Recombee Privacy Policy

This Privacy Policy explains how Recombee, s.r.o., with its principal place of business at Rybna 716/24, Stare Mesto, 110 00 Praha 1, Czech Republic (“Recombee”, “we”, “us” or “our”), collects, uses, stores, discloses and protects personal data in connection with Recombee’s websites, services, applications, communications and other related activities.

This Privacy Policy applies to visitors of Recombee’s websites, persons requesting a demo or contacting Recombee, users of Recombee’s Admin User Interface, representatives of Subscribers, prospective customers, business partners and other persons whose personal data Recombee processes for its own purposes.

This Privacy Policy does not replace any separate data processing agreement, order form, subscription agreement or other written agreement entered into between Recombee and a Subscriber.

1. GENERAL TERMS

Recombee provides recommendation services, related software tools, documentation, technical support, account management and other related services. In this Privacy Policy, such services are referred to as the “Services”.

For the purposes of this Privacy Policy:

1. “Subscriber” means a person or legal entity using, subscribing to or evaluating the Services;
2. “Admin User Interface” means Recombee’s administrative interface through which Subscriber may manage the Services;
3. “Personal Data” means any information relating to an identified or identifiable natural person;
4. “Subscriber Data” means data uploaded, submitted, transmitted or otherwise provided by Subscriber to Recombee’s systems in connection with the Services;
5. “Applicable Privacy Laws” means the GDPR, UK GDPR, ePrivacy laws, the California Consumer Privacy Act as amended by the California Privacy Rights Act, and other privacy or data protection laws applicable to Recombee and Services.

2. ROLE OF RECOMBEE

Recombee may process Personal Data in different roles depending on the context.

2.1 Recombee as Controller

Recombee acts as controller when it determines the purposes and means of processing Personal Data. This usually applies to Personal Data processed in connection with:

1. operation of Recombee’s websites;
2. registration and management of accounts;
3. demo requests, sales communications and business inquiries;
4. customer support and technical communications;
5. billing, accounting and payment administration;
6. marketing communications;
7. security, fraud prevention and abuse prevention;
8. protection of Recombee’s rights and legitimate interests;
9. improvement and analysis of Recombee’s websites and Services.

2.2 Recombee as Processor

Where Recombee processes Personal Data contained in Subscriber Data on behalf of Subscriber and pursuant to Subscriber’s instructions, Recombee acts as processor or service provider, as applicable.

Unless explicitly agreed otherwise in writing, Recombee’s standard Services are not intended for processing Personal Data contained in Subscriber Data. If Subscriber wishes to process Personal Data through the Services, Subscriber and Recombee must enter into a separate written agreement, including a data processing agreement where required by Applicable Privacy Laws.

Subscriber is responsible for determining whether Subscriber Data contains Personal Data and whether Subscriber has a lawful basis and all required notices, consents and permissions for such processing.

3. PERSONAL DATA COLLECTED BY RECOMBEE

Recombee may collect and process the following categories of Personal Data.

3.1 Contact and Identification Data

Recombee may process names, email addresses, telephone numbers, job titles, company names, country, business address and similar contact information.

3.2 Account Data

Recombee may process account registration data, login information, organization details, role and permission settings, account preferences and information about collaborators.

3.3 Commercial and Billing Data

Recombee may process subscription plan information, payment status, billing address, tax information, invoice data, payment method information and related business records. Payment card details may be processed by third party payment providers and are not intended to be stored directly by Recombee.

3.4 Technical and Usage Data

Recombee may process IP addresses, browser type, operating system, device information, identifiers, log data, timestamps, pages visited, referring URLs, API activity, Admin User Interface activity and other data generated through use of Recombee’s websites and Services.

3.5 Communications Data

Recombee may process messages, support requests, demo requests, emails, call notes, feedback and other communications exchanged with Recombee.

3.6 Marketing Data

Recombee may process preferences relating to newsletters, product updates, events, surveys and marketing communications.

3.7 Cookies and Similar Technologies

Recombee may use cookies, pixels, local storage, analytics tools and similar technologies to operate its websites, remember preferences, analyze usage, improve performance and support marketing activities.

4. SOURCES OF PERSONAL DATA

Recombee may collect Personal Data:

1. directly from the data subject;
2. from Subscriber or Subscriber’s authorized representatives;
3. from Subscriber’s collaborators;
4. through Recombee’s websites, Services and Admin User Interface;
5. from payment processors, analytics providers, marketing tools and other service providers;
6. from public sources, public registers, business directories, events, referrals and similar business sources.

