Privacy Policy

Last Updated: May 30, 2024

Introduction

This Privacy Policy governs the collection, use, and disclosure of personal information by Babadan Labs, an LLC incorporated in Delaware ("Babadan Labs" or “Reletter" or “Company”) in connection with its services.

Reletter is a service fully owned and operated by Babadan Labs, LLC.

About Reletter

Reletter offers subscription access to an online database of newsletters, allowing users to connect with newsletters and access information about them. Users can become monthly or annual subscribers through Stripe.

Categories and Types of Information We Collect

During a visitor’s or user's use of the Service or through other communications with Reletter, Reletter may collect and process certain personal information. Users may affirmatively provide Reletter with certain personal information, including, without limitation:

Personal Identifiers (such as your name, email address, phone number, mailing address, email receipt, and open data), which, when used alone or with other relevant data, can identify an individual (“PII”)
Employment information (such as your employer or industry)
Billing information (such as your credit card number)
User content (such as personal information about yourself or messaging service content or user-generated content shared through the Services)
Geolocation Data
Internet or other electronic network or device activity information (e.g., search history, information on interactions with the website or applications)
Information from Other Sources: We may obtain supplementary information about you from third party sources, such as public databases, social media platforms, data partners, and our joint marketing partners.
Inferences: We may infer your approximate location, age, purchasing preferences, and other attributes from the data we collect.

Please note that some of this information may be provided by your employer to grant you access to the Service.

It's important to refrain from submitting sensitive data related to:

Racial or ethnic origin
Political beliefs
Philosophical or religious beliefs
Membership of a trade union or political party
Physical or mental health or genetic makeup
Addictions and sexual life
The commission of criminal offenses or proceedings and associated penalties or fines
Social Security Number or other national identifier

If We determine that a user has provided such sensitive data, it will be promptly deleted.

Reletter does not collect characteristics of protected classifications under applicable laws, biometric information, education information, or sensitive data as described above, except for account logins and encrypted passwords.

Sources of Personal Information

Reletter receives personal information from one or more of the following sources:

Information from You

Directly from you when you visit the Site, register an account, provide personal data, log in as a registered user, or submit your information in a form on the Site.
When you contact us with inquiries, respond to surveys, or contact our customer support.
Transaction, billing, financial, and identity verification information you provide in connection with your use of the Services.
Indirectly from you when you navigate and interact with the Site, and certain information is automatically collected by cookies and similar technologies. This information may include your computer and internet connection details, like IP address, operating system, and browser type.
Any other information voluntarily provided by you.

Information from Third Parties

Personal data may be obtained from resellers or affiliates if you purchase access to the Services through them. This personal data includes business contact information, mailing addresses, job titles, email addresses, and phone numbers.
Reletter may collect information from publicly accessible sites such as business directories and social media sites.
If you are a Newsletter Contact, Reletter obtains personal data about you from third parties for use within the Newsletter Database. This data is limited to information that is likely to enable customers to engage with you in a meaningful way. It includes name, publicly available contact details (such as email and telephone), position, industry, workplace, social media links, topic areas covered, and links to publications.

How Reletter Uses Collected Information

Reletter uses the information, including personal information, for various purposes, including:

Presenting the Service and facilitating subscription access to the newsletter database.
Enabling user participation in interactive features.
Providing information, products, or services upon request.
Managing our relationship with users and sending administrative information, such as website updates and policy changes.
Improving the Service, enhancing security, and delivering content relevant to user interests.
Analyzing trends and user interactions for a better user experience.
Operating and administering our websites.
Preventing fraud, ensuring IT system security, and complying with legal obligations.
Fulfilling any other stated purpose for which information is provided.

Reletter may aggregate, anonymize, and analyze user content for purposes such as improvements to the Services, internal research, performance analytics, machine learning, and product development. Aggregated and anonymized personal data may include approximate geographic position, IP address, web browser and version, mobile application version, and operating system information.

Reletter may use third-party services to track and analyze user behavior, with information disclosed to third parties in an aggregated, de-identified, and anonymized format to protect customer data.

If users have not opted out of receiving marketing communications, Reletter may use their email address, phone number, or other personal information for marketing messages. Users cannot opt out of non-marketing or administrative communications without discontinuing their use of the Service.

