Privacy Policy - Reibus International

REIBUS INTERNATIONAL, INC. PRIVACY POLICY
EFFECTIVE DATE: December 19, 2022

SCOPE

This Privacy Policy applies to personal information processed by Reibus International, Inc. (“Reibus,” “we,” “us,” and “our”) through our Site located at https://www.reibus.com, the Reibus online metals and logistics transaction marketplace (“Marketplace”), mobile applications (including any applications used to access the Marketplace), and related Reibus offerings. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights. To make this Privacy Policy easier to read, our Site, the Marketplace and related offerings are collectively called the “Services.”

Capitalized terms not defined herein will have the meaning set forth in our Terms of Use.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with our Services. For residents of certain states, more information we collect is available in our supplemental disclosure below.

INFORMATION YOU PROVIDE TO US

Account Details. We may collect information when you create an account, such as your name, email address, phone number, and address.

Use of Marketplace. If you utilize the Marketplace, we may collect and store certain information regarding your preferences regarding certain offerings available for purchase and sale on the Marketplace. Such information may be used to create a menu of offerings for your perusal for purchase or sale utilizing the Services. This information may be used to better provide and tailor the Services to you, including to predict future offering-related interests and/or purchases.

Orders. If you place an order with Reibus, we will record the personal information and details associated with the transaction. For example, we will collect information about the offerings you purchase, your billing and shipping address, phone number, and payment information. Please note that we use a third-party service provider to collect and process payment card information on the Services. Reibus does not directly collect or store any payment card information provided to the Services, but it may receive information associated with your payment card information (e.g., your billing details).

Your Communications with Us. We collect personal information from you such as your email address, phone number, or mailing address when you request information about our Products and services, register a warranty, sign up for marketing from us, register for our newsletter, request customer or technical support, or otherwise communicate with us.

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

Interactive Features. We may offer interactive features such as forums, blogs and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein.

Conferences, Trade Shows, and Other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Reibus. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.

INFORMATION COLLECTED AUTOMATICALLY

Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information and inferred location based off of your IP address), Internet service provider, mobile carrier, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Services, including the frequency and duration of your activities, items or keywords you search for, details about your search criteria, the Products that you browse, and other information about how you use the Services.

Cookie Policy and Other Tracking Technologies (e.g., Cookies, Pixel Tags/Web Beacons, and Analytics Information). We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about engagement on the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. (Session Replay Analytics). We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of our analytics partners include:
- Google Analytics. For more information about how Google uses your personal information (including for its own purposes, e.g., for profiling or linking it to other data), please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
- MixPanel. For more information about how MixPanel uses your personal information (including for its own purposes, e.g., for profiling or linking to their data), please visit https://mixpanel.com/legal/privacy-policy/. To learn more about how to opt-out of MixPanel’s use of your information, please click here or email compliance@mixpanel.com.
- Mouseflow. For more information about how Mouseflow uses your personal information (including for its own purposes, e.g., for profiling or linking to their data), please visit https://mouseflow.com/legal/company/privacy-policy/. To learn more about how to opt-out of Mouseflow’s use of your information, please click here.
- Sentry.io. For more information about how Sentry.io uses your personal information (including for its own purposes, e.g., for profiling or linking to their data), or to learn more about how to opt-out of Sentr.io’s use of your information, please visit https://sentry.io/privacy/.
- Launch Darkly. For more information about how LaunchDarkly uses your personal information (including for its own purposes, e.g., for profiling or linking to their data), or to learn more about how to opt-out of LaunchDarkly’s use of your information please visit https://launchdarkly.com/policies/privacy.
How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed and/or reviewing purchase history through the Services, including the Marketplace, to better predict needs and potential purchases;
Advertising or Targeting Related. We may use first party or third-party Technologies, including cross-device tracking, to deliver content, including ads relevant to your interests, on our Services or on third-party sites.

INFORMATION FROM OTHER SOURCES

Third-Party Organizations. We may obtain information about you from other sources, including from third-party services and organizations. For example, if you purchase a Product with financing made available via a third-party financing provider, that provider may share personal information related to your order with us.

