Replaio

Privacy Policy

The content of the Privacy Policy presented below has been created in compliance with the recently implemented GDPR and has been in force since 10 October 2018.

The Privacy Policy used as part of Replaio services is inseparable from the Terms and Conditions (repla.io/terms) which define the rules for the use of Replaio services.

We respect and care for the privacy of our Users. This is the key principle that we follow in Replaio. Therefore, in this document we will present the principles we use when processing personal data. We will explain what kind of data we collect, who we share it with and what it is used for.

We encourage you to familiarize yourself with the practices that we follow when processing your data.

Definitions

AdID – the advertising industry standard unique identifier is a unique identifier assigned to the User allowing for the analysis of the User behavior on the Internet. It allows different entities to display ads tailored to the User's preferences. Every User can reset their ID or opt out of viewing personalized ads.

localStorage – a technology that allows storing information on the User's device using a web browser. It allows to store information about the User also after the browser has been closed. Only the service (application, website) that has originally created the data has access to the said data saved in the browser. The User can manually remove this data from the browser.

Cookies – the information saved in the form of a text file on the User's end device. They contain data about the User and can only be used by the service (application, website) that has originally created the file. Typically, they contain the domain name of the site, the time they have been stored on the end device as well as a unique number and are used to analyze the User’s activity.

Cookies and Related Technologies – a common name used for the purpose of this Privacy Policy for AdID, localStorage and Cookies.

Privacy Policy – the present Privacy Policy of Replaio LLC.

Terms and Conditions – Terms and Conditions of Replaio services provided by Replaio LLC.

GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46 / EC (general regulation on data protection).

Personal data

We process the data that you provide or leave as part of using Replaio services. These are primarily data necessary to provide you with Replaio services (including providing you with a Replaio account), in particular, an email address and data the User provides us with by completing the following forms: registration, contact, station notification and application evaluation.

Users can use Replaio services anonymously – without creating a Replaio account. This does not, however, preclude the processing of personal data by us.

Respecting the right to privacy, we also protect other collected data associated with the User’s behavior on the Internet and while using mobile applications. These data are obtained through using cookies and related technologies and do not always contain information about the User’s identity.

Personal Data Administrator

Replaio LLC based in Krosno, ul. Tysiąclecia 14a, NIP number 6842650730, REGON number 381340090 entered into the National Court Register – Entrepreneurs Register by the District Court in Rzeszów, XII Commercial Division of the National Court Register, under KRS number 0000749616 is the administrator of personal data processed as part of Replaio services.

Contact details: support@repla.io

Personal Data Protection Inspector

In order to ensure a proper protection of personal data, we have appointed the Personal Data Protection Inspector. Users can contact the Personal Data Protection Inspector directly in order to discuss all matters related to the processing of personal data.

Contact details: gdpr@repla.io

The purpose of processing, legal basis and the time for processing personal data

We process personal data for the following purposes:

Providing services without logging in to a Replaio account

In order to provide the services in the version which does not require logging in to a Replaio account, we process:

  1. Data regarding the User's device in order to ensure the correct operation of the services provided: the IP address of the device, information contained in cookies or related technologies, session data, Internet browser data.
  2. Data on how to use Replaio services.

These data are processed in accordance with art. 6 par. 1 lit. b GDPR, in order to provide services, namely a contract for the provision of electronic services, in accordance with the Terms of Conditions until a User ceases to use Replaio services.

Providing services to Users logged in to a Replaio account

In order to provide the services in the version which requires logging in to a Replaio account, in addition to the information indicated for the purpose of performing the services without logging in, we process the following data:

  1. Information necessary to register an account: email address and password.
  2. Additional information provided in a Replaio account: first name and last name.
  3. Information necessary to log in via other services – Facebook or Google+: email address, first name, last name, and avatar.
  4. Information about favorite radio stations.
  5. In the case of the Replaio Premium service – information about making a payment.

Using a Replaio account requires credentials: email address and password. Providing first and last name is voluntary and the User can add it anytime by accessing your account settings.

These data are processed in accordance with art. 6 par. 1 lit. b GDPR, in order to provide services, namely a contract for the provision of electronic services, in accordance with the Terms of Conditions until a User ceases to use Replaio services.

