Privacy Policy Reputeo

Effective as of: 12.12. 2021.

As Reputeo d.o.o BEOGRAD-Vračar (“Reputeo”, “we,” “our,” or “us”) we take your privacy very seriously and we encourage you to read the content of this document occasionally so that you could be completely informed and could provide your consent for application of this Privacy Policy (“Privacy Policy”) and obtaining, using, and otherwise processing your personal information as presented herein only upon obtaining full knowledge of its content.

This Privacy Policy applies to all persons visiting our websites, using the App and/or any of our other services, and all of App’s related features, functionality, and services, blog, posts, feed, online shop or one of our other products or services now or in the future that reference this Privacy Policy.

This Privacy Policy explains how we collect, use, and disclose your personal information.

Please note: Reputeo operates a an online AI-powered image and data analysis engine that enables brand managers to track and report original, counterfeit as well as second-hand goods online under the name Reputeo (“Reputeo“ or “App”) as well as provides other services. This Privacy Policy also applies when you are create a user account with us (“User Account”) and use the App and the services we provide within the App. By accessing our website and our services (including the App) and providing a consent to apply Privacy Policy, you agree that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. By accepting to apply this Privacy Policy, you have provided the consent as a data subject meaning that you have provided us with the legal ground to obtain and process the information as contemplated in this Privacy Policy. In addition, please note that this Privacy Policy may be closely corelated with our Terms and Conditions of Use of Reputeo Tool (for the purposes of this Privacy Policy, such document shall be hereinafter referred to as the “Terms of Service”) and by you accepting Terms of Service, we are entitled to obtain and process your information under this Privacy Policy in order to enforce such agreement or any other agreement between us. By accepting this Privacy Policy, you have agreed that your personal information can be obtained and processed in accordance with this Privacy Policy when our legitimate interests are pursued (as such legitimate interests are provided hereunder, including through providing examples). If you do not agree with this Privacy Policy and do not want to provide the consent for its application, please stop accessing our website and using our services. Even after providing your consent to application of this Privacy Policy, you are entitled to withdraw your consent for application of this Privacy Policy at any time, however in such case you will not be able to continue to access our website and/or use our services to its full extent or to use it at all.

1. Personal Information We Collect

1.1. Data Provided Directly by You:

  • Contact and Profile Information. When you access our website and/or use our services or otherwise communicate or interact with us, wemay collect information from you that you have provided us, such asyour name, username, password, email address, age, date of birth,gender, address, personal preferences, product and service reviews,purchasing habits, desired products, purchasing history, photos andvideos that you have posted within the App, and any other personalinformation that you choose to include, or in other communications withus or using the App, including through your comments and reviews. Youacknowledge that if you post a rating and/or review within the App, yourrating and/or review may become a public information and may beretained by us. We may combine personal and non-personalinformation about you collected by us or by our affiliates and we maycombine this information with information from external sources. We use this contact and profile information to: (i) create, verify, andpersonalize our services; (ii) communicate with you directly about ourservices as well as about any questions, issues, or concerns you orother users of our services may have; (iii) fulfill your order (including anysubscription plan you may have with us); and (iv) send you informationabout our or third party products offered within our services inaccordance with your possible preferences.
  • Use of our Services and the App. If you use the App or our servicesto track your activity (including purchase of products or services), wemay collect and store this information so that you can review it on theApp and track your activity. We may also use this information tocalculate further information about your activity so that this can beprovided to you as part of the functionality of the App and our services.
  • Payment Information. When you make your purchases, you mayreveal your financial information (e.g. credit card number, etc.), howeverwe do not collect any financial or billing information from you in relationto such a transaction. Please review the relevant payment processorterms and notices to learn about how your data is used. We keep arecord of the purchases you make, the time at which you make thosepurchases and the amount spent.
  • Transaction Information. When you submit purchase order, we collectinformation, including the purchased products and services, date andtime of your transaction, and other information necessary to fulfill theorder. We use this transaction information to fulfill your order, detect andprevent fraud, personalize your experience, perform analytics/identifyusage trends, and inform you of our advertising and marketingcampaigns.
  • Communications, Participation and Other Content. We maintain allcommunications resulting from your interactions with us by email, posts,forum, comments or using our services otherwise. We also recordcomments and opinions you express, responding to our surveys,entering a sweepstakes, or taking part in promotions we help to run. Weuse all of the foregoing communications to address your questions,issues, and concerns, and to improve our services. Suchcommunication and interaction may include the content of the messageand information about when the message has been sent, as well as theparticipants of the communication. Please be aware thatcommunication and interaction posted publicly will be accessible bythose users and that we are not responsible for the manner in whichthose users use or disclose such communication and interaction.
  • Other Information You Provide. With your previous permission, wemay access your photos and/or videos from your mobile device toenable you to share your comments and reviews on our services.

