Company responsible for data processing
When visitors access the Reply Website/Platform, their personal data may be processed, e.g. while browsing the Reply Website/Platform; other personal data may be voluntarily provided by visitors to the Reply Website/Platform when they register on the Reply Website/Platform, as described below.
The company responsible for data processing is Up Reply GmbH (registered office: Luise-Ullrich-Str. 14, 80636 Munich, Germany).
Types of data processed
IT systems and software procedures used to operate the Reply website/platform collect various personal data as part of their normal operation. These personal data are transmitted as part of the normal process of using the Internet (based on the TCP/IP protocol).
These personal data are not collected to associate them with specific individuals to whom they relate. However, they are such that, through the processing and aggregation of data held by third parties, it is possible to identify users.
This category of information includes the IP addresses or domain names of the computers of the users visiting the Reply website/platform, the addresses of the requested resources (in URI format, Uniform Resource Identifier), the time of the request, the method used to forward the request to the web server, the size of the file received in response, the numerical code indicating the status of the response delivered by the web server (e.g. successful, error, etc.), and other parameters related to the user's operating system and IT environment.
This data will only be used for anonymous, aggregated statistical information related to the use of the Reply Website/Platform and for the control of the correct functioning of the Reply Website/Platform in order to optimize its functionality in relation to the services offered.
Please note that the navigation data may be used for investigations aimed at identifying persons responsible for acts classified as computer crimes that harm the Reply website/platform or a linked website. If no such investigation is carried out, the web contact data will be destroyed within a few days.
Data provided voluntarily by the user
In the contact form, visitors can provide the requested personal data to complete their contact and optionally subscribe to our newsletter. In addition, in the area of the Reply Website/Platform dedicated to registered users, some other data may be collected by the Reply Website/Platform during the browsing session of logged-in registered users, e.g. for the download of restricted content.
When e-mail messages are voluntarily sent to the addresses indicated in the address section of the Reply website/platform, this implies the collection of certain personal data of the requestor, including the e-mail address of the requestor (necessary to respond to requests).
Processing methods and safety measures
Personal data is processed by Reply and/or its group of companies (hereinafter "Reply Group Companies"), as well as by third parties providing support on the Reply website/platform, using automated and non-automated equipment. This data will be processed only for the time necessary to perform the tasks for which it was collected. Compliance with specific security measures is ensured to prevent data loss, unauthorized or incorrect use and unauthorized access.
Rights of data subjects
The individuals to whom the personal data collected by the Reply website/platform refers have the right to request access to their personal data at any time and to obtain the rectification or cancellation of such data or to restrict or oppose the processing of their data. Individuals also have the right to data portability.
The persons whose data are processed after explicit consent have the right to withdraw their consent at any time, without affecting the lawfulness of the processing based on the consent given before the withdrawal.
EU residents also have the right to file a complaint with the competent supervisory authority.
Such inquiries are to be sent in writing to us: Up Reply GmbH., Luise.Ullrich.Str. 14, 80636 Munich or by e-mail to:
- (regarding the Reply website, upreply.de)
California residents may have additional rights and choices. For more information, see the CCPA Privacy Notice for California Residents.
Reply does not knowingly use its Reply website/platform to request and process data from minors, in accordance with the Data Protection Act and other laws and regulations applicable in their country of residence.
Cookies are text files or information packets sent by a Reply website/platform to the user's browser. They are stored on the computer and automatically sent back to the server each time the Reply website/platform is accessed.
There are different types of cookies, some used to make the use of the Reply website/platform more efficient, others to enable certain functions. Cookies and other tracking technologies can be:
- stored entered preferences;
- Function that prevents users from having to enter the same information several times during their visit, e.g. username and password;
- Analyses of the use of services and content provided by the Reply website/platform visited, in order to optimize the browsing experience and the services offered
- Function that allows users of the Reply website/platform to be recognized by third parties, e.g. Facebook, Linkedin, Google, Hubspot, Dynamic Yield, while navigating on the platforms of these third parties, in order to be informed about Reply initiatives that may be advertised on these platforms (retargeting);
- Conducting anonymous statistical analyses.
