Privacy Policy

Effective Date: 13-Nov-2024
Last Updated: 19-Nov-2024

Introduction

Forci Web Consulting Ltd. ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website https://replero.com or use our services, including our browser extension that provides smart buttons and summarization features (collectively, the "Service"). It also informs you about your privacy rights and how the law protects you.

We process your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. Please read this Privacy Policy carefully. If you do not agree with the terms, please do not access or use the Service.

1. Data Controller and Contact Details

Forci Web Consulting Ltd.
Address: Sofia, zh.k. Suhata reka, bl. 52, vh. G, ap. 18, Sofia-City 1517, Bulgaria
Email: legal+replero@forci.com
Phone: +44 203 823 6724

2. Personal Data We Collect

We may collect, use, store, and transfer different kinds of personal data about you:

  • Identity Data: First name, last name, date of birth.

  • Contact Data: Email address, telephone numbers, postal address, work address.

  • Profile Data: Username and password, social media profiles.

  • Financial Data: Payment card details, bank account information.

  • Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, operating system, platform, and other technology on the devices you use to access the Service.

  • Usage Data: Information about how you use our website, browser extension, and services.

  • Communications Data: Content of messages or information you input when using our Service, including any personal data contained within those messages.

  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.

3. How We Collect Your Personal Data

We use different methods to collect data from and about you, including:

  • Direct Interactions: You provide personal data when you fill in forms, create an account, subscribe to our services, or communicate with us.

  • Automated Technologies: As you interact with our Service, we may automatically collect Technical Data about your equipment, browsing actions, and patterns via cookies and similar technologies.

  • Third Parties or Public Sources: We may receive personal data about you from analytics providers, advertising networks, search information providers, and publicly available sources.

  • User Content: When you use our browser extension or other services to process messages or content, we collect and process the content you input, which may include personal data.

4. Purposes and Legal Basis for Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:


Purpose

Data Categories

Legal Basis

To register you as a new user

Identity, Contact, Profile

Performance of a contract

To process payments and deliver services

Identity, Contact, Financial

Performance of a contract

To manage our relationship with you

Identity, Contact, Profile

Performance of a contract; Legitimate interests (keeping records updated)

To send marketing communications

Identity, Contact, Marketing and Communications

Consent

To administer and protect our business and Service

Identity, Contact, Technical, Usage

Legitimate interests (running our business, network security)

To use data analytics to improve our Service

Technical, Usage

Legitimate interests (defining customer types, keeping website updated)

To process and analyze user messages via our Service (including the use of OpenAI models)

Communications Data

Performance of a contract; Legitimate interests (providing and improving our services)

To comply with legal obligations

Identity, Contact

Legal obligation


Note: Where we rely on consent, you have the right to withdraw consent at any time by contacting us at dpo+replero@forci.com.

5. Processing of User Messages and Use of Third-Party Processors

Our Service includes features that allow you to process messages and content, such as smart buttons and summarization tools. When you use these features, the content you input (which may include personal data) is processed through third-party services, including OpenAI's language models.

  • Third-Party Data Processors: We use OpenAI's language models to process user messages and generate responses or summaries. OpenAI processes this data in accordance with their privacy policies and data handling practices.

  • International Data Transfers: The processing of your messages by OpenAI may involve the transfer of your personal data outside the European Economic Area (EEA). We ensure that appropriate safeguards are in place for such transfers, as detailed in Section 6.

  • Data Minimization: We only send the necessary content to OpenAI's models for processing and take steps to minimize the personal data included in such content.

  • Confidentiality and Security: We have agreements in place with OpenAI to ensure that your data is handled securely and confidentially. OpenAI has implemented measures to protect personal data, including encryption and access controls.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the EEA, including the United States, where OpenAI is based. We ensure appropriate safeguards are in place to protect your personal data, such as:

  • Standard Contractual Clauses: We use standard contractual clauses approved by the European Commission to ensure an adequate level of protection.

  • Adequacy Decisions: For countries deemed by the European Commission to provide an adequate level of data protection, we rely on such decisions.

  • Additional Safeguards: OpenAI has committed to compliance with GDPR and implements additional measures to protect data transferred outside the EEA.

You can obtain further information about the safeguards we use for international transfers by contacting us at dpo+replero@forci.com.

7. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including legal, accounting, or reporting requirements.

Retention Periods:

  • User Account Data: Retained for the duration of your account and up to 2 years after termination.

  • Financial Records: Retained for 7 years to comply with tax and legal obligations.

  • Communications Data: Content processed through our Service may be retained for up to 30 days, after which it is securely deleted. OpenAI's retention policies may vary; please refer to OpenAI's Data Usage for Services for more information.

  • Marketing Data: Retained until you withdraw consent.

8. Your Rights

Under GDPR, you have the right to:

  • Access: Request access to your personal data.

  • Rectification: Request correction of inaccurate or incomplete data.

  • Erasure: Request deletion of your personal data where there is no good reason for us to continue processing it.

  • Restriction: Request restriction of processing your personal data in certain circumstances.

  • Data Portability: Receive your data in a structured, commonly used, machine-readable format, and have the right to transmit those data to another controller.

  • Object: Object to processing of your personal data where we are relying on legitimate interests.

  • Withdraw Consent: At any time, where we are relying on consent to process your personal data.

To exercise these rights, contact us at dpo+replero@forci.com.

You also have the right to lodge a complaint with a supervisory authority in your country, such as the Bulgarian Commission for Personal Data Protection.

9. Cookies and Similar Technologies

We use cookies and similar tracking technologies to enhance your experience and analyze usage of our Service. For details, please refer to our Cookie Policy.

10. Security

We implement appropriate technical and organizational measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. However, no system is completely secure, and we cannot guarantee absolute security.

11. Children's Privacy

Our Service is not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If we learn that we have collected personal data from a child under 16, we will delete that information promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes we make will be posted on this page, and where appropriate, notified to you via email or a prominent notice on our Service. Please check back frequently to see any updates or changes to our Privacy Policy.

13. Third-Party Links

Our Service may include links to third-party websites, plug-ins, and applications, including those of OpenAI. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy policy of every website you visit.

14. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer:

Data Protection Officer

Forci Web Consulting Ltd.
Address: Sofia, zh.k. Suhata reka, bl. 52, vh. G, ap. 18, Sofia-City 1517, Bulgaria
Email: dpo+replero@forci.com

By using our Service, you acknowledge that you have read and understood this Privacy Policy.