1.2. Personal Information Generated and/orAutomatically Collected During Your Use ofOur Website, the App and Our OtherServices:

  • Information About Your Device and Its Software. Information aboutyour device and its software includes your IP address, browser type,internet service provider, device type/model/manufacturer, operatingsystem, date and time stamp, and a unique ID that allows us to identifyyour browser, mobile device, or your User Account (if any), identifiers ofbeacons communicated to us, and other similar information. We mayuse this device and software information to diagnose and fix technologyproblems, personalize your experience, perform analytics/identify usagetrends, and improve our products and services or develop newproducts.
  • Information About the Way You Access and Use Our Services. Wecollect information regarding your use of our services and any otheruser generated content that you generate. We also link your subscriberinformation with your activity on the App across all your devices usingyour email, password or similar information. We may also use theinformation about the way you access and use our services and/or theApp to determine which of our products and services may be of interestto you, to improve our products and services, to evaluate the success ofadvertising and marketing campaigns, and to send you marketingcommunications.
  • Analytics Information. We may collect analytics data or use third-partyanalytics tools such as Google Analytics to help us measure traffic andusage trends and the demographics of our users in order to improveour services. Please go to the Google Privacy Policy to learn more.
  • Location Information. We do not obtain or store your locationinformation while using our website or using our services. In that sense,under no circumstances shall we be liable for claims or for anydamages therefrom, arising out of your informed decision to allow otherusers to see your mobile device location information in any form, including without limitation through posting your photos, while using orinteracting with our services.

We typically collect the foregoing information through a variety oftechnologies, including use of third-party partners or services toassist with this effort. Information we collect automatically about youor your device may be combined with other personal information wecollect directly. For information about our and our third-partypartners’, please see our “Third-Party Tracking” further below

We or the third-party partners we use, may use the data collectedautomatically through mentioned technologies to: (a) rememberinformation so that you will not have to re-enter it during your visit orthe next time you visit the App; (b) provide custom, personalizedcontent and information; (c) provide and monitor the effectivenessof our services; (e) perform analytics and detect usage patterns onour services; (f) diagnose or fix technology problems; (g) detect orprevent fraud or other harmful activities, and (h) otherwise plan forand enhance our services and for other internal purposes.

1.3. Data From Other Sources:

  • Information We Receive from Third-Party Sites or Applications. Wemay receive personal information about you from third parties andcombine that with information we collect through the App or our otherservices. For example, we may obtain information when you loginthrough a third-party social network or authentication service, such asGoogle. These services will authenticate your identity and provide youthe option to share certain personal information with us, which couldinclude your name, email address, gender or other information. Thedata we receive from these third-party sites is dependent upon that thirdparty’s policies and your privacy settings on that third-party site. Prior tousing any such sign-in service, please review the privacy policies ofthese social media providers as they may have different policies andpractices than us. We do not assume any responsibility for the privacypractices, policies or actions of the operators of these social mediawebsites.
  • Information We Receive from Third Parties. From time to time, wemay collect information about you from third parties, such as analyticsproviders. We may also collect information about you that is publicly available. We may receive additional information about you, such asfraud detection information, from third-party partners and combine itwith other information that we have about you. We use this informationfrom third parties to create your User Accounts, to contact you, to sendyou promotional materials or to personalize our services, to protectagainst bot attacks and account takeovers, and to better understand thedemographics and interests of our users.

2. How We Use Your Information

As explained below, we use your information to fulfill and enforceour Terms of Service, to improve and administer our services, andto allow you to use its functionalities. We may also use yourinformation to, among other things, show you suggestions, promoteour services and third-party offerings, and customize yourexperience. We will use your information to:

2.1 Provide Services to You.

We use your personal information to create your User Account,enable you to use the App and our services, as well as to provideyou a support in using the App and our services.

2.2 Maintain and Improve Our Services.

We may use your personal information to provide, maintain,improve and develop the App and our services. For example, wemay use information about how users of our App search for and findspecific products to better understand the best ways to organizeand present the content that we offer. Specifically, we may use yourpersonal information in order to (i) provide our services to you,including, without limitation, sending receipts, and tracking andnotifying you of payment information; (ii) providing custom and personalized content and information; (iii) to perform analytics,detect activity patterns and otherwise research usage; and (iv) totest and develop new features and functionality and otherwiseenhance the App and our services.