Complaints

In order to investigate complaints, we process the following personal data: email address, name, the content of complaint, information obtained while communicating with the User. As part of the analysis related to the complaint, we can also process information about the User's use of Replaio services, information about devices, cookies or related technologies.

These data are processed in accordance with art. 6 par. 1 lit. b GDPR, in order to provide services, namely a contract for the provision of electronic services, in accordance with the Terms and Conditions for the time necessary to consider the complaint and no longer than 3 months after the completion of the complaint procedure. This is done for archiving purposes and in the case of the necessity to defend against any claims.

Contract execution

Through contacting our Users as part of technical assistance and guidance on how to use the application and collecting reviews about the application, the email address and the content of the message is processed.

These data are processed in accordance with art. 6 par. 1 lit. f GDPR, for a legitimate interest, which is to ensure contact with our Users. The processing these data does not violate their rights and freedoms.

The content of correspondence and the information about the contact is processed only for the duration of the said communication and no longer than 3 months after its completion. This is done for archiving purposes and in the case of the necessity to defend against any claims.

Legal proceedings and claims

We may process personal data of particular Users in the case of legal proceedings related to violations of the Terms and Conditions or legal regulations, proceedings to assert our claims as well as to defend against claims pressed by Users or other entities.

If personal data are processed in order to claim other Users, these data may be made available to other Users and entities or public bodies authorized by law, including but not limited to: courts, the police, prosecutors.

We will then process the data, including their disclosure in accordance with art. 6 par. 1 lit. c GDPR, i.e. in order to fulfil the obligation resulting from the provisions of law or in accordance with art. 6 par. 1 lit. f GDPR, i.e. in the legitimate interest of pursuing claims against the User.

Statistics on the use of the services

In order to improve the quality of our services, we can process statistical information regarding the use of Replaio services, including session information, IP number, time spent while using Replaio services (on individual pages and subpages, using particular functionalities), information about the device and browser used, cookies or related technologies.

These data are processed in accordance with art. 6 par. 1 lit. f GDPR, for a legitimate interest of facilitating the use of services as well as improving the quality and functionality of the services provided. The processing of these data does not violate the rights and freedoms of Users. These data are processed as part of our ongoing activities, but no longer than 60 days after receiving the information. After this time, we can continue to process general statistical data that will be deprived of information about individual Users.

Marketing and remarketing

We do not use email addresses and other data regarding Users identities for other entities’ marketing purposes. We protect Users' personal data against using them to distribute other entities’ marketing content. However, we can sporadically use these data to send information about our promotional activities.

Together with external suppliers, we process User data, including personal data collected through cookies or related technologies for marketing purposes, including the use of personalized ads (advertising that is tailored to the User's preferences) from other entities.

We do not combine this information with any information allowing to identify Users. In the case of Users who are not logged in to a Replaio account, their personal data will not be a part of this information. However, it cannot be ruled out that when combined with other data processed by us, this information may constitute personal data.

The processing of information about Users and Users' activity on the Internet is done on the basis of a legitimate interest (art. 6 par. 1 lit. f GDPR) and consists of undertaking several marketing activities aiming to present marketing information tailored to the needs and interests of Users.

Voluntary provision of personal data

Providing personal data is voluntary, however, in the case of some services, failure to provide personal data will make it impossible for Users to use these services.

Your rights related to the processing of personal data

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

Right to access data

You can request the information about the processing of personal data, namely a confirmation whether your personal data is being processed or not. If we process your data, you have the right to access them as well as to obtain a copy and additional information about: the purposes of processing, categories of personal data used, information about recipients or categories of recipients to whom the data were or will be disclosed, the period of data storage or the criteria for determining them, your rights related to the processing of personal data, the possibility of filing a complaint to the supervisory authority as well as profiling and automated processing of decisions (Right of access, art. 15 of the GDPR).

Right to rectify data

You can rectify your personal details. If you receive information that your personal data processed by us is incorrect, out-of-date or incomplete, you have the right to request their prompt rectification or supplementation (Right of rectification, art. 16 of the GDPR).

Right to delete data (in certain cases)

You have the right to request the deletion of your personal data, but if you have previously given consent to the processing of your personal data, the removal request will have the same effect as the withdrawal of the consent (Right to erasure, art. 17 of the GDPR).