Types of cookies and other tracking technologies used by the Reply Website/Platform. The types of cookies and other tracking technologies used by the Reply Website/Platform are listed below and grouped according to the purpose for which they are used.
Technical and strictly necessary cookies
These cookies enable the correct functioning of certain parts of the Reply Website/Platform and are essential for the User to browse the Reply Website/Platform and use its functions (e.g. session cookies). Such cookies do not require the prior consent of the User.
There are two categories of technical cookies:
- Persistent cookies: they are used to store information such as the user's login name and password to prevent them from having to be re-entered each time the Reply website/platform is visited. This information remains stored on the computer even after closing the browser.
- Session cookies: they are used to store temporary information that allows the user to associate actions performed during a specific session. These cookies are automatically deleted from the computer when the browser is closed.
These technical and strictly necessary cookies, which are always sent by the Reply Website/Platform, are necessary for the correct visualization and functioning of the Reply Website/Platform and are therefore always used and sent in relation to the technical services offered (unless the user changes the settings in his/her browser). This category includes the persistent cookies used to allow the user to contact or register on the Reply Website/Platform and access the protected area of the Reply Website/Platform.
The aforementioned cookies used by the Reply Website/Platform avoid the need to use other data processing techniques that could potentially compromise the confidentiality of users' navigation on the Reply Website/Platform and do not allow the collection of personal information about the user.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool "Real Cookie Banner". Details on how "Real Cookie Banner" works can be found at https://devowl.io/de/rcb/datenverarbeitung/.
Legal bases for the processing of personal data in this context are Art. 6 para. 1 lit. c DS-GVO and Art. 6 para. 1 lit. f DS-GVO. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.
This type of cookies also includes third-party analytics cookies, which are used exclusively to collect information about the use of the website by visitors in aggregate form and for statistical analysis, in order to improve and facilitate the use of the Reply website/platform.
The Reply website/platform uses Google Analytics (a web service provided by Google, Inc.) in an anonymous form to measure visits to the Reply website/platform and to improve its use. This type of cookie anonymously collects information about the use of the Reply website/platform. For more information, please visit the Google Analytics page.
This website uses HubSpot, a service provided by HubSpot Inc, a software provider based in the USA with a branch office in Ireland (HubSpot Inc, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500), which we use to cover various aspects of our online marketing. These include:
- Content management (e.g. website content)
- E-mail marketing (newsletters as well as automated mailings, e.g. to inform about updates)
- Social media publishing & reporting (e.g. LinkedIn)
- Reporting (e.g. traffic sources, accesses, etc. ...)
- Contact management (e.g. user segmentation & CRM)
- Provision of landing pages and contact forms
HubSpot uses so-called "web beacons" and also "cookies", which are stored on your computer and which enable an analysis of your use of the website by us. HubSpot evaluates the collected information (e.g. IP address, geographical location, type of browser, duration of the visit and pages viewed) on our behalf in order to generate reports about the visit and the pages you visited. If you generally do not want cookies to be collected, you can prevent cookies from being stored at any time by changing your browser settings accordingly.
The data we collect using HubSpot is used by us exclusively to provide and optimize our marketing and to initiate contracts. Your data can then be used by us to contact you as a visitor to our website and to determine which of our company's services are of interest to you. If you subscribe to our blog and download documents, we can also use HubSpot to record your visits on a personal basis via your additional details (especially name/email address) and, if necessary, provide you with targeted information on topics you prefer. With the help of HubSpot, we also provide our contact service ("Let's talk about your business" or "Make an appointment now" or "Request a digital espresso"). The Contact Us Service allows you, as a visitor to our website, to learn more about our business, download content, and provide us with your contact information and other information about yourself and your business, or to schedule an appointment with us. Where required by law, we will ask you beforehand and separately for your consent to the collection, storage and processing of your data.
