Last updated 05-01-2023
Your Data Controller
How do we protect personal information?
Information we may collect about you
Lawful basis for processing your personal information
Disclosure of your personal information
Where we store your personal data
Transfers of personal information outside of the European Economic Area (EEA) and the United Kingdom (UK)
Transfers of personal information outside of your country
Privacy when using blockchains
Your rights regarding your personal information
Our products and services are not available to children
Choices and Access
Data Protection Authorities
Supplemental Privacy Notice for US Residents
Privacy Notice for Nevada Residents
As part of our daily business operations, we collect personal information from our users and prospective users in order to provide them with our products and services and ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information.
Please note that if you are an employee of the Company, a contractor to the Company or a third-party provider, your personal information may be used in connection with your employment contract or your contractual relationship, whichever applies.
As used herein, the following terms are defined as follows:
“Site” or “our services” refers to all the services and functionalities available on  https://www.re.xyz and any pages thereof, mobile app (if any) and any other software, tools, or features provided by the Company.
“Personal information” or “personal data” or “your data” refer to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
“User”, “users” or “you” refer to anyone who accesses or uses Site and other services, websites, or apps provided by the Company.
“We”, “us”, or “Company” refer to Re, Inc. and its successors, assigns, and affiliates.
The Company respects the privacy of users who access Site, and it is therefore committed to taking the reasonable steps to safeguard any existing or prospective users, applicants and app visitors that may be required by applicable law.
The Company seeks to keep any personal data of its users and its potential users in accordance with the applicable privacy and data protection laws and regulations.
While no website or application is absolutely secure, we believe we have the necessary and appropriate technical and organizational measures and procedures in place to seek to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment. Although we have not appointed an official Group Data Protection Officer, you may request to exercise your applicable access, rectification, cancellation, and/or objection rights at the contact set out below.
The personal information that you provide us with when creating a user account or similar engagement with Site is classified as registered information, which is protected in several ways. You can access your registered information after logging in to user account. It is your responsibility to make sure that the password to your user account (if any) is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location, and only authorised personnel have access to it. All personal information is transferred to the Company over a secure connection, and thus reasonable measures are taken to prevent unauthorized parties from viewing any such information. Personal information provided to the Company that does not classify as registered information is also kept in a safe environment and accessible by authorized personnel of the Company only.
When you are opening a user account with us or using the Site, we may collect from you any of the following information:
Information that we may collect about you automatically:
We obtain information about you in a number of ways through your use of our services, including through any of our websites, the user account opening process or similar engagement with Site, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of on-going support service communications. We may also receive information about you from third parties such as your payment providers and through publicly available sources. For example:
We will process your personal information on the following bases and for the following purposes:
We process personal data in order to provide our services and products, as well as information regarding our products and services based on the relationship with our users (i.e., so as to perform our obligations), to provide users with related customer service, to respond to your inquiries and fulfill your requests, such as to send you documents you request or email alerts, to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies and/or other administrative information. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation. In addition, the processing of personal data takes place to enable the completion of our user on-boarding process.
We must verify your identity in order to open the user account and we will use your personal data in order to effectively manage your use of the Site with us.
There are a number of legal obligations which may ultimately be imposed by relevant laws to which we are subject, as well as specific statutory requirements e.g., anti-money laundering laws, financial services laws, corporation laws, privacy laws and tax laws. There are also various supervisory authorities whose laws and regulations may apply to us. Such obligations and requirements imposed on us necessary personal data processing activities for identity verification, payment processing when appropriate, compliance with court orders, tax laws or other reporting obligations and controls.
These obligations apply at various times, including user on-boarding, payments and systemic checks for risk management.
We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. Example of such processing activities include (but are not limited to) the following:
We must use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to try to ensure that we are providing the best products and services so we may periodically review your needs based on our assessment of your personal information to ensure that you are getting the benefit of the best possible products and services from us.
We may, from time-to-time, use personal information provided by you through your use of our services and/or through user surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to try to ensure the highest standards when providing you with our products and services and to continue to be a market leader within our industry.
We may need to use personal information collected from you to investigate issues or to settle disputes with you because it is our legitimate interest to ensure that issues and disputes get investigated and resolved in a timely and efficient manner.
We may need to use your personal information to comply with any applicable laws and regulations, subpoenas, court orders or other judicial processes, or requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.
From time to time, we may send you surveys as part of our user feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our products and services at the highest standard. However, we may from time to time also ask you to participate in other surveys and if you agree to participate in such surveys, we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out whether for user feedback or otherwise will be aggregated and depersonalized before the results are published and shared.
Our website pages and emails may contain web beacons or pixel tags or any other similar types of data analysis tools that allow us to track receipt of correspondence and count the number of users that have visited our webpage or opened our correspondence. We may aggregate your personal information with the personal information of our other users on an anonymous basis (that is, with your personal identifiers removed), so that more rigorous statistical analysis of general patterns may lead us to providing better products and services.