Right to restrict data processing

You can request restricting the processing of your personal data (Right to limit processing, art. 18 of the GDPR), namely demand the cessation of their processing except for the storage of said data, when:

  • You question the accuracy of your personal data – during the period when we will verify their correctness.
  • You question the lawfulness of the processing of your personal data.
  • We no longer need your data, but you need them to establish, investigate or defend your claims.
  • You have objected to the processing of your data – until we decide on the validity of the objection.

Right to object

You can object to your personal data being processed for our legitimate purposes.

Right to transfer personal data

You can transfer and receive the personal data that you provided us with and for which you consented in a structured, commonly used machine-readable format or request that the said data is to be transferred to another designated administrator (Right to data portability, art. 20 of the GDPR).

To exercise the abovementioned rights, please contact the Personal Data Administrator or Personal Data Protection Inspector using the email addresses provided in the "Contact details" section.

Transfer of personal data

Service providers

In order to provide the highest quality of Replaio services and operating in accordance with the law, we may provide certain personal data to other trusted entities cooperating with us, such as:

  • Providers of hosting services that offer us certified and secure IT resources.
  • Internet and analytical service providers.
  • Suppliers of marketing services, also for the purpose of profiling Users, for example with the use of data about radio stations being listened to.

Providing data to the service providers is carried out only on the basis of relevant cooperation agreements created in line with the provisions of the GDPR.

Other entities

Excluding the cases described above, we do not disclose or transfer personal data to other Users or entities. However, in certain situations and pursuant to the applicable law, we may be obliged to disclose personal data to for example law enforcement authorities, state authorities or other Users for the purpose of pursuing their claims. In such cases, only the data that we will be obliged to disclose would be disclosed or transferred.

Information about cookies

Replaio services may use cookies, namely information saved as a text file on the User's end device. These cookies store data used only by the Replaio website. They usually contain the domain name of the site, the time they have been stored on the end device and their unique number.

Replaio services may use cookies for the following purposes:

Provision of services

We use cookies or related technologies necessary to provide and improve Replaio services. We use them to customize the content of the site to the User's preferences and its optimization, as well as to maintain the User's session which is necessary to ensure the smooth and ergonomic use of additional functions offered by our services.

Creating statistics on the use of services

We use cookies while implementing our services in order to create statistics and analyze how Users benefit from our services. This information is used to improve the quality of our services.

Our statistics are created based on a service provided by an external entity – Google Analytics.

Advertising activities

We use cookies or related technologies to display ads tailored to the preferences and interests of Users.

For this purpose, we use cookies or related technologies for analyzing the User’s online activity as well as determining the User’s preferences and interests. We also use the services provided by external entities, e.g. Google Adwords.

Types of cookies used by Replaio services

Session cookies – temporary files stored in the browser's memory until the end of the session/ the closing of the browser. They are necessary for the correct operation of some services and functions. Persistent cookies – they remain in the browser's memory for a longer period of time. This type of cookies allows to transfer information to the server each time the User visits a website. They are used to optimize the page for the User’s preferences. Third party cookies – this is the information from, e.g. advertising servers, company servers and servers of service providers that cooperate with the owner of a given website.

Web browsers allow the storage of cookies on the User's end device by default. Users can change their cookies settings at any time. Browser settings allow you to block the automatic handling of cookies or to inform about every time they are saved on the User's device. Failure to change the default cookies settings means that they will be saved on the User's device. Detailed information about the possibility of handling cookies are available in the web browsers’ settings.

Disabling the use of cookies may cause difficulties in the use of certain Replaio services or hinder the functioning of its components.

Data security

When processing your personal data, we use organizational and technical measures that are in compliance with the law on the protection of personal data and in particular with the GDPR. All data transfer operations are carried out using the SSL encryption of connections and the data are stored in a certified and secure Data Center.

Supervisory Authority

In Poland, the President of the Office of Personal Data Protection based in Warsaw, ul. Stawki 2, email: kancelaria@giodo.gov.pl is the Supervisory Authority in the field of personal data protection. If you believe that your personal data is being processed incorrectly, you have the right to file a complaint with the President of the Office of Personal Data Protection.

Changes to the Privacy Policy

This Privacy Policy may be modified or amended in order to provide our Users with an up-to-date and reliable information on the processing of personal data.