The data we collect using Hubspot is stored on servers of the third-party provider HubSpot in the USA. We have created the necessary conditions so that this complies with the requirements of the relevant EU data protection law. HubSpot Inc. is certified under the terms of the EU-US Privacy Shield Framework and has undertaken to treat all personal data obtained from member states of the European Union (EU) and from Switzerland in accordance with the applicable principles of the Privacy Shield agreement.
On our website and in our apps, we use Contentsquare, a tool provided by Content Square Ltd, 16 Carlisle St., London W1D 3BT, to provide visitors with a better digital experience and to improve this service and our interaction with them. Contentsquare is a digital experience analytics and information processing tool that helps us better understand the experiences of our online visitors. (Among other things: How much time do individual users spend on which pages? Which links do they click on? What is their click speed or frequency (to capture factors such as hesitation or frustration)?) To provide this information and analytics, Contentsquare uses proprietary cookies and other technologies to collect and process data about our visitors' behavior and end-user devices on our behalf. Such data includes, but is not limited to, end user device IP address, online ID (similar to a cookie ID number), device type and screen size, browser information, geographic location (up to the city or town level), e-commerce data, preferred display language on our website, and user accessibility preference behavior. To improve the tool and its services, Contentsquare may reuse this data internally for development purposes.
Reply does not use this information to identify users or to combine this data with other data.
Technical-functional cookies (implemented only for the Reply website upreply.de)
These cookies are used to store certain settings chosen by the user in order to offer him improved and personalized functions. Such cookies require the prior consent of the user.
Technical-functional cookies may be stored for the duration of a session, but are generally permanent and are sent by the Reply website/platform.
The information collected by these cookies is anonymous and cannot track the user's behavior outside the Reply website/platform.
The Reply website/platform may use functions of third parties that may install their cookies with the User's consent. These are, for example, social network icons (e.g. LinkedIn, Facebook, Twitter). This enables users to share the contents of the Reply website/platform on the aforementioned social network, or to use third party software services requested by users (e.g. map creation software and other software that provides additional services that are explicitly highlighted on the Reply website/platform). Such social network buttons are merely links that, when voluntarily clicked by the user, redirect the user to the social network platforms. This may result in cookies being stored by these social networks on the user's device. The social network providers are responsible for setting up their own cookies and their own cookie policies, which apply to the User and to which the User may refer. Reply has no
control over the process used by social network providers to collect information related to the User and associated with the available data. If the User does not want such cookies, it is sufficient not to click on such social buttons. If the user subsequently wishes to remove these cookies, he can follow the instructions in the privacy policies of the providers of these social networks.
Cookies for the creation of profiles
The Reply website/platform uses third-party tracking technologies that require the prior consent of the user.
In particular, some Reply web pages contain third-party tracking pixels (e.g. Linkedin, Facebook, Google) that are used to create profiles of users who have given their consent as described above. This information in the users' profile is used, with their consent, to recognize them when they browse third party social platforms and to inform them of content in support of Reply's initiatives (retargeting).
Reply's role is limited to enabling the installation of such third party technologies after the Users have given their consent on the cookie banner on the Reply
website/platform. The creation of user profiles and the retargeting of these users to Reply's content on third party websites and platforms are activities carried out by third parties.
Reply cannot read or use users' information collected by third party tracking technologies.
The third-party tracking technologies for retargeting purposes are:
- Facebook Pixel, a feature of Facebook Inc. 1601 Willow Road, Menlo Park, California, 94025, USA ("Facebook").
- LinkedIn Pixel, a function of LinkedIn Corporation ("LinkedIn").
- Google Pixel, a feature of Google LLC ("Google").
Users may choose to remove these tracking technologies at any time by following the instructions below.
Consent of the user to cookies and tracking technologies
For EU residents, according to the Cookie Law (Directive 2009/136/CE), Reply Website/Platform is not required to obtain consent for first party technical and analytical cookies, as they are necessary to provide the requested services. Therefore, they are automatically installed by the Reply Website/Platform during the User's first visit to a Reply Website/Platform page.
