Replaio Browser

Replaio Services Privacy Policy

First effective date: 2018-10-21
Last update: 2022-01-18

Introduction

We do our best to make using Replaio services enjoyable and safe for you. You entrust us with some personal data by using our services. We assure you that we process personal data in a very limited way, only to the extent required for providing our services at the highest possible level.

We respect and do care about the privacy of our users. This is the number one priority at Replaio. In this document, we want to make you familiar with the rules that we apply when processing personal data. We highly encourage you to read and review our policies and practices carefully.

We process personal data in accordance with the law, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation - GDPR)

The administrator of personal data processed as part of Replaio Services is Replaio sp. z o.o. with its registered office in Krosno, ul. Tysiąclecia 14a, NIP 6842650730, REGON number 381340090 entered into the National Court Register by the District Court in Rzeszów, 12th Commercial Division of the National Court Register, under KRS number 0000749616.

The Privacy Policy applied as part of the Replaio Services is inextricably linked with the Terms of Use https://repla.io/terms, which governs the use of the Replaio Services.

In order to get information related to this privacy policy, please e-mail us at support@repla.io or write at the following address: Replaio sp. z o.o, ul. Tysiąclecia 14a, 38-400 Krosno, Poland.

About this Privacy Policy

In this Privacy Policy, we want to provide you with information about the processing of personal data as part of the supplying of Replaio Services, and also we want to explain to you:

  • What data do we process?
  • For what purpose and on what basis do we process the data?
  • What are your rights?
  • How long do we keep the data?
  • Do we share data and where can it be processed?
  • Who do we collect personal data from?
  • How do we protect and process personal data?
  • Children's privacy protection. Do we collect data from children?

What personal data do we process?

We process only the necessary data that you provide or leave when using Replaio Services and data acquired from our partners. These are primarily data necessary to provide the Replaio Services, including providing you with a Replaio account. You can use the Replaio Services anonymously - without creating a Replaio account. However, this does not exclude the processing of personal data by us.

Providing personal data is voluntary, but not providing them in the case of certain services results in not supplying them.

More information about what data we process can be found in the next point in the section "Purposes of data processing".

For what purpose and on what basis do we process personal data?

The basic purposes of processing personal data by us are:

  • providing Replaio Services,
  • fulfillment of our legal or contractual obligations,
  • pursuing our legitimate interests.

When you start using our services, incl. by installing the Replaio Radio application, you accept and enter into a contract with us in accordance with the provisions of our Terms of Use https://repla.io/terms. Pursuant to this agreement, we are required to provide services to you, which requires the processing of personal data.

Purposes of data processing

Provision and personalization of Replaio Services

Without using a Replaio Account - without logging in

In order to provide Replaio Services without logging in, we process:

  1. Data on the user's device, in order to ensure the correct operation of the services: device IP address, the information contained in cookies or other similar technologies, session data.

Processing of your location data is required to offer Replaio Services tailored to your location (e.g., suggesting local radio stations). In order to provide services, Replaio Radio processes the IP address of the user's device. This simplified "geolocation", that is, assignment to the place of supply of the service, takes place solely on the basis of the IP address. From the information obtained in this way, it is not possible to obtain precise information as to the current location of the user.

  1. Data on how to use Replaio services.

Provision of Services with a Replaio Account - with logging in

In order to provide services in the version with logging in, in addition to the information indicated for the purpose of providing services without logging in, we process:

  1. Information necessary to register an account: e-mail address and password.
  2. Additional not required information provided to identify the Replaio account: nickname or name and surname.
  3. Information necessary to log in via other services: Facebook, Google, Huawei: e-mail address, name and surname, avatar.
  4. Information about your favorite radio stations.
  5. In the case of Replaio Premium service - payment information.

Using a Replaio account requires providing credentials: an e-mail address and a password. Providing your name and surname is voluntary and the user can add them at any time as account identification data.

We process this data in order to provide services, i.e. to perform the contract. The legal basis for the collection and processing of personal data is Art. 6(1)(b) GDPR.

Implementation of contact

When contacting our users as part of technical support and how to use the application, and collecting opinions about the application, we process the e-mail address and the content of the message.