2.3 Maintain the Safety, Stability and Securityof Our Services and the App.

We may use your personal information to investigate and remedyfraudulent or allegedly fraudulent activity as well as diagnose or fixtechnology problems.

2.4 Communications with You to ProvideSupport and Other Important Messages andNotifications.\

We may use personal information to communicate importantmessages and notifications to you and/or to provide you withsupport and use your data to manage our relationship with you andto improve our services and enhance your experience with us.

2.5 For Promotion Purposes.

We may promote third party products or services that we believemight interest you. Please note that, if you choose to purchaseproducts or services promoted by us, you may be a customer ofboth us and third parties developing and producing such productsor services and that we may share certain information with suchthird parties in order to fulfil your order and enforce such contract.

2.6 Legal and Regulatory Requirements andProceedings.

We may use the personal information in connection with legalproceedings and requirements. For example, we may need thepersonal information to enforce our corporate reporting obligationsand our Terms of Service, or to comply with applicable laws.

2.7 Enforce Our Rights.

We may use your personal information to ensure you comply withour Terms of Service and this Privacy Policy and use your personalinformation to monitor, investigate, prevent and/or mitigateviolations of these legal provisions, as well as enforce ouragreements with third parties and business partners.

2.8 Other Purposes Disclosed at the Time ofCollection.

From time to time, we may use personal information for a specificpurpose not contemplated by this Privacy Policy. In such an event,we will specifically disclose that use to you.

3. Sharing of Your Information

We may share your personal information in the instances describedbelow. We encourage you to repeatedly check this part of ourPrivacy Policy in order to be informed with whom we share yourpersonal information.

We May Share Your Personal InformationWith:

  • Reputeo's Subcontractors. Reputeo, together with itssubcontractors, helps us to develop, run and improve the App and otherservices, while we are providing you with our services and providingyou with the App offerings. If you chose to use the App and provide yourconsent to obtain personal information as contemplated in this PrivacyPolicy while opening the User Account and/or using the App, pleasenote that we may share some of your information with Reputeo’s subcontractors. However, in such case Reputeo shall be onlyallowed to use your information in order to obtain aggregated data (e.g.improving the App features, purchasing habits of certain age andgender groups, etc.) and we shall not share any of your information thatmay as the end-product uniquely identify you or any other user of theApp. Further, such information may be further disclosed by Reputeo to its subcontractors on the basis of our legitimate interest to fulfil theirobligations towards us. For more information, please contact usfollowing the instructions in the “Contact Us” section.
  • Third Parties at Your Direction or Request. In certain cases you mayalso elect to share your personal information with third persons. Pleasebe aware that some or all of your information shared in such mannermay be publicly available and used by third persons. We do not takeany responsibility for actions and omissions of such third persons.
  • Business Partners. We may share information with our businesspartners in order to help run the App offerings in a smooth andundisturbed manner and help you provide better user experience. Suchdisclosure may include third parties like customer service providers,advertising and marketing partners, email service providers, textingservice providers, cloud storage providers, storage providers, our andtheir subcontractors. However, we shall not share any of yourinformation that may as the end-product uniquely identify you or anyother user of the App.
  • Payment Providers. In case that we use third parties in processingyour payment, payment providers may request us to provide certainpersonal information in order to help cultivate the payment and facilitatethe payment.
  • Service Providers and Contractors. We use third parties that performservices on our behalf as needed to carry out their obligations to us.Our service providers may have access to personal information asneeded to provide data analysis, infrastructure provisioning, IT services, customer services, email delivery services, promotional, marketing andother similar services. However, we shall not share any of yourinformation that may as the end-product uniquely identify you or anyother user of the App.
  • Analytics Providers. We work with third-party analytics providers tobetter understand the demographics of our users, and to personalize,enhance and improve the App and our services.
  • Social Media. We may use social media plugins on our services (e.g. a“share” or “like” button), and your use of these plug-ins, may result inthe disclosure of certain of your information to the social media platformin question, and possibly presented on your social media profile, to beshared with others in your network – however, we will only share yourinformation with these social media platforms if you have provided yourexpress consent for us to do so.
  • Business Transaction or Reorganization. We may disclose yourinformation to third parties: (i) in the event that we sell or buy anybusiness or assets (for example, as a result of liquidation, bankruptcy orotherwise). In such transactions, we may disclose your data to theprospective seller or buyer of such business or assets; or (ii) if we sell,buy, merge, are acquired by, or partner with other companies orbusinesses, or sell some or all of our assets. In such transactions, userinformation may be among the transferred assets.
  • Legal Obligations and Rights. We may disclose personal informationto third parties, such as legal advisors and law enforcement, asrequired by law or subpoena or if we reasonably believe that suchaction is necessary to: (a) comply with the law and the reasonablerequests of law enforcement; (b) enforce our Terms of Service or toprotect the security or integrity of our services and the App; (c) detect,suppress or prevent fraud or reduce credit risk and collect debts owedto us; and/or (d) exercise or protect the rights, property, or personalsafety of us.
  • Public. We may make available through the App and our servicescertain features which may enable you to post information andmaterials, for example, comments, ratings and reviews. Please notethat any information you provide in connection with such services maybe available to the general public. Please do not disclose your personalinformation in these public or interactive areas, and we urge you toexercise discretion and caution when deciding to disclose any otherinformation and/or materials in these public or interactive areas on ourservices or the App.
  • Consent. Where not provided herein, we may disclose personalinformation about you to other third parties with your consent.

