our Privacy and Cookie Policy

Overview

User Replay Limited and its US Subsidiary (UserReplay) respect the privacy of our website visitors, prospective client, clients, business partners, prospective employees, and employees.  It is important you understand the kind of information we collect about you and how it is used. We recognize the need for appropriate safeguards and management practices in relation to the collection and use of Personal Information. This Privacy Policy sets forth the privacy principles UserReplay follows with respect to your Personal Information.  Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.


Information Collection

The information UserReplay collects falls into three primary categories: non-personally identifiable information, personally identifiable information, and sensitive personally identifiable information.

Non-Personally Identifiable Information is information that cannot alone be used to identify or contact you. A primary source of such information includes browser information when you are using our websites.  Website log files and Third Party scripts collect information that may include IP addresses, browser type, internet service provider (ISP), referral / exit pages, pages viewed, date & time stamps, and other similar information.  Log files and Third Party scripts may also collect general demographic information. We use these log files and Third Party scripts to help us analyze traffic patterns & site usage, understand audiences, as well as improve our sites and services.

Personally Identifiable Information (“PII”) is information that can be used to identify or contact you. Such information might include your name, mailing address, email address, telephone number, company or job title.  PII may be collected when you apply for an employment opportunity on our site, establish a user account for use with our services, register for an event, complete a survey, inquire about employment, correspond with us, or inquire about our service offerings.

Sensitive Personally Identifiable Information is Personal Identifiable Information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual.  Such information is only collected in the context of an employment relationship as required by law or for employment purposes.


Information Use and Sharing

UserReplay is the sole owner of the information collected through its marketing, recruitment, sales, and other commercial activities. In these activities, we only have access to and collect Personal Information that 1) you voluntarily provide us or that 2) we acquire through third-party sources such as business intelligence platforms.  We will not sell or rent to anyone the information provided to us or obtained by us.

Unless you ask us not to, we use this Personal Information for purposes such as communicating information about products or services; offering employment; responding to requests; processing transactions; providing you the services you have requested; tracking compliance with our sites’ terms of use; analyzing the characteristics of our applicants, visitors, and customers; and improve our services.  From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail

You may opt-out of communications at any time by clicking the unsubscribe link provided in an email or by sending a request to support@userreplay.com

UserReplay is the sole owner of Personal Information collected from its employees in the context of employment relationships. In this context, the data collected is solely used for employment-related purposes.  When Personal Information collected is no longer needed for the purpose(s) for which it was collected and UserReplay no longer is required to retain this information by law or policy, the information will be deleted or destroyed.  We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.


EU-U.S. Privacy Shield

UserReplay complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  UserReplay has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In the event of of any onward transfers of Personal Information, UserReplay retains responsibility for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  UserReplay shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, UserReplay commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Private Shield policy should first contact UserReplay at support@userreplay.com.  UserReplay has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint.  The services of EU DPAs are provided at no cost to you. A binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.  UserReplay is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).


How we Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.  A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.  This will prevent you from taking full advantage of the website.  To use the customer portal, you must accept cookies. If you do not, this will prevent you from being able to access the portal.


Links to Other Websites

Our website may contain links to other websites, however, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.


Controlling your Personal Information

You have the right to know what Personal Information has been collected and stored within UserReplay’s information systems about you and also ensure that this Personal Information is accurate and relevant for the purposes for which UserReplay has collected it.

Upon reasonable written request to support@userreplay.com, you may review your Personal Information, request modification/correction of any data that it is incorrect, or request removal/inactivation of Person Data as permitted by applicable law and UserReplay policies.  A small fee will be payable. Such updates will not have an effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Statement before such update.

To protect your privacy and security, we will take reasonable steps to verify your identity, before granting access to your Personal Information. In addition, we may limit or deny access to Personal Information where providing such access would be unreasonably burdensome or expensive in the circumstances.  UserReplay will endeavor to respond to all reasonable written requests of individuals to view, modify, or remove/inactivate Personal Information within 30 days of the original request.  In the context of employment relationships, UserReplay will make reasonable efforts to accommodate employee privacy preferences.

You may choose to restrict the use of your Personal Information by informing us that you do not wish to receive direct marketing information by contacting us at support@userreplay.com you may change your mind at any time by writing to or emailing us at support@userreplay.com.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.


Disclosures & Onward Transfers of Personal Information

In achievement of internal business operations, UserReplay discloses Personal Information only to Third Parties who reasonably need to know such data in accomplishment of a contracted task. For example, the electronic billing of clients or processing of benefits/payroll through third-party providers.

Recipients must agree to abide by contractual obligations established 1) restricting use of information to UserReplay instructed/specified purposes, 2) securing the availability, integrity, and confidentiality of the information whilst in their possession, and 3) returning & purging information upon termination of contract. UserReplay will ensure that the same or a better level of protection as UserReplay provides is afforded to Personal Information by contracted third-parties throughout the defined term during which a third-party is contracted. Third-parties are not permitted to use Personal Information except for the purpose of providing contracted services.

If UserReplay becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure that the acquiring organization agrees to protect personal information subject in accordance with the commitments we have made in this Privacy Policy.  UserReplay may also disclose Personal Information to any other Third Party with your prior consent to do so.

In the context of an onward transfer, UserReplay retains responsibility for the processing of Personal Information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf.  UserReplay shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.


Changes to this Policy

This Policy may be amended from time to time, and updates will be posted on this page. You should check this page from time to time to ensure that you are happy with any changes.  UserReplay employees and contractors will be notified of changes to the policy through email and through other internal communication mediums.

We will notify candidates, employees, and customers if we make changes that materially affect the manner in which we handle Personal Information previously collected. In such cases, we will allow those impacted to choose whether their Personal Information may be used in the proposed materially different manner.

 

Last Revised: 2017-03-24