In this policy, “Reps, ““we”, “us” or “our” means Reps; “user” means a user who enrolls with, uses, or assists in providing Reps Services; “visitor” is someone who is on the Reps Website, but does not enroll, use, or assist in providing Reps Services; and “you” or “your” means individually or collectively a user and/or a visitor.
In this policy “Personal information” is information about you that can personally identify you and that may not otherwise be publicly available. Examples of Personal Information are name, address, email address, phone number, and payment method information.
PERSONAL INFORMATION ABOUT YOU THAT REPS COLLECTS:
We collect your personal information in order to provide and continually improve our products and services. The types of personal information we collect includes:
Information You Give Us: Examples are:
- identifying information such as your name, address, email address, and phone numbers;
- payment / billing information, such as shipping address of a gift card recipient, credit or debit card number, verification number, zip code, and expiration date;
- log-in credentials;
- your location information;
- other people’s or entities addresses, email addresses, and phone numbers including, without limitation, if you request that your purchase be provided to someone other than yourself (such as a gift recipient), we use the information you provide about the other person to fulfill your request;
- content of reviews and emails to us;
- personal descriptions and photographs;
- images and videos ;
- information and documents regarding identity;
- credit history information;
- the Services you use;
- processing your orders, such as the courses in which you enroll, and demographic information related thereto;
- requests or questions you submit to us via online forms, email, or otherwise;
- your participation in sweepstakes, contests, or surveys;
- your account registration (such as log-in credentials) and administration of your account;
- uploads or posts to the Services, such as User-generated content you provide to us, as when you comment on content on the Services, respond to a survey request, review a course, or participate in public forums;
- courses in which you enroll;
- requests for customer support and technical assistance; and
- Any other information you choose to provide to us in connection with your use of the Services.
Automatic Information: We automatically collect and store certain types of information about your use of the HTM website and Reps Services, including information about your interaction with content and services available through Reps website and Reps Services. We use "cookies", other unique identifiers, other technologies, applications, and our web pages to obtain certain types of information when your web browser or device accesses the Reps website or Reps Services and other content served by or on behalf of Reps on other websites. Examples of the information we collect and analyze include:
- the internet protocol (IP) address used to connect your computer or device to the internet;
- login, email address, and password;
- the location of your device or computer;
- content interaction information, such as content downloads, streams, and playback details, including duration and number of simultaneous streams and downloads, and network details for streaming and download quality, including information about your internet service provider;
- device metrics such as when a device is in use, application usage, connectivity data, and any errors or event failures;
- Reps website and Reps Services metrics (e.g., the occurrences of technical errors, your interactions with service features and content, your settings preferences and backup information, location of your device running an application, information about uploaded images and files such as the file name, dates, times and location of your images);
- version and time zone settings;
- purchase and content use history, which we may aggregate with similar information from other customers for analyses purposes, to create or modify features, or to otherwise use in connection with the Reps Services;
- the full Uniform Resource Locator (URL) clickstream to, through, and from our website(s), including date and time; products, services and content you viewed or searched for; page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs);
- on your device -- browser types, browser language, operating system, software and hardware attributes, date and time of use, content watched, total minutes watched, error logs, operating system, version, domain name and other similar information; and
- images or videos when you are on our website or using Reps Services.
Information from Other Sources / Participating Third Parties:
- We might receive information about you from other sources, such as search results and links, including paid listings (such as sponsored links), payment processors, business partners, marketers, researchers, analysts or other third parties we may attribute to you who participate in Reps Services (“Participating Third Parties”). We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.
- Reps strives to obtain assurances from its Participating Third Parties that they have the legal right to license or provide data to Reps.
PURPOSES THAT REPS USES YOUR PERSONAL INFORMATION:
We use your personal information to operate, provide, develop, and improve the products and services that we offer you. These purposes include:
Purchase and delivery of products and services. We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, including, without limitation, providing you with updates and information about courses in which you have enrolled, help us better understand your interests and needs, and improve the Services.
Provide, troubleshoot, and improve Reps Services. We use your personal information to provide functionality, analyze performance, fix errors, secure our websites and applications, resolve app crashes and other issues being reported, and improve the usability and effectiveness of Reps Services.
Recommendations and personalization. We use your personal information to recommend features, products, and services that might be of interest to you, identify your preferences, and personalize your experience with Reps Services.
Comply with legal obligations. In certain cases, we collect and use your personal information to comply with laws. For example, we may collect payment processor information for identity verification and other purposes.
