Privacy Policy

This Privacy Policy describes the ways we collect, store, use and manage the information you provide to us or we collect in connection with our Services and the Website.

If you are an employee of or a user of a service provided to you by our Business Customer, Section 11 “Personal Information Processed on behalf of Business Customers” of this Privacy Policy applies to you.

CALIFORNIA NOTICE AT COLLECTION OF PERSONAL INFORMATION: To learn about the categories of Personal Information to be collected, the purposes for which it is collected and used, whether it is “sold” or shared, our data retention practices, and how you may exercise your California privacy rights please review Section 12 “California Privacy Notice” below.

1. Definitions

• “Policy” means this Privacy Policy.
• “We”, “our” or “us” means Onerep LLC, a company located at 1750 Tysons Blvd, Suite 1500, McLean, VA 22102.
• “You”, “your” means you as an individual user of our Services and/or Website, an individual Affiliate, or an individual who is an ‘Affiliate’ contact person.
• “Website” means our website on which this Policy appears.
• “Services” means our services provided to you according to the Terms.
• “Affiliate” means an individual or a legal entity that participates in our affiliate marketing program and provides advertising services to us.
• “Terms” means our Terms of Service.
• “Personal Information” means, if not otherwise defined in the applicable law, information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. If you cannot be identified (e.g.,, when Personal Information has been aggregated and anonymized), then this Policy does not apply.
• “Business Customer” means an entity using our API or ‘Employee Benefits’ solution.

2. What Data We Collect and How We Do That

When you visit our Website, use our Services, or contact us directly we or our service providers collect and process your Personal Information. The ways it is collected can be broadly categorized into the following:

Information you provide to us directly

When you use some parts of our Services we might ask you to provide Personal Information to us. For example, you will provide your email address, home address and your name when you create an account with us. We may collect information from you when you contact us or provide feedback. In order to use our removal Services you will need to provide to us your name, alias, email address, phone number and date of birth. When you enable two-factor authentication for your account, you provide your cell phone number to us and to applicable infrastructure providers.

By subscribing to our Services you make available to us information about the payer’s zip code, IP address, card network type (Visa, MasterCard, American Express, etc.), last 4 digits of the card and its expiration date. This information we receive from our payment service providers (e.g., Stripe). We do not receive any other payment details from payment providers.

If you or your company participate in our affiliate program, we require the following information:

• if you joined as an individual, we will need to collect your name, email address, address, and other information and documents detailed in the affiliate agreement between us;
• If you are a contact person of an Affiliate, you will need to provide your name, corporate email address, and/or messenger username.

Information we or our service providers collect through your interactions with our Services

As is true of most online services, we may automatically collect certain information about the devices you use to access the Services and Website. As described further below, we or our service providers may collect and analyze (i) device information such as IP addresses, unique device identifiers, screen resolution, time zone, browser types, browser version, browser language, operating system, device make and model, and (ii) information related to the ways in which you interact with the Website and Services, such as referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website and Services, the amount of time spent on particular pages, the date and time you used the Website or Services, the frequency of your use of the Website and Services, error logs, and other similar information.

We may use third-party analytics, advertising, marketing, and affiliate management services and technologies (such as Google Analytics, Facebook Ads, Google Ads, Microsoft Ads, Sendgrid, Hotjar, Everflow, etc.) to assist in collecting this information. Information collected by various technologies, including cookies and similar tools, will be collected directly by these service providers, who use the information, for example, to evaluate your use of the Services and Website, including by analyzing usage trends, or to track which Affiliate (if any) has referred you to our Services.

Cookies and similar tracking technologies

A cookie is a small piece of text sent to your browser by a website you visit.

We use cookies necessary for you to use the Website and its essential features, including:

• to recognize you when you visit the Website.
• to remember your preferences, for example, to keep a chat with customer support after a page reload.
• to perform security measures.