We process this data in order to provide services, i.e. to perform the contract, and in the legitimate interest of ensuring contact with users. The legal basis for the collection and processing of personal data is Art. 6(1)(b) and Art. 6(1)(f) GDPR

Diagnostics, troubleshooting, development, development of new features and improvements to Replaio Services

In order to improve the quality of our services, we may process information about the use of Replaio Services, including information about the session, IP address, amount of time spent while using Replaio Services on individual pages and subpages, use of individual features and content. We process this data in order to provide services, i.e. to perform the contract, and in the legitimate interest of creating solutions that facilitate the use of services and improve the quality and functionality of the services provided. The legal basis for the collection and processing of personal data is Art. 6(1)(b) and Art. 6(1)(f) GDPR.

Statistics

For statistical analysis of the use of services, Replaio uses Google Firebase, a service provided by:

Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043, USA (hereinafter Google).

Google Firebase collects and processes data that enables the analysis of how users use the Replaio application. The data obtained in this way is in no way linked to other personal data processed by Google. Replaio has no influence on the scope of such data collection. The purpose and scope of data collection, processing and use by Google as well as the rights and options for setting up privacy are described in the Google privacy policy at: https://policies.google.com/privacy.

The legal basis for data collection is Art. 6(1)(f) GDPR.

Marketing, promotion and advertising

Direct marketing

We do not use personal data, including e-mail addresses and other data regarding the identity of users, for marketing purposes of other entities. However, we may occasionally send you information about our promotional activities in the form of e-mails or push notifications directly in the app.

In order to partially cover the cost of living, we place advertisements provided by our partners in our services. For this purpose, they also provide us with data that may be related to the users' behavior on the Internet: advertising identifiers and cookie identifiers. This allows us to display advertisements that are more relevant to the interests of users. In addition, this data allows us to test the effectiveness of the content provided in this way.

Standard advertising

Standard advertising is advertising that is not related to user preferences. In the event of such advertising, the data is processed for marketing purposes in connection with the implementation of our legitimate interest.

Personalized advertising

Together with external suppliers, we process user data, including data collected via cookies or other similar technologies, for marketing purposes, including in relation to targeting users with personalized advertising (i.e. advertising that is tailored to the user's preferences) of other entities.

Profiling for marketing purposes, carried out by our trusted partners, takes place provided that you give your consent. The consent is voluntary. Consent may be expressed in a message displayed in the consent collection process. You can withdraw your consent at any time.

We do not combine this information with information determining the identity of users, and in the case of users who are not logged in, they will not constitute personal data.

Our partners, the services we use are:

Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043, USA (hereinafter Google)

Replaio uses a Google service to display ads on Replaio (text ads, banners, etc.). Cookies may be stored on the user's device or another solution may be used by Google or a third party on behalf of which Google acts. Thanks to them, Google collects data about the use of the website or application. Google uses the information obtained in this way to analyze user behavior with regard to advertising. If necessary Google will also pass this data to third parties if the third party processes the data at Google's request. Google does not associate the user's IP address with other data. Replaio has no influence on the processing of personal data by Google.

You can block the installation of cookies or the use of other technologies through the settings on your mobile device. You can also limit the collection of data (including your IP address) related to the use of the application by Google by changing the ad display settings. More information on this can be found at: https://policies.google.com/technologies/ads.

Through Google Services, Replaio displays advertisements from various advertising networks. The selection and display of advertisements are completely automatic. As part of this process, the following are processed: IP addresses, cookie identifiers, device identifiers, as well as the time the advertisement was displayed and the time the advertisement was clicked.

More information on how Google processes data from websites and applications can be found at: https://policies.google.com/technologies/partner-sites.

Ads provided by Google are displayed based on your activity and use of Google services. The following are analyzed: information you add to your Google account, interests estimated on the basis of your internet activity and interactions with advertisers cooperating with Google when displaying advertisements. For more information, please visit: https://safety.google/privacy/ads-and-data.

You can change the settings for displaying advertisements tailored to your preferences at: https://adssettings.google.com.

The purpose and scope of data collection, processing and use by Google and your rights and configuration options to protect your privacy are described in the Google privacy policy at: https://policies.google.com/privacy.

