Privacy Policy

Introduction

This privacy policy is designed to inform users of our proprietary products available at https://www.channelreply.com/, including all sub-sites and micro-sites controlled by us, and any related smartphone or mobile application (collectively, the “Service”) about how 3CG CHANNELREPLY LLC DBA ChannelReply ("ChannelReply", "we" or "us") gathers and uses personal information submitted to ChannelReply through the Service. ChannelReply will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with all applicable U.S. laws. In this policy, “user” or “you” means any person viewing the Service or submitting any personal information to ChannelReply in connection with using the Service.

By accessing our website, using the service, integrating with our systems, or by otherwise providing us with your personally identifying information, you are accepting the practices and policies described in the Privacy Policy. Our Privacy Policy may change from time to time, and any changes will be posted on this page, and if the changes are significant, we will provide a more prominent notice. If you have questions or concerns regarding the Privacy Policy, you should first contact us at support@channelreply.com.

Our Privacy Policy does not apply to services offered by other companies or individuals, including third-party services used by ChannelReply. For these third-party services, we encourage you to familiarize yourself with the applicable third-party privacy policies.

What information do we collect?

Personal Information: If you sign up to create an account, we may ask you for certain personal information for the account, including the name of the individual creating the account, business email address, business phone number, company name, and payment information such as credit card number (the “Personal Information”). In addition, if you contact ChannelReply and disclose additional personal information, we may store that Personal Information.

User Data: When you use the service as well as any related software and application, you transmit to ChannelReply certain user-specific data (“User Data”), including to but not limited to your use of the Service, and additional information.

Web Tracking Information: We, and third-party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Service efficiently and to collect data related to usage of the Service. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the ChannelReply website, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Service you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Service more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Service or in email communications to collect information about actions that users take when they interact with the Service or such email communications, and our Contractors may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Service, but this may affect the performance of the Service.

How do we use the information we collect?

Personal Information: We will use and store Personal Information for the purpose of delivering the Service (including to establish or renew your ChannelReply account), and to analyze and enhance the operation of the Service. We may also use Personal Information for the internal operational and administrative purposes of the Service. We may enter Personal Information into our contact management database, and may use such database to send you marketing materials and to contact you regarding your interest in ChannelReply products and services.

User Data: We will use the User Data to provide the Service. We may aggregate User Data across all or a subset of users to create statistical information relating to the use of the Service, as described in “Aggregate Information” below.

Aggregate Information: We will also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information and User Data but in its aggregated form it does not relate to or identify any particular client or individual or any specific user’s data. This data is used to understand our customer base and to develop, improve and market our services.

Web Tracking Information: We use Web Tracking Information to administer the Service and to understand how well our Service is working, to store your user preferences, and to develop statistical information on usage of the Service. This allows us to determine which features users like best to help us improve our Service, to personalize your user experience, and to measure overall effectiveness.

Legal Exception: Notwithstanding the above, ChannelReply may use Personal Information and User Data to the extent required by law or legal process, or if in ChannelReply’s reasonable discretion use is necessary to investigate fraud or any threat to the safety of any individual, to protect ChannelReply’s legal rights or to protect the rights of third-parties.

What information do we disclose to third-parties?

ChannelReply’s Disclosure of Personal Information: ChannelReply will not disclose Personal Information to any third-party except to our Contractors who are bound by written obligations of confidentiality, or as described under “Permitted Disclosures” below.

User Data: We only disclose User Data to any of the designated administrators of the business entity that you establish via your account. Except as described above, we disclose User Data only to you, the user who submitted the User Data to ChannelReply, to our Contractors who are bound by obligations of confidentiality, and as described under “Permitted Disclosures” below.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Service and the behavior of users, and to operate and improve the Service.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information that identifies any particular user or person to any third-parties, such as potential customers, business partners, advertisers, and funding sources, in order to describe our business and operations.

Permitted Disclosures: Notwithstanding the foregoing, ChannelReply reserves the right to disclose any information ChannelReply collects in connection with the Service, without further notice to you (a) to any successor to ChannelReply’s business as a result of any merger, acquisition or similar transaction; and (b) to any law enforcement or regulatory authority to the extent required by law or if, in ChannelReply’s reasonable discretion, disclosure is necessary to investigate fraud or any threat to the safety of any individual, to protect ChannelReply’s legal rights or to protect the rights of third-parties.