If your personal information is completely anonymized, we do not require a legal basis as the information will no longer constitute personal information. If your personal information is not in an anonymized form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.
We may use your personal information to send you marketing communications by email or other agreed forms (including social media campaigns), to ensure you are always kept up-to-date with our latest products and services. If we send you marketing communications we will do so based on your consent and registered marketing preferences.
We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the products and services we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the Terms and Conditions governing our relationship with you and other Site policies, guidelines, and procedures.
Often the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of changes to the Terms and Conditions, any other Site policies, guidelines, and procedures. or the features of our products or services. We need to process your personal information to send you these notifications. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.
As part of using your personal information for the purposes set out above, the Company may disclose your personal information to the following:
If the Company discloses your personal information to service providers and business partners, in order to perform the services requested by users, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.
In addition, where allowed by applicable law, we may use and disclose information that is not in personally identiﬁable form for any purpose. If we combine information that is not in personally identiﬁable form with information that is identiﬁable (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined
Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers and business partners store and may process your personal data in the European Union, Japan, the United Kingdom, the United States of America and elsewhere in the world.
Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), your information may be transferred to countries outside of your country of residence, including to the United States, which may provide for different data protection rules than in your country. We may transfer your personal information outside the EEA and UK to other Company subsidiaries, service providers and business partners (i.e., Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of the EEA and UK, we will use reasonable efforts to ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the European Union (EU) General Data Protection Act 2016 and the UK Data Protection Act 2018. If transfers of personal information are processed in the US, we may in some cases rely on standard contractual clauses.
Your transactions and some other activities on Site relating to Digital Assets may be recorded on a public blockchain. Please note, to be clear, the Company is entitled to limit payments for any products or services to any one or more Digital Assets and/or to fiat. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized networks which are not controlled or operated by Company or its affiliates, we are not able to erase, modify, or alter personal data from such networks.
As used above, Digital Asset” means a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “crypto asset,” or “digital commodity”), such as bitcoin, XRP or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium. We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take reasonable measures to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.
When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease being our user). For example, we may be subject to certain laws that require us to retain certain information for a period of 5 years after our business relationship with you has ended.
We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory, or technical reasons.
Also, the personal information we hold in the form of a recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements (i.e., 5 years after our business relationship with you has ended or longer if you have legitimate interests (such as handling a dispute with you). If you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.
The rights that are available to you in relation to the personal information we hold about you are outlined below.
If you ask us, we will confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request.
It is important to us that your personal information is up to date. We will take all reasonable steps to make sure that your personal information remains accurate, complete and up-to-date. If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly.
You may inform us at any time that your personal details have changed by emailing us at the email address indicated below. The Company will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof, i.e., personal information that we are required to keep for regulatory or other legal purposes.
You can ask us to delete or remove your personal information in certain circumstances such as if we no longer need it, provided that we have no legal obligation to retain that data. Such requests will be subject to the contract that you have with us, and to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have disclosed your personal information to others, we will let them know about the erasure request where possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly. Erasure is subject to the limitations set forth in the Terms and Conditions and any other Site policies, guidelines, and procedures.
You can ask us to block or suppress the processing of your personal information in certain circumstances such as if you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information. We will inform you before we decide not to agree with any requested restriction. If we have disclosed your personal information to others, we will let them know about the restriction of processing if possible. If you ask us, if possible and lawful to do so, we will also inform you with whom we have shared your personal information so that you can contact them directly.
In certain circumstances you might have the right to obtain personal information you have provided us with (in a structured, commonly used and machine readable format) and to re-use it elsewhere or ask us to transfer this to a third party of your choice.
Please see limitations and procedures set forth in the Terms and Conditions and any other Site policies, guidelines, and procedures published on the Site. Please be aware that information cannot be deleted from the public blockchain. Otherwise, you can ask us to stop processing your personal information, and we will do so, if we are:
If we have made a decision about you based solely on an automated process (e.g., through automatic profiling) that affects your ability to access Site and our products and services or has another significant effect on you, you can request not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us or for the compliance with applicable law. Even if a decision is necessary for entering into or performing a contract, you may contest the decision and require human intervention. We may not be able to offer our products or services to you in such a case.
[Except to the extent permitted by the Terms and Conditions, our products and services are not directed to persons under the age of majority in such person’s jurisdiction (e.g., 18 years old in the United States), hereinafter “Children”, “Child” and we do not knowingly collect personal information from Children. If we learn that we have inadvertently gathered personal information from a Child, we will take legally permissible measures to remove that information from our records. The Company will require the user to delete his or her account and will not allow the use of our products and services. If you are a parent or guardian of a Child, and you become aware that a Child has provided personal information to us, please contact us at the email address indicated below. You may request to exercise your applicable access, rectification, cancellation, and/or objection rights by contacting us at firstname.lastname@example.org.
If you have a problem reading or accessing information or materials on Site, please inform us at the email address indicated below.