Facebook Inc.
1 Hacker Way
Menlo Park, CA 94025, USA (hereinafter Facebook)

Replaio uses services provided by Facebook Inc. to display advertisements on Replaio (text ads, banners, etc.). For this purpose, Replaio sends pseudonymised data to Facebook with the information that the application has been started. An advertising ID provided by the device's operating system is used. Replaio has no influence on the data processing by Facebook Inc. Purpose and scope of data collection, processing and use by Facebook Inc. and your rights and configuration options to protect your privacy can be found in the privacy policy at: https://www.facebook.com/policy.

Ads delivered by Facebook are displayed based on your activity and use of Facebook services. The following are analyzed: websites liked by you and your friends, information from your profile on Facebook and Instagram, places where you check in on Facebook. For more information, please visit: https://www.facebook.com/ads/about.

Settings regarding your preferences related to ads delivered by Facebook can be found on this page: https://www.facebook.com/adpreferences/ad_settings.

We process this data in a legitimate interest, which consists in obtaining the funds necessary to finance the services provided. The legal basis for the collection and processing of your personal data is Art. 6(1)(f) GDPR.

Explanatory proceedings, pursuing claims

In the case of proceedings related to violations of the Terms of Use or legal provisions, proceedings to assert our claims, defend against claims of users or other entities, we may process the personal data of certain users.

If personal data will be processed in order to pursue claims of other users, this data may be made available to other users and entities or to public authorities authorized by law, e.g. courts, police, public prosecutor's office.

We will then process this data, including making it available for the purpose of fulfilling the obligation resulting from legal provisions, i.e. in the legitimate interest of pursuing your claims against the user. The legal basis for the collection and processing of your personal data is Art. 6(1)(c) GDPR.

Ensuring compliance with the law and law enforcement requests

We may process personal data in order to fulfill legal obligations related to the activities and requests of law enforcement authorities. The legal basis for such processing of personal data is compatibility with applicable law and legitimate interest. The legal basis for the collection and processing of your personal data is Art. 6(1)(c) and Art. 6(1)(f) GDPR.

What are your rights?

The General Data Protection Regulation (GDPR) grants individuals specific rights regarding their personal data. Replaio ensures users of its services the possibility to make use of these rights subject to the technical possibilities and limitations of applicable law.

By using Replaio's services, you have the following rights regarding the processing of your personal data:

The right to access data

You have the right to be informed about the personal data we process and you can request access to this data.

The right to correct and supplement data

You can correct your personal data. If you receive information that your personal data processed by us is incorrect, out of date or incomplete, you have the right to demand immediate rectification or supplementation.

The right to delete data

You have the right to request the deletion of some of your personal data.

The right to limit data processing

You have the right to temporarily or permanently stop processing all or some of your personal data.

Right to object

You have the right to request the deletion of some of your personal data.

The right to transfer personal data

You have the right to transfer your data - the right to request a copy of your personal data in electronic form and the right to transfer it to another entity for the purpose of providing services by that entity. In order to exercise the above-mentioned rights, please contact us at the e-mail provided in the introduction to this privacy policy.

The right to lodge a complaint with a supervisory authority

You have the right to make a complaint with the supervisory authority dealing with the protection of personal data.

How long do we keep personal data?

We store personal data for as long as it is necessary for the purpose of:

  • providing services at the highest level,
  • legitimate business interest related to the development and improvement of the services provided,
  • ensuring compliance with legal obligations,
  • settlement of claims and disputes.

We only store most of the data for the duration of your use of the Replaio Services.

The personal data stored in the provision of the Replaio Services will be deleted if they are no longer needed for the purpose of storage.

Personal data of Replaio users will be deleted upon revocation of consent to such processing and storage, where applicable.

The deletion does not include data whose rectification, blocking or deletion is contrary to statutory or contractual retention periods, as well as data necessary to establish, implement or change the contractual relationship between Replaio and the user.

Do we share data and where can it be processed?