We may also use aggregate personal information for regulatorycompliance, industry and market analysis, research, demographicprofiling, marketing and advertising, and other business purposesas long as the end-product does not uniquely identify you or anyother user of the App and/or our services.

4. Control Over Your Information

Profile and Data Sharing Settings. You may update your profileinformation in your User Account settings.

How to Control Your Communications Preferences: You canstop receiving promotional email communications that we send byclicking the “unsubscribe link” provided in such communications.This unsubscribe action applies only to promotional emailcommunications that we send. You may not opt out of servicerelated communications (e.g., verification, transactionalcommunications, changes/updates to features of the App and/or ourservices, technical and security notices).

Modifying or Deactivating Your Information: If you would like toreview, modify, or deactivate your User Account, you can go to the“Account” tab or similar tab within the App. We may not be able tomodify or deactivate your information in all circumstances.

5. Third-Party Tracking

  • Google Analytics. We use Google Analytics to recognize you and linkthe devices you use when you visit or use the App, login to your UserAccount on our services or the App, or otherwise engage with us. Weshare a unique identifier, like a user ID or hashed email address, withGoogle to facilitate the service. Google Analytics allows us to betterunderstand how the users interact with our services or the App and totailor our content to you. You should learn on how Google Analytics collects and processes data, as well as how you can control informationsent to Google, review Google's site. You should also learn aboutGoogle Analytics’ currently available opt-outs, including the GoogleAnalytics Browser Ad-On.

6. How We Store and Protect YourInformation

Data Storage and Transfer. Your information collected through ourservices and the App is stored and processed in [insert country]. Ifyou are located in other regions with laws governing data collectionand use that may differ from the law of mentioned country whereservers are located, please note that we may transfer information,including personal information, to a country and jurisdiction thatdoes not have the same data protection laws as your jurisdiction.

Keeping Your Information Safe. We care about the security ofyour information and employ physical, administrative, andtechnological safeguards designed to preserve the integrity andsecurity of all information collected through our services. However,no security system is impenetrable and we cannot guarantee thesecurity of our systems. Please recognize that protecting yourpersonal information is also your responsibility. Accordingly, westrongly recommend that you choose unique passwords that are notreused across other App or websites, and otherwise takeprecautions when communicating your personal information on theinternet. If you know or have reason to believe that your UserAccount credentials have been lost, stolen, misappropriated, orotherwise compromised or in case of any actual or suspectedunauthorized use of your User Account, please contact us followingthe instructions in the “Contact Us” section below.

7. Children’s Privacy

Our services are not directed to children under the age of [18]; nordo we knowingly attempt to collect or solicit personal informationfrom children under the age of [18]. In the event that we areinformed that we have inadvertently collected personal informationfrom a child under age [18], we will disable our services and deletethe provided information as quickly as possible. If you believe thatwe have any information from a child under mentioned age, pleasecontact us following the instructions in the “Contact Us” sectionbelow.

8. Changes to Our Privacy Policy

We will update this Privacy Policy from time to time. When we makechanges to this Privacy Policy, we will change the "Effective" date atthe beginning of this Privacy Policy. If we make material changes tothis Privacy Policy, we will notify you by email to your registeredemail address or through other appropriate communicationchannels. All changes shall be effective from the Effective Dateunless otherwise provided. If you do not object before the date thewhen revised Privacy Policy becomes effective, your continuedaccess to or use of the App and/or services or you otherwiseengaging us will be subject to the revised Privacy Policy.