Third-Party Services

This Privacy Policy does not address the privacy or information practices of third parties, including those operating websites or services linked to the Services. Reletter is not responsible for the information collection, use, disclosure, or security policies of other organizations, app developers, app providers, open-source software, social media platform providers, operating system providers, wireless service providers, or device manufacturers.

Cookies and Similar Technologies

By using the Service, Reletter may collect certain non-personal information through the following means:

Information Collected by "Cookies"

When accessing the Service, Reletter may send one or more "cookies" to your computer, which are used for various purposes, including saving passwords and delivering content specific to user interests. You may manage or disable cookies through your browser settings.

Log File Information

Reletter's servers automatically record information sent by your browser when you access the Service. This information may include web requests, IP addresses, browser types, and more. For additional information on cookies and log file information, contact [email protected].

How We Share Your information

Reletter may provide personal information to employees, consultants, affiliates, or other entities for processing on our behalf. These third parties include providers of payment processing, fraud prevention, risk assessment, hosting, IT services, email communications, customer support, analytics, marketing, and advertising. These parties are required to protect the confidentiality of such information and comply with this Privacy Policy.

In the event of a merger, acquisition, financing, bankruptcy, sale of assets, or service transition, personal data may be transferred to a successor or affiliate as part of that transaction.

Reletter will disclose personal data to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

User Choice and Access

Reletter offers users choices about how it collects, uses, and shares personal information.

Users may opt-out of the following:

Email Communications: Users can opt-out of email marketing communications by clicking the "unsubscribe" link at the bottom of marketing emails. Reletter will continue to send non-promotional, transactional, and service-related communications.
Sharing of Personal Information with Third Parties: Users can request that Reletter not share their personal information with third parties for marketing purposes. To make this request, contact[email protected].
Cookies and Tracking Technologies: Most browsers let users remove or manage cookies and other tracking technologies. To manage cookies, please refer to your browser's settings.
Other Choices: Users can adjust user-specific information, like email subscriptions, in the "Settings" section of their account. To make additional privacy-related requests or for any questions, please contact Reletter at [email protected].

Data Security

Reletter follows industry-standard practices to secure personal information and prevent unauthorized access or disclosure. Relettersecures the personal information on computer servers in a controlled and secure environment.

It's important to note that no data transmission over the internet or method of electronic storage is 100% secure. As such, while Reletter strives to protect personal information, Reletter cannot, and does not, guarantee its security. Users acknowledge this risk when using the Service.

Data Retention

Reletter retains your personal information for as long as necessary to provide the services, fulfill the purposes described in this Privacy Policy, or as required by applicable law and regulations. We will then either delete your information or de-identify it so that it is anonymous and no longer attributed to your identity.

In general, Reletter retains your personal information for as long as your account is active or as needed to provide Services to you. Reletter also retains information from deleted accounts to comply with the law, prevent fraud, collect fees owed, resolve disputes, assist with investigations, enforce our Terms of Service, and take other actions permitted by law.

The specific retention periods vary depending on the type of information collected and how it is used, but some typical retention periods are:

Account information: Retained while your account is active and a reasonable period thereafter in case you decide to re-activate our Services.
Marketing information: Retained for a reasonable period from when it was last updated by you, unless you opt-out from receiving marketing communications, in which case it will be deleted promptly.
Transaction and purchase history: Retained for a period reasonably necessary for accounting, tax reporting, auditing, billing, reconciliation and other related purposes.
Usage, web activity, and analytics information: Retained for a reasonable period to analyze activity trends, estimate audience size, improve the Services, and for other research, statistical and business purposes.
Location information: Retained only as long as necessary to provide a Service you requested.
Legally mandated information: Retained for the period required by applicable law.
Job applicant information: Retained for the duration of the application process and a reasonable period thereafter.

We may retain de-identified or aggregated information for longer periods without expiry for research, analytics and business intelligence purposes. If you request deletion of your account, we will retain only the minimum information necessary to prevent fraud and abuse of our Services.