5. PURPOSES OF PROCESSING

Recombee may process Personal Data for the following purposes:

1. to provide, operate and maintain the Services;
2. to create, administer and secure accounts and organizations;
3. to provide access to the Admin User Interface;
4. to respond to inquiries, demo requests and support requests;
5. to communicate with Subscriber and its representatives;
6. to issue invoices, process payments and maintain accounting records;
7. to monitor usage limits, service performance and system stability;
8. to prevent abuse, unauthorized access, fraud, security incidents and unlawful activity;
9. to maintain and improve Recombee’s websites, documentation and Services;
10. to send product updates, service notices and administrative messages;
11. to send marketing communications;
12. to comply with legal, tax, accounting and regulatory obligations;
13. to establish, exercise or defend legal claims;
14. to conduct business planning, reporting and internal administration.

6. LEGAL BASES FOR PROCESSING

Where EU, EEA or UK data protection laws apply, Recombee relies on the following legal bases:

1. Performance of contract, where processing is necessary to provide the Services, manage accounts, administer subscriptions or communicate about the contractual relationship;
2. Legitimate interests, where processing is necessary for Recombee’s business, security, service improvement, fraud prevention, customer support, business communications or internal administration, provided that such interests are not overridden by the rights and freedoms of the data subject;
3. Compliance with legal obligations, where processing is necessary for tax, accounting, corporate, regulatory or legal compliance;
4. Consent, where consent is required for specific cookies, marketing communications or other processing activities;
5. Establishment, exercise or defense of legal claims, where processing is necessary in connection with disputes, investigations or legal proceedings.

7. COOKIES

Recombee may use cookies and similar technologies for the following purposes:

1. strictly necessary operation of the websites and Services;
2. remembering user preferences;
3. measuring website performance and usage;
4. improving website functionality;
5. supporting marketing and analytics activities.

Where required by law, Recombee will request consent before using non-essential cookies. A user may manage cookies through browser settings or, where available, Recombee’s cookie preference tools.

Disabling certain cookies may affect the availability or functionality of Recombee’s websites or Services.

8. DISCLOSURE OF PERSONAL DATA

Recombee may disclose Personal Data to the following categories of recipients when they need to know them:

1. hosting, infrastructure and cloud service providers;
2. payment processors and billing service providers;
3. analytics, monitoring and security providers;
4. customer support and communication tools;
5. marketing and sales tools;
6. accounting, tax, legal and business advisors;
7. public authorities, courts, regulators or law enforcement bodies;
8. successors or potential successors in connection with a merger, acquisition, financing, restructuring or sale of assets.

Recombee does not sell Personal Data in the ordinary meaning of the word.

9. INTERNATIONAL TRANSFERS

Recombee is established in the Czech Republic. Personal Data may be processed in the European Union, the United Kingdom, the United States and other countries where Recombee or its service providers operate.

Where Personal Data is transferred outside the European Economic Area, the United Kingdom or Switzerland, Recombee shall use appropriate safeguards where required by Applicable Privacy Laws. Such safeguards may include the European Commission’s Standard Contractual Clauses, UK transfer mechanisms, adequacy decisions or other lawful transfer mechanisms.

10. SECURITY

Recombee shall use commercially reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, accidental or unlawful destruction, loss, alteration, disclosure or misuse.

Such measures may include access controls, authentication, encryption where appropriate, logging, monitoring, backup procedures, confidentiality obligations and security review of relevant systems.

No method of transmission over the Internet or electronic storage is completely secure. Recombee therefore cannot guarantee absolute security.

11. RETENTION

Recombee retains Personal Data for as long as necessary for the purposes described in this Privacy Policy.

The retention period depends on the nature of the Personal Data, the purpose of processing, the type of relationship with Recombee, legal obligations, limitation periods, accounting requirements and legitimate business needs.

Account data is generally retained for the duration of the account or subscription and for a reasonable period thereafter. Billing and accounting records may be retained for the period required by tax and accounting laws. Marketing data is retained until the recipient unsubscribes or Recombee otherwise removes the data in accordance with applicable law.

12. RIGHTS OF DATA SUBJECTS

Subject to Applicable Privacy Laws, a data subject may have the following rights:

1. the right to access Personal Data;
2. the right to correct inaccurate or incomplete Personal Data;
3. the right to delete Personal Data;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to withdraw consent where processing is based on consent;
8. the right to lodge a complaint with a supervisory authority

Requests may be submitted to Recombee using the contact details stated in this Privacy Policy.

Recombee may need to verify the identity of the requesting person before responding. Recombee may refuse or limit a request where permitted by law, including where the request is manifestly unfounded, excessive, affects the rights of others or conflicts with legal obligations.

