Last updated on August 20, 2018
This website is operated by Separo, a division of Represent Holdings LLC (“Separo” or “we”).
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.
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.
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.
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 email@example.com. 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 firstname.lastname@example.org. 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.
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.
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.
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.
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.
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.
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 email@example.com. 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.
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 firstname.lastname@example.org 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.”
You may contact us at:
Represent Holdings, LLC
1680 Vine St., #400
Los Angeles, CA 90028