We do not transfer personal data outside the EU or EEA, unless necessary. However, some of our partners and service providers may be based or their servers may be located in a different country. All operations related to such transfer of personal data take place only in accordance with the provisions governing the processing of personal data, GDPR in particular. We ensure that third party recipients apply standard contractual clauses in accordance with EU law.

Service providers, we work with when providing Replaio services

In order to provide Replaio services at the highest level and in accordance with the law, we may share certain personal data with other trusted entities cooperating with us:

  • hosting service providers providing us with certified and secure IT resources,
  • Internet and analytical service providers.

The transfer of data to service providers takes place only on the basis of appropriate cooperation agreements that comply with the provisions for the processing of personal data, including GDPR.

Our trusted partners we work with:

DigitalOcean, LLC.
101 Avenue of the Americas
10th Floor,New York, NY 10013 USA
https://www.digitalocean.com

DigitalOcean is a cloud infrastructure provider based in New York and data centers around the world. As part of the provision of services, Replaio uses DigitalOcean hosting services - application servers and database servers.

DigitalOcean processes data in accordance with the provisions of GDPR: https://www.digitalocean.com/legal/gdpr

Any transfer of data by DigitalOcean to a country outside the EU or EEA that may be necessary for the provision of services is based on data protection guarantees in accordance with GDPR, in particular under data transfer agreements containing standard contractual clauses approved by the Commission European.

The purpose and scope of the collection, processing and use of personal data by DigitalOcean, Inc. can be found in the privacy policy: https://www.digitalocean.com/legal/privacy-policy.

Cloudflare, Inc.
101 Townsend St.
San Francisco, CA 94107, USA
https://www.cloudflare.com

Cloudflare, Inc. is a company dealing with internet infrastructure and the security of internet services. Cloudflare stores information on servers that may be located anywhere in the world. Cloudflare has committed to providing guarantees that ensure an adequate level of data protection.

Cloudflare relies on Standard Contractual Clauses as a legal mechanism for the transfer of personal data from the EEA to the US. Cloudflare Inc processes data in accordance with the provisions of the GDPR: https://www.cloudflare.com/gdpr/introduction.

The purpose and scope of the collection, processing and use of personal data by Cloudflare, Inc., can be found in the privacy policy: https://www.cloudflare.com/privacypolicy.

Freshworks Inc.
2950 S. Delaware Street, Suite 201
San Mateo, CA 94403, USA
https://www.freshworks.com

Freshworks Inc. provides, among others, the freshdesk service https://freshdesk.com, which we use as part of the Replaio Services to handle contacts with our users in order to provide technical assistance and support regarding the use of the application. As part of this goal, the following are processed, inter alia, e-mail address and message content.

Freshworks processes personal data in the USA and EEA and other countries through third parties whose services it uses. For more information, please visit: https://www.freshworks.com/privacy/data-hosting. Freshworks Inc, ensures a high level of security and processes data in accordance with the provisions of the GDPR: https://freshdesk.com/gdpr.

The purpose and scope of the collection, processing and use of personal data by Freshworks Inc. can be found in the privacy policy: https://www.freshworks.com/privacy.

Bugsnag Inc.
30 7th Street San Francisco, CA
94103 United States
https://www.bugsnag.com

Bugsnag provides Replaio with secure error monitoring and analysis of how users use Replaio Radio.

Bugsnag collects and processes personal data in accordance with the requirements of the EU General Data Protection Regulation (GDPR). Bugsnag may transfer personal data outside the EEA, usually to the United States. The transfer of data takes place only on the basis of GDPR-compliant procedures, such as standard contractual clauses: https://www.bugsnag.com/security

Purpose and scope of collection, processing and use of personal data by Bugsnag Inc. can be found in the privacy policy: https://docs.bugsnag.com/legal/privacy-policy.

Other entities

Apart from the cases described above, we do not disclose or transfer personal data to other users and entities. However, under applicable law, we may be required in certain situations to disclose personal data, e.g. to law enforcement authorities, state authorities or other users in order to pursue their claims. In such cases, only the data to which we are required to disclose is disclosed.

Who do we collect personal data from?

In order to provide Replaio Services, we may collect personal data from other, trusted and legally operating external partners.