13. CALIFORNIA PRIVACY NOTICE

This Section applies to California residents where the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies.

13.1 Categories of Personal Information Collected

In the preceding twelve months, Recombee may have collected the following categories of personal information:

1. identifiers, such as name, email address, business address, IP address and account identifiers;
2. commercial information, such as subscription, billing and payment-related records;
3. Internet or other electronic network activity information, such as website usage, log data and interactions with Recombee’s Services;
4. professional or employment-related information, such as company name, job title and business contact details;
5. geolocation information at a general level, such as approximate location derived from IP address;
6. inferences drawn from the above information for business communication, service improvement and account administration.

13.2 Purposes of Collection

Recombee collects personal information for the purposes described in Section 5 of this Privacy Policy, including providing the Services, administering accounts, responding to requests, processing payments, securing systems, improving services, marketing where permitted and complying with legal obligations.

13.3 Disclosure of Personal Information

Recombee may disclose personal information to the categories of recipients described in Section 8 of this Privacy Policy.

13.4 Sale or Sharing of Personal Information

Recombee does not sell personal information in the ordinary meaning of the word. Recombee does not knowingly sell or share personal information of persons under sixteen years of age.

To the extent any use of cookies, analytics or advertising technologies is considered a “sale” or “sharing” under California law, Recombee will provide a method to opt out where required.

13.5 California Rights

California residents may have the right to:

1. know what personal information Recombee collects, uses, discloses, sells or shares;
2. access personal information;
3. correct inaccurate personal information;
4. delete personal information;
5. opt out of sale or sharing of personal information;
6. limit the use and disclosure of sensitive personal information, where applicable;
7. not be discriminated against for exercising privacy rights.

California residents may submit requests using the contact details in this Privacy Policy. Recombee may verify the request before responding.

14. MARKETING COMMUNICATIONS

Recombee may send marketing communications to business contacts, prospects, Subscribers and other persons where permitted by applicable law.

Recipients may unsubscribe from marketing emails by using the unsubscribe link in the email or by contacting Recombee. Recombee may continue sending non-marketing communications, including service, security, billing and administrative messages.

15. CHILDREN

Recombee’s websites and Services are not directed to children. Recombee does not knowingly collect Personal Data from children under the age at which parental consent is required under applicable law.

If Recombee becomes aware that it has collected Personal Data from a child without required consent, Recombee will take reasonable steps to delete such Personal Data.

16. SUBSCRIBER RESPONSIBILITIES

Subscriber shall ensure that its use of the Services complies with Applicable Privacy Laws.

Subscriber is responsible for:

1. determining whether Subscriber Data contains Personal Data;
2. providing all notices required to end users or other data subjects;
3. obtaining all required consents or establishing another valid legal basis;
4. ensuring that Subscriber Data is accurate, lawful and appropriate for use with the Services;
5. entering into a separate data processing agreement with Recombee where required.

Subscriber shall not upload, transmit or otherwise provide Personal Data to Recombee unless the Parties have entered into an appropriate written agreement allowing such processing.

17. THIRD PARTY WEBSITES AND SERVICES

Recombee’s websites, documentation or Services may contain links to third party websites, applications or services.

Recombee is not responsible for the privacy practices, content or security of such third parties. Use of third party websites or services is governed by the terms and privacy policies of those third parties.

18. CHANGES TO THIS PRIVACY POLICY

Recombee may update this Privacy Policy from time to time.

If Recombee makes material changes, Recombee may provide notice by posting the updated Privacy Policy on its website, sending an email, displaying a notice in the Admin User Interface or by other reasonable means.

The updated Privacy Policy becomes effective on the date stated at the beginning of the Privacy Policy, unless a different date is specified.

19. CONTACT

Questions, requests or complaints concerning this Privacy Policy or Recombee’s processing of Personal Data may be sent to:

• Data Protection Officer (DPO): Our DPO oversees our data protection strategy and compliance with privacy laws. For any concerns related to privacy practices, data protection rights, or personal data inquiries, the DPO can be contacted at:

  • Email: dpo@recombee.com
  • Postal Address: Recombee s.r.o., Václavské náměstí 846/1, 110 00 Nové Město, Praha, Czech Republic

• Privacy Compliance Team: For general privacy inquiries or to report a privacy incident, our Privacy Compliance Team is available to assist. They can be reached at:

  • Email: data-privacy@recombee.com
  • Postal Address: Recombee, s.r.o., Rybná 716/24 110 00 Staré Město, Praha, Czech Republic

Where required by Applicable Privacy Laws, Recombee may designate additional privacy contacts, representatives or data protection contacts.