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from:
Receiving marketing communications from us: If you no longer want to receive marketing communications from us on a going forward basis, you may opt out of receiving them by contacting us at the email address indicated in the section “Contact Information” below. In your request to us, please provide your name, identify the form(s) of marketing communications that you no longer wish to receive, and include the address(es) to which it/they are sent. For example, if you no longer wish to receive marketing emails or direct mail from us, tell us that, and provide your name and email or postal address.
Receiving reminders from us: If you no longer want to receive reminders from us on a going-forward basis, you may opt out of receiving them by contacting us at the email address indicated in the section “Contact Information” below. In your request to us, please provide your name and the email address or phone number at which you receive reminders from us.
Our sharing of your personal information with afﬁliates and third-party partners: If you previously opted in to receiving marketing communications from our afﬁliates or third-party partners, you may opt out of our sharing of your personal information with those parties for their direct marketing purposes on a going-forward basis by contacting us at the email address indicated in the section “Contact Information” below. In your request to us, please state that we should no longer share your personal information with our afﬁliates and/or third party partners for their marketing purposes, and include your name and email address.
We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your personal information from the databases of our affiliates with which we have already shared your information (i.e., as of the date that we implement your opt-out request). Please also note that if you opt out of receiving marketing-related messages from us, we may still send you important transactional and administrative messages, from which you cannot opt out.
If you would like to review, correct, update, restrict, or delete your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact us the email address indicated in the section “Contact Information” below. We will respond to your request as soon as reasonably practicable and no later than one month after receipt. If circumstances cause any delay in our response, you will be promptly notiﬁed and provided a date for our response.
Last updated 05-01-2023
This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about California, Colorado, Virginia, Utah, and Connecticut consumers. It provides information required under the following laws (collectively, as amended from time to time, “US State Privacy Laws”):
We also provide information collected about Nevada consumers under the heading “Privacy Notice for Nevada Residents” at the end of this Supplemental Notice. The other portions of this Supplemental Notice do not apply to Nevada consumers.
Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.
Please note that if you are an employee of the Company, a contractor to the Company or a third-party provider, your personal information may be used in connection with your employment contract or your contractual relationship, whichever applies.
To the extent other terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.
We, and our Vendors, may have collected and processed the following categories of Personal Information about you in the preceding 12 months:
Retention of Personal Information. We retain your Personal Information for the period reasonably necessary to provide goods and services to you and for the period reasonably necessary to support our business operational purposes listed in Section E.
We may disclose the following categories of Personal Information to Vendors and Third Parties:
Disclosure for California Consumers: Unless specifically stated, we have not sold or shared Personal Information about California consumers to third parties for their own use in the past twelve months. Relatedly, we do not have actual knowledge that we collect, sell, or share Personal Information of California consumers under 18 years of age. If you are a parent or guardian of a California consumer under 18 years of age and you become aware that this consumer has provided personal information to us, you may request to exercise your applicable access, rectification, cancellation, and/or objection rights by contacting us at email@example.com.
However, we may share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.
For purposes of the CPRA, a “sale” is the disclosure of Personal Information to a Third Party for monetary or other valuable consideration, and a “share” is the disclosure of Personal Information to a Third Party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not sell or share Personal Information to Third Parties for their own use. However, we may share or process one or more of the above categories of personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.
We may collect Personal Information directly from California, Colorado, Virginia, Utah, and Connecticut consumers, as well as from our affiliates, business partners, joint marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, caregivers, third party information providers, affiliates with whom you have a business relationship, service providers with which we have a contractual relationship and to which you have provided your personal information, cookies and other tracking technologies, and Vendors and Third Parties when they share the information with us.
We, and our Vendors, collect and process the Personal Information (excluding Sensitive Personal Information) described in this Supplemental Notice to:
To the extent that We and our Vendors collect and process Sensitive Personal Information, We, and our Vendors, collect and process the Sensitive Personal Information described in this Supplemental Notice for:
You may exercise the data subject rights applicable to you under the applicable US State Privacy Law by contacting us at firstname.lastname@example.org. While we will make reasonable efforts to accommodate your request, we reserve the right to impose certain restrictions or requirements on your request, if allowed by or required by applicable law.
Consumers in some states, including California, may also authorize an agent to make data subject requests on their behalf.
We have provided such information in this Supplemental Notice, and you may request further information about our privacy practices by contacting us at email@example.com.
We collect certain personal information of Nevada consumers through our Internet websites or other online service. This information includes one or more of the following elements of personally identifiable information:
We collect this personal information for the following purposes:
Your Privacy Rights: Right to access and/or correct your personal information, or opt out of sale of personal information.
If you would like to review, correct, or update your personal information, you or your authorized representative may submit your request to firstname.lastname@example.org. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.
We generally do not disclose or share personal information for profit. Under Nevada law, you have the right to direct us to not sell or license your personal information to third parties. To exercise this right, if applicable, you or your authorized representative may submit a request to email@example.com. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.