comply with the applicable data protection laws.
We may disclose non-personal information and de-identified aggregate information to third parties.
We will disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements. We also may disclose your information in response to a law enforcement agency's request or other request for information from the U.S. or other government entities, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with our policies and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements.
In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with Separo, or our other business units. You will be notified in advance of any rights you may have to block or object to this transfer of your information.
International or Cross-Border Transfer of Your Personal Information and Your Express Agreement
Given that the Internet operates in a global environment and that transfer of your data is necessary to enable you to use the Separo Services, to provide updates, and to respond to your inquiries, using the Internet to collect and process Personal Information necessarily involves the transmission of data on an international, or cross-border, basis. By using the Separo Services, and/or by communicating with us by email, you acknowledge and expressly consent to our processing and disclosure of your Personal Information in this way. The Personal Information of users who are located outside the U.S. will be transferred outside of each eligible country to the United States where our servers are located and where it will be processed and stored on servers in the U.S. The U.S. has not been recognized as providing an adequate level of protection according to European Union (EU) data protection requirements and the requirements of some other countries, but we will take all steps reasonably necessary to ensure that users’ Personal Information is treated securely in respect of such transfer and as described in this Privacy Policy. By using the Site and Separo Services or by providing information to the Site, you expressly agree to such transfer, processing, storage and disclosure in countries outside the EU.
Children’s Privacy
Our Site and Separo Services are directed to individuals who are the age of majority or older in their jurisdiction of residence. We do not knowingly collect information from children. If you believe your child has provided information to the Site or Separo Services, please contact us using the information provided below.
Your California Privacy Rights; California Do Not Track Disclosures
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below. Please note that we do not disclose Personal Information to third parties for direct marketing purposes. In addition, we currently do not honor Do Not Track signals.
Accessing Your Information
You may access, review, change, update or delete your Personal Information, request information about our collection, use and disclosure of such information, and request information on our policies and practices relating to disclosure of information to our service providers, by contacting us at support@separo.io. We will respond to these requests in accordance with the laws that apply to you. You can help us maintain the accuracy of your information by promptly notifying us of any changes to your information.
Your European Union Privacy Rights
If you are located in the European Union, you have certain additional rights with respect to your Personal Information under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), including the following:
The right of access to your Personal Information.
The right to rectify your Personal Information if it is incorrect or incomplete.
The right to have your Personal Information erased (“right to be forgotten”) if certain grounds are met.
The right to withdraw your consent to our processing of your Personal Information at any time (if our processing is based on consent).
The right to object to our processing of your Personal Information (if processing is based on legitimate interests).
The right to object to our processing of your Personal Information for direct marketing purposes.
The right to receive your Personal Information from us in a structured, commonly used and machine-readable format, and the right to transmit your Personal Information to another controller without hindrance from us (data portability).
If you are or have been our customer, we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. We will never share your Personal Information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.
You may contact us at support@separo.io to exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances we may charge a reasonable fee for access to your Personal Information. Furthermore, if you believe that our processing of your Personal Information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you have the right to lodge a complaint with the data protection supervisory authority of your country.
For purposes of the GDPR, we are a “controller” and you are a “data subject.”
Contact Us About Complaints, Questions or Notices relating to this Privacy Policy
Separo commits to resolving complaints about your privacy and our collection or use of your Personal Information. If you believe your privacy rights have been violated or you disagree with any action Separo has taken with regard to your Personal Information you may file a complaint with Separo by emailing us at support@separo.io. Users with complaints about their privacy or this Privacy Policy should submit their complaint in writing with as much information as possible.
You may contact us at:
Privacy Officer
Represent Holdings, LLC
1680 Vine St., #400
Los Angeles, CA 90028
Email: support@separo.io
Terms of Use
Please also visit our Terms of Use section establishing the use, disclaimers, and limitations of liability governing the use of our website at https://separo.io/terms.