Communicate with you. We use your personal information to communicate with you via different methods (e.g., by phone, email, chat).
Fraud Prevention and Credit Risks. We use personal information to prevent and detect fraud and abuse in order to protect the security of our customers, Reps, Participating Third Parties, and others. We may also use scoring methods to assess and manage credit risks
Internet –Based Ads. Interest-based ads are sometimes referred to as personalized or targeted ads. We show interest-based ads to display features, products, and services that might be of interest to you. We do not use information that personally identifies you to display interest-based ads.
- To serve you interest-based ads, we use information such as your interactions with the Reps websites or Reps services. We do not use information which on its own identifies you, such as name or e-mail address, to serve interest-based ads.
- We work with third parties, such as advertisers, publishers, social media networks, search engines, ad serving companies, and advertising companies working on their behalf, to improve the relevance of ads we serve. In providing you interest-based ads we do not associate your interactions on unaffiliated sites with information which on its own identifies you, such as name or email address, and we do not provide any such information to advertisers or to third-party sites that display our interest-based ads. Advertisers and other third parties may assume that users who interact with or click on an interest-based ad or content are part of the group that the ad or content is directed towards. Some third-parties may provide us pseudonymized information about you (such as demographic information or sites where you have been shown ads) from offline and online sources that we may use to provide you more relevant and useful advertising.
You can generally opt out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, or who are members of the European Interactive Digital Advertising Alliance at edaa.eu (“EIDAA”) by visiting the opt out pages on the NAI website, DAA website, or the EIDAA website.
The Reps Website and Reps Services may include third-party advertising and links to other websites and apps. Third-party advertising partners may collect information about you when you interact with their content, advertising, and services. We may provide ad companies with information that allows them to serve you with more useful and relevant Reps ads and to measure their effectiveness. We never share your name or other information that directly identifies you when we do this. Instead, we use an advertising identifier like a cookie or other device identifier. Some ad companies also use this information to serve you relevant ads from other advertisers.
COOKIES, PIXELS AND OTHER IDENTIFIERS (COLLECTIVELY, “COOKIES”).
A cookie is a small amount of data, which often includes an anonymous unique identifier that can be sent to your browser to be stored in your computer's hard drive.
Reps may set and access Reps cookies on your computer. Reps uses its own cookies for a number of purposes, including, but not limited to: (i) providing you with customized content or to remember the last page visited, (ii) accessing your information when you "sign in", (iii) keeping track of preferences you specified while on the Reps Website or using Reps Services, (iv) provide general internal and customer analytics, (iv) conducting research to improve Reps Services, (vi) support security measures such as, by example only, requiring re-logging into a Reps Service after a certain amount of time has elapsed, and (vii) assisting in identifying possible fraudulent activities.
Reps lets other third parties who participate in Reps Services or in the Reps Website, to set and access their cookies on your computer. Other companies' use of their cookies is subject to their own privacy policies, not this one, and their privacy policies should be consulted.
You can configure your browser to accept all cookies, reject all cookies, or be notified when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. In addition, to prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking https://tools.google.com/dlpage/gaoptout.
If you reject all cookies, you may not be able to fully use the Reps Website and a user may not be able to fully use Reps Services, and you may not be able to take full advantage of all offerings. . Reps refreshes cookie information related to you each and every time you log into the Reps Website or Reps Services on whichever computer or device you are using at that time. Accordingly, the previous deletion of a cookie by you may not be effective. Instead, a user should contact Reps at [email protected] to implement this.
If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Reps computers that send web pages, and process and store information, every day create records called “log files”. Log files are used for analysis, research, auditing, and other purposes. After this information has been used, it is stored and is inaccessible. Until the information is stored, a user’s Reps ID may remain in Reps’ active server log files.
REPS SHARING OF YOUR PERSONAL INFORMATION.
Reps does not share Personal Information with other people or non-affiliated companies except (i) to provide products or services you have requested or are providing, (ii) to facilitate the sharing of information to persons or entities you have authorized or are necessary for providing the Services, and/or (iii) under the following circumstances:
∙ We provide information to trusted partners who work on behalf of or with Reps. As an example, these partners may use information to help Reps communicate with you. .
∙ We use information to respond to subpoenas, court orders, or legal/regulatory process, or to establish or exercise our legal rights or defend against legal claims.
∙ We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to property and/or the physical safety of any person, violations of Reps Terms, or as otherwise required by law.
∙ We will transfer your if Reps is acquired by or merged with another entity.
Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
COMMUNICATION BY REPS TO YOU
You can opt out of receiving marketing communications from Reps by following instructions contained in the messages you receive.