9. How to Contact Us

If you have any questions or requests in connection with thisPrivacy Policy or other privacy-related matters, please send an email to


Reputeo respects your rights to privacy: it is important that youhave control over your personal information. In that sense, we areacting in accordance with Serbian Law which is compliant withGeneral Data Protection Regulation (”GDPR”). Therefore, we wouldlike to make you aware of your rights, as further elaborated below.

Who is responsible for processing your personalinformation? We are acting as a “data controller” for all thepersonal information obtained on you, in sense of Serbian law andthe GDPR. Reputeo is acting as a “data collector” and “dataprocessor” for such personal information.

What Personal Information do we collect (including byautomated means)? Personal information that we are collectingare presented in Section 1 above.

Why and how do we use your Personal Information? We useyour personal information, including the reasons for their use, inaccordance with the Sections 2-4 above.

How do we protect and manage your Personal Information(including international transfers)? Your personal information isoriginally stored in [insert country] as of the moment you havestarted engaging with us, based on your consent to apply thisPrivacy Policy. We generally do not transfer your data outside thecountry where they are stored, however where we transfer yourpersonal data to countries outside the Serbia, EEA, United Kingdomor Switzerland we also require all third party data recipients toprocess your information in a secure manner and in accordancewith the GDPR (e.g. through the signing of the EU standardcontractual clauses). If you have further questions about this orwould like to request to view copies of the applicable safeguards(where required), please contact us at the contact details providedin Section 9.

What are the retention periods? We retain your personalinformation for as long as it is necessary for your use of ourservices and exercise our rights in relation to the information involved. Where we do not need your information in order to providethe service to you, we retain it only as long as we have a legitimatebusiness purpose in keeping such data or where we are subject toa legal obligation to retain the data. That basically means, that wemay still retain a limited portion of your personal information so thatwe can maintain a continuous relationship with you if and when weare in contact with you again, and to comply with our internalprocesses and any regulatory obligations. We will also retain yourdata, if necessary, for legal claims. When we no longer need yourpersonal data, we will securely delete or destroy it.

Who do we share your Personal Information with? We shareyour information in accordance with the Section 3 above.


  • ACCESS YOUR DATA: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.
  • DELETE YOUR DATA: You can ask us to delete all or some of yourpersonal data.
  • CHANGE OR CORRECT DATA: You can ask us to change or fix yourdata.
  • PORTABILITY: You can ask for a copy of personal data you provided ina machine readable form. This enables you to take your data from us inan electronically useable format and to be able to transfer your data toanother party in an electronically useable format; and
  • OBJECT TO PROCESSING OF YOUR PERSONALINFORMATION: You can use this right where we are relying on alegitimate interest (or those of a third party) and there is somethingabout your particular situation which makes you want to object toprocessing on this ground. You also have the right to object where weare processing your personal information for direct marketing purposes;
  • OBJECT TO AUTOMATED DECISION-MAKING INCLUDINGPROFILING. You can use this right where that is not to be subject ofany automated decision-making by us using your personal informationor profiling of you;
  • REQUEST THE RESTRICTION OF PROCESSING OF YOURPERSONAL INFORMATION. This enables you to ask us to suspendthe processing of personal information about you, for example if youwant us to establish its accuracy or the reason for processing it;
  • OBJECT OR RESTRICT USE OF DATA AND WITHDRAWCONSENT: Besides your above mentioned rights, you can ask us tostop using some or all of your data, e.g. if we have no legal right tokeep using it. You can ask us to stop processing your personal data fordirect marketing purposes. If you object to such processing, we ask youto share the reason for your objection in order for us to examine theprocessing of your personal data and to balance our legitimate interestin processing and your objection to this processing.

Before we can respond to a request to exercise one or more of therights listed above, you may be required to verify your identity oryour account details. Please note that we may charge a small fee inorder to cover the costs of processing your requests.

For information about how to make these requests, you can contactus using the contact information provided in Section 9, and we willreview your request while considering applicable laws.

Updates to this part of the Privacy Policy. We will update thispart of the Privacy Policy from time to time. When we makechanges to this part of the Privacy Policy, we will change theeffective date at the beginning of this notice. All changes shall beeffective from the effective date unless otherwise provided in thenotification. If you do not object before the date the revised noticebecomes effective, you will be subject to the such revised notice.

How to contact us? You can contact as per contact detailsprovided in the Section 9 above.

11. Governing Law

By choosing to apply this Privacy Policy, you agree that any disputeover privacy or the terms contained in this Privacy Policy will begoverned by the law of Republic of Serbia, without reference to thechoice of law or conflicts of law principles thereof, and will besubject to the dispute resolution clause contained in the Terms ofService which is incorporated herein by reference regardless of thefact whether Terms of Service apply to you or not.