Referrals and Sharing Features. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends or colleagues through our referral services. Our referral services may allow you to forward or share certain content with friends or colleagues, such as an email inviting your colleague to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

HOW WE USE YOUR INFORMATION

We use your personal information for a variety of business purposes, including:

To Provide the Services, Products, or Information Requested, such as:

· Fulfilling our contract with you and any orders for Products you place;

· Allowing designated customer service representatives (“CSRs”) to communicate with you, update your preferences on or through the Marketplace and/or place and accept bids on your behalf;

· Tailoring your customized menu of offerings on the Marketplace including adding or removing offerings and selecting certain offerings as favorites;

· Managing your information and account;

· Processing your payment card and/or other financial information for Products and services purchased;

· Sending you updates about your order via text message and other channels;

· Responding to questions, comments, and other requests;

· Allowing you to register for events;

· Providing access to certain areas, functionalities, and features of our Services; and

· Answering requests for customer or technical support.

Administrative Purposes, such as:

· Pursuing legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

· Measuring interest and engagement in our Services and Products;

· Improving the Services and Products;

· Developing new products and services;

· Short term, transient use, such as contextual customization of ads;

· Ensuring internal quality control and safety;

· Authenticating and verifying individual identities;

· Debugging to identify and repair errors with our Services;

· Carrying out audits;

· Communicating with you about your account, Products, activities on our Services, and Privacy Policy changes;

· Detecting security incidents;

· Preventing against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

· Enforcing our agreements; and

· Complying with our legal obligations.

We may use your information for other legitimate business purposes as permitted by law.

Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements, including tailoring your menu available through the Marketplace, tracking preferences and potential sales. We may provide you with these materials as permitted by applicable law including, but not limited to, by email, telephone and text message (including via automatic telephone dialing system), direct mail, and custom audiences advertising. Consent for calls and texts is not required as a condition to purchase Products or services. Message and data rates may apply.

Some of the ways we market to you include email campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Service Providers. We may share any personal information we collect about you with our third-party service providers, including when CSRs are third parties. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment and transaction processing; (v) customer service activities; and (vi) the provision of IT and related services.

Third-Party Financing Providers. Some of our Products may be eligible for financing offered by third-party financing providers. If you interact with a third-party financing provider, they will collect the personal information that you provide to them. Please note that the third-party financing provider is directly collecting personal information from you and may process your information in accordance with its privacy policy. In addition, if you finance the purchase of a Product through a third-party financing provider, Reibus will share personal information about your order with the third-party financing provider. We are not responsible for the third-party financing provider’s processing of your personal information.

Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising”, “cross-context behavioral advertising” or “personalized advertising.” If you prefer not to share your personal information with third-party advertising partners, you may follow the instructions below.

APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.

Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation and prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

As Permitted by Law. We may share your information with third parties as appropriate and permitted by law. The privacy choices you may have about your personal information are determined by applicable law and are described below.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. There may be additional information specific to your country, which may be found on the applicable Reibus website.

SUPERVISORY AUTHORITY

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

YOUR CHOICES

General. You may be able to opt out of certain uses of your personal information as permitted by law.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).

Text Messages. You may opt out of receiving text messages by replying “STOP” to a text message you have received from us or by otherwise contacting us.

Phone Calls. If you receive an unwanted phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in the “Contact Us” below.

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by using the following hyperlinks to visit the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out in each browser and on each device.

“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail, or by sending an email to you.

THIRD-PARTY SERVICES

The Services may contain links to third-party services and other third-party services may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each third-party service with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy or security practices of such third-party services. Using or providing personal information to these third-party services is at your own risk.

CHILDREN’S INFORMATION

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected a child’s personal information in violation of applicable law, we will promptly take steps to delete such information.

YOUR PRIVACY RIGHTS

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your personal information, including the right to opt-out of the sharing of personal information; (v) object to or restrict our use of or your sensitive personal information, including the right to opt-out of the sharing of sensitive personal information; (vi) opt out of the processing of your personal information for purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (vii) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (viii) withdraw your consent; and (ix) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

DATA RETENTION

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

CHANGES TO OUR PRIVACY POLICY

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect. This Privacy Policy was last updated per the effective date.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Reibus International, Inc.

privacy@reibus.com

(888) 834-2031

SUPPLEMENTAL STATE PRIVACY POLICY
Scope of Supplemental State Privacy Policy. This Supplemental State Privacy Policy applies to our processing of personal information under applicable laws in certain states.

The following table describes the categories of personal information Reibus has collected and whether Reibus disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

Category of Personal Information Collected by Reibus
Categories of Third Parties’ Personal Information is Disclosed to for a Business Purpose
Identifiers
· Service providers

· CSRs, which may be both employees of Reibus and contracted third parties