Authentication Service Partners

By creating a Replaio account, you can choose to log in using your account in one of the services: Facebook, Google, Huawei. Then the partners provide us with the necessary data that help us set up your account. This is done on the basis of secure APIs provided by our partners.

Login with Facebook account

This service is provided by:
Facebook Inc.
1 Hacker Way
Menlo Park, CA 94025, USA (hereinafter Facebook)

To create a Replaio account with your own Facebook account you can use the "Continue with Facebook" button. In the next step, you are redirected to Facebook where you can log in using your login data. After successful login, the Facebook service provides Replaio with basic user data saved on your Facebook profile. This data is publicly available and shared with third-party services with your consent. Replaio may process your name, e-mail address and profile picture. This information is necessary to identify you when using your Replaio account.

The purpose and scope of data collection, processing and use by Facebook as well as your rights and configuration options to protect your privacy can be found in Facebook's privacy policy: https://www.facebook.com/policy.

Login with Google account

This service is provided by:
Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043, USA (hereinafter Google)

To create a Replaio account with your own Google account, you can use the "Continue with Google" button. In the next step, you are redirected to the Google service where you can log in using your login data. After successful login, the Google service provides Replaio with basic user data saved on your Google profile. This data is publicly available and shared with third-party services with your consent. Replaio may process your name, e-mail address and profile picture. This information is necessary to identify you when using your Replaio account.

The purpose and scope of the collection, processing and use of data by Google as well as your rights and configuration options for the protection of your privacy can be found in the Google privacy policy: https://policies.google.com/privacy.

Login with Huawei account

This service is provided by: Huawei Technologies Co., Ltd.
9TH Floor Tower 6 the Gateway no.9 Canton RD
Tsim Sha Tsui Kowloon HK (hereinafter Huawei)

You can use the "Continue with Huawei" button to create a Replaio account with your own Huawei account. In the next step, you are redirected to the Huawei service, where you can log in using your login data. After successful login, the Huawei service provides Replaio with basic user data stored on your Huawei profile. This data is publicly available and shared with third-party services with your consent. Replaio may process your name, e-mail address and profile picture. This information is necessary to identify you when using your Replaio account.

The purpose and scope of the collection, processing and use of data by Huawei as well as your rights and configuration options to protect your privacy can be found in the Huawei privacy policy: https://consumer.huawei.com/en/privacy/privacy-policy

The legal basis for the collection and processing of your personal data is Art. 6(1)(b) and Art. 6(1)(f) GDPR.

Technical service partners

We use the services of partners who provide us with an IP address mapping service. This is how we determine the approximate location of users. We set the location only at the country level. This is necessary to provide the Replaio Services and to provide you with relevant user-specific features and content.

How do we protect personal data?

We respect the personal data of our users and strive to provide them with protection at the highest level. We operate in accordance with applicable law and use reasonable administrative, logical and physical safeguards to protect personal data against loss, theft, unauthorized access, use or modification. These safeguards are to ensure a level of security appropriate to the risks related to the processing of the personal data of our users. We have implemented and applied various data protection policies, incl. pseudonymization, data encryption, access control, and the data is stored in a certified secure Data Center.

Children's privacy protection. Do we collect data from children?

Our Services are not directed to children under the age of 13 and we do not knowingly collect information about them. If we find that a person under the age of 13 has provided us with personal information, we delete it immediately.

If you have information that a child under the age of 13 or a child over the age of 13 has provided us with personal data without parental consent, please contact us. If we learn that we have collected any personal data from children that we should not process, or for the processing of which parents have not consented, we immediately take steps to delete such data.

The supervisory authority

The supervisory authority for the protection of personal data in Poland is the President of the Personal Data Protection Office with its headquarters in Warsaw, ul. Stawki 2, e-mail address: kancelaria@giodo.gov.pl. You have the right to lodge a complaint with PUODO in any case if you believe that your personal data is being processed incorrectly.

Changes to the Privacy Policy

This privacy policy may be modified in order to provide up-to-date and reliable information on the processing of personal data.

If the changes are material, we will expressly notify you by displaying information on the Replaio Services or by sending an e-mail. We reserve the right to inform you in advance about changes to the privacy policy.