We also use ‘local storage’ and ‘session storage,’ which are used to store data in your web browser. Local storage supports persistent data storage, similar to cookies but with an enhanced capacity and no information stored in the HTTP request header. Session storage is purged when you close the browser.

As mentioned earlier, third parties whose tools and services we use can serve their cookies when you use the Website and Services (third-party cookies).

We and third-party services may use the following types of cookies:

Performance and Analytics Cookies. These cookies are used, for example, to count how many visitors we receive to a page, to understand from what sources users come to the Website or to help us analyze how the Website and Services are used. For more information on Google Analytics cookies, visit https://policies.google.com. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Targeting Cookies. Such cookies, tags or pixels are set by third-party advertising services. These cookies can be used to create a user profile and display relevant ads on other sites (remarketing tags). These cookies identify the browser and the device.

Functional Cookies. These cookies are used to remember your preferences and settings.

Most web browsers allow some control of most cookies through the browser settings.

You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Website and Services may not function properly if the ability to accept cookies is disabled.

3. How We Use Personal Information

Our processing of your Personal Information is necessary for us to provide you with the Services and Website. If we do not process your Personal Information, we may be unable to provide you with all or some features of the Services.

We use your Personal Information and may share it with our service providers, partners, and contractors for a number of purposes, which may include the following:

• To operate our Services and Website, ensure they work as intended and deliver the Services you have requested.
• To support you, including assisting with the resolution of technical or other issues relating to the Services and Website.
• To facilitate billing, payments, and subscriptions to the Services.
• To manage accounts and for other administrative matters.
• To enhance our services and websites, test and develop new features and carry out research and analysis so that we can optimize your user experience and provide you and other users with more efficient tools and features.
• To analyze and aggregate data, to prepare statistics, in particular, to produce aggregated analytics and reports, which we may use internally.
• To display advertisements to you.
• To manage our Affiliate marketing program.
• To facilitate your ability to leave a review about your experience with us, as well as to assist in this process.
• To manage our relationship and communicate with you. This may include (a) operational and transactional communications, like information about changes to our Services, information about new features, security updates or assistance with using our Services; (b) survey requests, feedback collection and follow-up communication if the Terms or the use of Services has been terminated or suspended; or (c) providing you with the information you have requested from us or information we are required to send to you. These communications are part of the Services we provide to you and in most cases you will not be able to opt out of them. If an opt-out is available, you will find that option within the communication itself or in your profile settings.
• To promote and drive engagement with the Services and Website.
• To send information including confirmations, invoices and billing, technical and billing notices, updates, security alerts, and transactional or administrative messages, including text messages.
• To send marketing communications that may be of specific interest to you. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new services, newsletters, product offers, and promotions we think may be of interest to you. You may opt out of receiving marketing communications from us at any time by clicking an ‘unsubscribe’ link at the bottom of the email or contacting our support team at [email protected].
• To prevent, detect and report crime, protect you, other users and us, for example, by ensuring network and information security, mitigating security risks, detecting and preventing any fraudulent or malicious activity, and make sure that everyone is using our Services and Website fairly and in accordance with the Terms and applicable regulations.
• To perform legal duties, responsibilities, and obligations; and to comply with laws and regulations that apply to us.
• To exercise our rights set out in the Terms or other agreements with you.
• To disclose information to our contractors on a need-to-know basis.
• To evaluate or conduct a merger, restructuring, reorganization, or other sale or transfer of some or all of our assets.