Profiling cookies and technical-functional cookies are installed only with the prior consent of the User. For this reason, when accessing the Reply Website/Platform, the User is informed through a special banner ("Cookie Banner") that (i) the Reply Website/Platform uses technical-functional cookies and profiling cookies and that (ii) the User can accept the use of such cookies by clicking on the corresponding button on the Cookie Banner or by accessing the "Cookie Settings" section.
Reply keeps track of the User's consent (if any) by means of a special technical cookie. Should the User decide to disable technical cookies, Reply will lose track of the User's consent. As a result, the next time the User visits the Reply website/platform, the cookie banner will be displayed again to the User, and the User will be asked again for his/her consent and will have to select the cookie settings. If the user uses a different Internet browser, he/she will also have to block these cookies again, since the user's settings and the cookies associated with them depend on the browser and device (computer, tablet, smartphone, etc.) used to visit the Reply Website/Platform. In any case, the cookie banner will be displayed in accordance with the applicable regulations.
If the User does not wish to give his/her consent to technical-functional cookies or profiling cookies, the User may freely decide at any time to block or disable certain groups of cookies by one or more of the following means, without affecting the functionality and use of the contents of the Reply Website/Platform:
- by clicking on the X in the upper right corner of the cookie banner;
- about changes to the settings in the "Cookie preferences" section (see the following section for more information);
- via specific browser settings used to browse the Reply website/platform (see the section below for more information).
How to manage the cookies used by the Reply website/platform through the browser configuration
Cookie Preferences Section
Users can set and change their preferences regarding cookies at any time through the Cookie Settings section. The Cookie Settings section can be accessed either through the Cookie Banner or through the specific link on each web page of the Reply Website/Platform. The Cookie Settings section allows the User to view the groups of cookies stored by Reply (as described above under Types of cookies and other tracking technologies used by the Reply Website/Platform), customize the cookie settings and withdraw the previously granted consents for each cookie category.
Please note that editing cookie settings does not remove existing cookies from the browser, but only affects the way cookies are used in the future.
The Reply website/platform is regularly scanned with our cookie scan tool to provide the most accurate list possible.
In all cases, the user also has the option to delete individual cookies from their device by consulting "Help" in the Internet browser menu.
To delete cookies from a smartphone/tablet's Internet browser, the user should consult the device's user manual for more information.
The user can learn more about cookies and how to block cookies in different browsers at https://www.allaboutcookies.org.
Other methods to disable third-party profiling cookies
In addition to disabling and/or deleting profiling cookies (see the section "Profiling cookies"), the User may follow the instructions in the privacy and cookies sections of third party websites/platforms (e.g. Facebook, Linkedin, Google). Third party providers have their own privacy information, which is different from that of the Reply website/platform and is not related to the latter.
Additional information for EU/EEA citizens
The controller of the processing of your personal data is Reply S.p.A., with registered office at Corso Francia n. 110, Turin, Italy, represented by the pro tempore legal representative.
If you have any questions or concerns about our collection or use of your personal data, you may contact one of our EU Data Protection Officers (DPOs):
If you are dissatisfied with the way we handle your personal data or if you have any questions about data protection, you have the right to complain to the competent national data protection authority. You can find the contact details of the data protection authority in your country of residence in the EU Commission's Directory of Data Protection Authorities.
Additional information for California citizens
If you are a resident of the State of California, you have the right to request information about the sharing of your personal information with third parties for direct marketing purposes and to opt out of such sharing. Please note that we do not share your personal information with unaffiliated third parties for such purposes and that we do not resell your personal information. California residents may have additional privacy rights and choices. For more information, please see theCCPA Privacy Notice for California Residents.
Additional information for citizens of Brazil
If you have any questions or concerns about our collection or use of your personal information, you may contact us:
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Up Reply GmbH
80636 Munich, Germany