How can you opt out of use and disclosure of your information?

If you would like your Personal Information removed from our mailing list or database, please contact us at support@channelreply.com. In the event of any such removal, ChannelReply may retain copies of information for its archives.

Access and updating of information

You can update your Personal Information by using the profile editing tools on the Service. ChannelReply will respond to any reasonable request by a user to review or amend his or her Personal Information held in our mailing list or database. ChannelReply reserves the right to verify your identity in order to provide such access. Please contact us by sending an email to support@channelreply.com.

Security: We will take security precautions to protect the security and integrity of your Personal Information and User Data in accordance with this policy and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third-parties that breach our reasonable security procedures.

Links: The Service may contain links to other websites. ChannelReply is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our site and review the privacy statements of each Website they visit that collects information. This Privacy Policy applies solely to personal information collected by ChannelReply.

Amendments: ChannelReply may modify or amend this policy from time to time. If we make any material changes, as determined by ChannelReply, in the way in which Personal Information or User Data is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Service.

Service Visitors from outside the United States: ChannelReply and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Terms of Use: This policy forms part of, and is subject to, the provisions of ChannelReply’s Terms of Service on any applicable Subscription Agreement.

Data Processing Agreement: By using the Service, you agree to our Data Processing Agreement.

Rights of EU Residents

This Section applies to users who are accessing the Site from the EU. Under certain circumstances, EU residents have rights under data protection laws in relation to their personal data. If you are an EU resident, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us OR email gdpr@channelreply.com.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of your other rights) unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

International Transfers

Whenever we transfer personal data out of the European Economic Area, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them under the Standard Contractual Clauses or another legal mechanism which requires them to provide similar protection to personal data shared between Europe and the US.

Privacy Notice for California Residents

This Section applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in compliance with the California Consumer Privacy Act of 2018 (CCPA). Capitalized terms used herein and not defined in the Privacy Policy have the same meaning as defined in the CCPA.

Information We Collect

Our Site collects Personal Information, further defined under “What information do we collect?” For purposes of this Section, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.

Our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Category	Specific Fields
A. Identifiers.	First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data submitted, stored, sent, or received by the Data Subjects.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data submitted, stored, sent, or received by the consumers. Note: Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.	None.
D. Commercial information.	Purchased product/service.
E. Biometric information.	None
F. Internet or other similar network activity.	IP Address, system usage data, aggregated data.
G. Geolocation data.	Country, state/province, address.
H. Sensory data.	None.
I. Professional or employment-related information.	None.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	None.
K. Inferences drawn from other personal information.	None.

For purposes of this Section, “Personal Information” does not include:

1. Publicly available information from government records.
2. Deidentified or aggregated consumer information.
3. Information excluded from the CCPA’s scope, such as:
   1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
   2. Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the Personal Information listed above directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms). For more information about how we collect your Personal Information, see “What information do we collect?” above.

Use of Personal Information

We may use or disclose the Personal Information we collect for the business purposes set forth in the Section titled “How do we use the information we collect?” above.

Sharing Personal Information

3CG CHANNELREPLY LLC DBA ChannelReply does not sell or disclose your Personal Information to third-parties for commercial purposes or otherwise except as set forth in the Section titled “What information do we disclose to third-parties?” above. You can opt out of our disclosure of your Personal Information by contacting us.

California Residents’ Individual Rights

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access and Data Portability Rights

California residents have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting or selling that Personal Information.
• The categories of third-parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

California residents have the right to request that 3CG CHANNELREPLY LLC DBA ChannelReply delete their Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user generated content such as product reviews), or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise a right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our Site. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at 3CG CHANNELREPLY LLC, 16192 Coastal Highway,
Lewes, Delaware 19958, or gdpr@channelreply.com.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our Site, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that 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 us an electronic message through our Site or write us at ChannelReply, 1225 Franklin Avenue, Suite 325, Garden City, NY 11530, or gdpr@channelreply.com.

Feedback

If there are any questions regarding this page, please contact us:  support@channelreply.com