We reserve the right to send users certain communications relating to the Reps Services, such as service announcements, administrative messages, changes in terms, and the Reps Newsletter, if any, that are considered part of the Reps Services users receive, without offering you the opportunity to opt out of receiving them.
CHILDREN / MINORS
Reps Services are not intended for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible.
We do not knowingly process data of European Union (“EU”) residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
If you are a California resident under the age of 18 and are a registered user of Reps Services, California Business and Professional Code Section 22581 permits you to request and obtain removal of content or information you have publically posted. Please be aware that such a request does not insure complete or comprehensive removal of information, and there may be circumstances in which the law does not require or allow removal even if requested.
CERTAIN RIGHTS YOU MAY HAVE
Your local laws (e.g., in the EU) may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
- update information which is out of date or incorrect
- delete certain information which we are holding about you
- restrict the way that we process and disclose certain of your information
- transfer your information to a third party provider of services
- revoke your consent for the processing of your information
We will consider all requests to [email protected] concerning the above, and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. As described above, we also may subcontract the processing of your data to, or otherwise share your data with service providers and business partners in countries other than your country of residence, including the United States. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge and agree to any such transfer, storage or use.
CALIFORNIA CONSUMER PROTECTION ACT (“CCPA”)
California Consumer Protection Act Disclosures. As required by the California Consumer Protection Act, the following disclosures are made effective February 6, 2021 (“Reps California Disclosure Effective Date”):
Categories of Information that can be protected. The Personal Information that Reps can collect – though none has been collected by Reps from consumers in the twelve (12) month prior to the Reps California Disclosure Effective Date above - fall into the following categories established by the California Consumer Protection Act, depending on which Reps Service is used:
- identifiers such as your name, alias, address, phone numbers, or IP address;
- personal information, such as a credit card number, or payment processor information;
- age, gender, or other protected classifications;
- commercial information, such as service, purchase and content streaming activity;
- Internet or other electronic network activity information, including content interaction information, such as content downloads, streams, and playback details;
- biometric information;
- geolocation data, such as the location of your device or computer;
- audio or visual information, such as voice, images and and/or videos recorded, collected or stored in connection with Reps Services;
- education information, such as information you provide;
- professional information, for example data you may provide about your business; and
- inference data, such as information about your purchase or service preferences.
Categories of personal information disclosed for a business purpose. The Personal Information that GDS can disclose to the third parties about consumers for a business purpose in the twelve months prior to the effective date of this Disclosure – though none has been collected by Reps from consumers in the twelve (12) month prior to the Reps California Disclosure Effective Date above - fall into the following categories established by the California Consumer Privacy Act, depending on which Reps Service is used:
- identifiers such as your name, address, phone numbers, or IP address; for example if we use a third party to provide services;
- personal information, such as a credit card number, or payment processor information;
- your age, gender, or other protected classifications (for example if you choose to participate in a survey);
- commercial information, such as the details of a product or service you purchased if a third party service provider is assisting to provide that product or service to you;
- internet or other electronic network activity information;
- geolocation data, such as providing a third partner the location of a business or residence as part of providing services to you;
- audio or visual information, for example if we use a third party to provide Reps Services to you;
- education information, for example coursework of you we may provide to a third party to provide Reps Services to you; and
- professional information, for example we may provide your professional information to a visitor or user.
Right to Request Access to or Deletion of Personal Information: You may have the right under the California Consumer Privacy Act to request information about the collection of your Personal Information by Reps, or access to or deletion of your personal information possessed by Reps. If you wish to do any of these things, please [email protected]. Please be aware that such a request does not insure complete or comprehensive removal of information, and there may be circumstances in which the law does not require or allow removal, even if requested. Also, the fulfilment of your request may result in certain Services being limited or unavailable.
No sale of personal information / Opt out. In the twelve months prior to the Reps California Disclosure Effective Date above, Reps has not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act. If you e a California resident, the CCPA may permit you or an authorized agent to opt out of the “sale” of your personal information to third parties. If you wish to do so, please contact [email protected].
No Discrimination. Reps will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.
ADDITIONAL CALIFORNIA PROTECTION
If you are a California resident you may have certain rights under California Civil Code Section 1798.83 that permits applicable individuals to request information regarding disclosure, if any, of their personal information to third parties for such third parties’ direct marketing purposes. .
CONFIDENTIALITY AND SECURITY
We have safeguards that protect personal information about you.
If you have questions or suggestions, please contact us at: [email protected].