4. To Whom We May Disclose Your Personal Information

There will be times when we may need to disclose your Personal Information to third parties. We may disclose your Personal Information to:

• Data broker and people-search sites: in order to provide you with the Services we have to disclose your information to data brokers and people search sites, which allows us to find your records on these sites and request their removal on your behalf;
• Third-party service providers and partners who assist us in the provision of the Services and Website, for example, (a) those who support delivery of or provide certain features in connection with the Services and Website (e.g. Stripe, a payment services provider; Sendgrid and Brevo, email delivery and customer relationship management services; HubSpot, a CRM platform, and Sentry, a crash reporting platform); (b) providers of analytics and measurement services (e.g. Google Analytics, ProfitWell etc.); (c) providers of technical infrastructure and security services (e.g. Microsoft Azure, Google Cloud, Amazon AWS, and Cloudflare); (d) providers of customer support services (e.g. Zendesk); (e) those who facilitate conduct of surveys (e.g. Hotjar); (f) those who help to advertise, market or promote our Services and Website (e.g. Mautic, Facebook Ads, Google Ads, Linkedin Ads, Tik Tok Ads, Reddit Ads, and Microsoft Ads); (g) those who assist us in developing a better product and testing new features (e.g. Unleash); (h) two-factor authentication solution providers (e.g. Twilio).
• Providers of affiliate management products and services (e.g. Everflow);
• Customer review platforms (e.g. Trustpilot);
• Law enforcement agencies, government bodies, courts or other third parties, when required by law;
• Professional advisors, such as lawyers, auditors, etc. where necessary in the course of the professional services that they render to us;
• Our contractors who have entered into binding obligations of privacy and confidentiality that are at least as protective as those in this Privacy Policy and as required by the applicable law;
• Successor to all or part of our business; and/or
• Other persons where we have your consent.

5. Data Retention

Some information you can delete whenever you like, some data is deleted automatically, and some information we retain for longer periods of time when necessary. When the information is being deleted, we make sure that your information is safely and completely removed from our servers or retained only in anonymized form.

There may be technical or business reasons or legal requirements where we are unable to fully delete or anonymize certain information. Reasons we might retain some data for longer periods of time include:

• To ensure that the Services and Website are available to you and other users.
• To protect you, other persons, and us from fraud, abuse, illegal activity and unauthorized access, for example, when we suspect someone is committing fraud.
• To comply with tax, anti-money laundering and other financial regulations, or for accounting purposes.
• To facilitate dispute resolution.
• To meet and comply with applicable law, regulation, legal process or enforceable governmental request, or when we are required to enforce the Terms, including investigation of potential violations.
• If you have directly communicated with us, for example, through a customer support channel or provided feedback or a bug report.

6. Security Measures

We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store.

Security and privacy third party risk assessment is established as a part of our vendor management process.

7. Information Concerning Children

The Website and Services are not intended for children aged 16 or under. We do not seek to collect Personal Information about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our Services, or if you believe that your child under the age of 16 may have entered Personal Information onto our Website, please contact us at [email protected]. We will delete such Personal Information from our records or seek verifiable parental or legal guardian consent to retain such information within a reasonable time..

8. Third Party Links and Services

The Services and Website may contain links to third party websites, apps, plug-ins and other services. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or privacy practices of such third party websites or services. The collection, use and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We encourage you to read the privacy statements of each and every site you visit.

9. Modifications

We reserve the right, at our sole discretion to modify or revise this Policy at any time by posting the amended Policy on the Website. Please check the most current Policy.

Your continued use of the Website or Services after a change or update has been made will constitute your acceptance to the revised Privacy Policy. If you do not agree with the modifications, please discontinue use of the Website and Services.

10. Privacy Related Inquiries

If, for any reason, you are concerned with the way that we may be using your Personal Information, you have questions about the privacy aspects of the Services or Website, please, contact us at [email protected].

11. Personal Information Processed on behalf of Business Customers

In connection with performing services to our Business Customers, we may collect, process, and store Personal Information owned and controlled by our Business Customers, strictly on a need-to-know basis to facilitate the intended Services for Business Customers and their users or employees.

We do not share Personal Information of Business Customers’ employees with third-party service providers, except for the following limited cases:

• with SendGrid, an email delivery service, we share email addresses, first names, and last names;
• with Zendesk, a provider of support services, we share email addresses, first names, last names, and phone numbers.

We do not share Personal Information of Business Customers’ employees or users for marketing or analytics purposes.

Our databases containing Personal Information are hosted on Microsoft Azure, an enterprise-level cloud platform.

This Privacy Policy does not apply to our security and privacy practices in connection with (i) your access to and use of our Business Customers’ products and services that use our API, and (ii) your data handled by your employer when administering its Employee Benefits program with us.

Business Customers are responsible for establishing policies and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, related to the collection of Personal Information in connection with the use of our Services by their end users or employees.

We collect information under the direction of our Business Customers, and have no direct relationship with individuals whose Personal Information we process in connection with our Business Customers’ use of our Services.

If you are an individual who is an end user or an employee of our Business Customer, you will be directed to contact the Business Customer you have relations with for assistance with any requests or questions related to your Personal Information.

12. California Privacy Notice

This Privacy Notice for California residents supplements the information contained in this Privacy Policy.

Categories of Personal Information Collected

Personal Information that we may collect, or may have collected from you in the preceding twelve months, fall into the following categories established by the California Consumer Privacy Act (CCPA):Such Personal Information will be retained for as long as you maintain an account with us. Certain Personal Information may be deleted earlier upon your request.

We use and disclose Sensitive Personal Information for the limited purposes permitted under the CCPA and not for the purposes of inferring characteristics about a consumer. For example, we may process your Sensitive Personal Information in order to perform the services you request from us or to verify information. The CCPA does not afford you rights to limit the use or disclosure of your Sensitive Personal Information for these purposes.

Categories of Sources of Personal Information

In the past twelve months, we have collected Personal Information relating to California residents from the sources described above in Section 2 “What Data We Collect and How We Do That”.

Categories of Third Parties and Other Entities to Whom We Disclose Personal Information

We disclose Personal Information to the categories of third parties, service providers, and contractors described above in Section 4 “To Whom We May Disclose Your Personal Information”.

Categories of Personal Information Disclosed for a Business Purpose

Personal Information that we may have disclosed about consumers for a business purpose in the preceding twelve months fall into the following categories established by the CCPA:

• identifiers, such as your name, email address, or phone numbers, for example if we use a third-party customer support services, two-factor authentication solutions, or when you interact with a customer review platform following our invitation;
• identifiers, such as your name, home address, or, in exceptional cases, ID card or driver’s license information, for example when we remove your information from people search websites;
• your age or other protected classifications under California or US federal law, for example if we conduct user surveys or analysis using a third-party service provider;
• commercial information, such as the details of a product or service you have purchased if a third party service provider is assisting to provide that product or service to you;
• geolocation data and Internet or other electronic network activity information, if we use a third-party service provider to help us with analytics, marketing or advertising;
• audio, visual, electronic or other similar information, for example if a third-party provider of customer support services reviews recordings of customer support phone calls for quality assurance purposes.

For more information about Personal Information we may disclose to third parties for a business purpose, please visit Section 4 “To Whom We May Disclose Your Personal Information” above.

Business and Commercial Purposes for Collecting Personal Information

We use Personal Information we collect for business and commercial purposes described above in Section 3 “How We Use Personal Information”. We may also use Personal Information relating to California residents for one or more of the specific “business purposes” listed in the CCPA.

Categories of Personal Information “Sold” or Shared

We do not disclose or transfer your Personal Information in exchange for payment. However, the definition of “sale” in the CCPA may be interpreted broadly.

We may provide your Personal Information to our advertising partners, analytics providers, and social networks, who assist us in advertising our Services or providing them to you. These third parties may collect such data directly from you through your use of our Services. Since these third parties may use the data for their own limited purposes, such as improving their services, enhancing their ad delivery, or for online or “cross-context” behavioral advertising, our sharing of Personal Information with them may be considered "sale" or sharing for cross-context behavioral advertising under the CCPA. In the past 12 months, the following categories of Personal Information have been "sold" or shared for cross-context behavioral advertising (as defined under the CCPA) with advertising partners, analytics providers, and social networks:

• Identifiers (e.g., device identifiers);
• Online activity information (e.g., information about devices and browsers, IP addresses associated with those devices and browsers, and usage data);
• Geolocation data (e.g., IP addresses, excluding precise geolocation).

The purpose for such “sale” or sharing is for us to use these third-party services (e.g., Google Analytics) to analyze your interactions with the Website and Services, and to market our Services.

Your Rights

You have the following right under the CCPA:

• To request that we disclose to you (a) the categories of Personal Information we have collected about you; (b) the categories of sources from which the Personal Information is collected; (c) the business or commercial purpose for collecting, “selling”, or sharing Personal Information; (d) the categories of third parties to whom we disclose Personal Information; and (e) the specific pieces of Personal Information we have collected about you.
• To request that we disclose to you (a) the categories of Personal Information we “sold” or shared about you and the categories of third parties to whom it was “sold” or shared, by category or categories of Personal Information for each category of third parties to whom it was “sold” or shared; and (b) the categories of Personal Information we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
• To request correction of inaccurate Personal Information.
• To request to delete your Personal Information, in some circumstances.
• To opt out of “selling” or sharing for cross-context behavioral advertising certain Personal Information.
• To the extent we have collected Sensitive Personal Information about you, to direct us to limit our use of it to that use which is necessary to perform our Services and to perform other services as set forth in the CCPA (which has already been done, since we do not use your Sensitive Personal Information for other purposes).
• To designate an authorized agent to exercise some of your rights.

If you wish to do any of these things, please contact us at +1 (855) 856-6655 or at [email protected]. Please be aware that we do not accept or process requests through other means (e.g., via fax, social media, etc.).

We will review the information provided and may request additional information to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information, and there may be circumstances in which the law does not require or allow us to fulfill your request.

To the extent we receive requests directly from end users or employees of our Business Customers regarding their Personal Information, we will work with such Business Customers to comply with their obligations under the CCPA.

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA.

13. Other State Privacy Laws

Certain states such as Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Virginia, and Utah have enacted their privacy laws. Although many state privacy laws do not currently apply to us due to their applicability exemptions, we are committed to voluntarily adhering to the fundamental principles of these laws.

This Privacy Policy, including Section 12 “California Privacy Policy”, comprehensively describes how we collect and process your Personal Information. In addition to these disclosures, we would like to provide the following information:

• We do not process sensitive personal information (as defined in the state privacy laws, excluding the CCPA).
• The purpose for processing Personal Information is described above in Section 3 “How We Use Personal Information”.
• The categories of Personal Information that we process are listed in Section 2 “What Data We Collect and How We Do That”.
• We process Personal Information for targeted advertising.
• We do not sell Personal Information. However, the definition of “sale” in the data privacy laws of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, and Texas, may be interpreted broadly. This interpretation could include instances where we permit authorized third-party services (e.g., Google Analytics) to collect Personal Information from our Website and use it for their own limited purposes.
• We do not process Personal Information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as those terms are defined under the applicable state privacy laws.
• We share Personal Information with our service providers, contractors, and third parties as described above in Section 4 “To Whom We May Disclose Your Personal Information”.
• We will not discriminate against you for exercising any of your consumer rights contained in the applicable state privacy laws.

Subject to the exclusions and limitations set forth in the applicable state privacy laws, you have the following rights concerning your Personal Information:

• To request that we delete your Personal Information, and we will do so unless it is reasonably necessary for us to maintain your Personal Information in compliance with the applicable state privacy law.
• To request that we correct inaccurate Personal Information.
• To confirm whether or not we are processing your Personal Information and to access it.
• To obtain a copy of Personal Information that you previously provided to us in a portable format.
• To opt out of the processing of your Personal Information for purposes of targeted advertising or the “sale” of Personal Information.

Please, contact us at +1 (855) 856-6655 or at [email protected] if you have any data privacy requests or if you wish to appeal our decision with respect to your request.