Your Rights and Control Over Your Personal Data

Reletter respects user data rights, including the right to access, correct, or delete personal information. If you are a user of the Services, you may access, review, modify and delete your account profile within the Services by going to your account and editing your information. For all other requests to access, review, modify, update, delete, or limit the use or disclosure of the personal data we hold about you, and to see or amend your Media Database profile, you must email your request to us at [email protected].

EU Data Privacy Rights

If you are a resident or are otherwise located in the European Union ("EU") or the United Kingdom ("UK"), this section provides additional details about the personal data we collect about you, and your rights granted by the EU and UK General Data Protection Regulations, as applicable (“GDPR”).

Subject to certain limitations, the GDPR provides you the following privacy rights:

Transparency and the right to information. Through this Privacy Policy we explain how we use and share your personal information. However, if you have questions or concerns you can contact us at [email protected].

Right of access, restriction of processing, correction, erasure, and portability (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You can make a request to access, object, restrict, correct, erase, or transfer any of your personal information by emailing [email protected]. You also have the right to withdraw your consent when we process your personal information based on your consent.

Right to Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Right to opt-out from direct marketing. You have the right to opt-out from receiving marketing materials from us by following the opt-out instructions in our commercial emails, by contacting us, or by adjusting your preferences under your profile details on the Site.

Right not to be subject to an automated decision, including profiling. We do not make automated decisions using your personal data that may negatively impact you. We use cookies and similar technologies on the Site to personalize your experience on the Site and recommend software products and services that may be of interest to you.

Right to lodge a complaint with a supervisory authority. If you consider that the processing of your personal information infringes your GDPR privacy rights, you have the right to lodge a complaint with a supervisory authority, in the member state of your habitual residence, place of work, or place of the alleged infringement. Contact details for the EU data protection authorities can be found here . For users located in the UK, you can contact the Information Commissioner’s Office (ICO). Contact details for the ICO can be found here.

We will retain your data for the length of time you engage with the Services until you request deletion, in writing, of such personal information. We will take reasonable steps to permit individuals to correct, amend, delete, restrict processing of, and request portability of the personal information we hold about you. We also rely upon you to assist in providing accurate updates of your personal information.

If you would like to submit a request to us to exercise your EU or UK privacy rights under the GDPR, you may do so either by submitting a request by emailing [email protected] with your request.

Legal Basis for Processing (EEA, Switzerland and United Kingdom only)

Our legal basis for collecting and using your personal information will depend on the type of information and the context in which we collect it. However, we will normally collect personal information from you only in the following circumstances:

We have your express consent to do so;
We need the personal data to perform a contract with you; or
Processing is in our legitimate interests and is not overridden by your data protection interests or fundamental rights and freedoms.

In some cases, we may also have a legal obligation to collect personal information from you to protect your vital interests or those of another person (for example, to prevent, investigate or identify possible wrongdoing in connection with the Site or to comply with legal obligations).

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will identify such a basis for processing at the relevant time and let you know if the provision of your personal information is mandatory or not (as well as the possible consequences associated with not providing such information).

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate the Site, communicate with you in relation to your account or the Site, to measure interest in and improve our offerings and Site, to engage in marketing activities, and to otherwise customize your experience with us.

California Privacy Rights

If you are a resident of California, the California Consumer Privacy Act notice applies to you and supplements our Privacy Policy. This notice is intended to provide certain information to you as required by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

This notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, other similar identifiers (“Personal Information”) or Social Security number (SSN), driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account (“Sensitive Personal Information”).

Personal information does not include publicly-available information, de-identified or aggregated consumer information and certain other information that is regulated by other applicable laws.

Subject to some limitations and exceptions you have the following rights:

That we provide you access to details on the categories or specific pieces of personal information we collect (including how we use and disclose this information);
That we delete any of your personal information;
That we correct any inaccuracies in your personal information;
That we provide the business or commercial purpose for collecting your personal information.
If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
That we allow you to opt out of any “sale” or "sharing" of your personal information that may occur, including sensitive personal information; and
If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold.
To not be discriminated against for exercising any of the above rights.

Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions.

After we receive your verified request we will provide you with the following in accordance with the time period allowed under the applicable law:

The categories of personal information we have collected from you
The categories of personal information we have shared about you and the categories of third parties to whom we shared such information, by category or categories of personal information for each category of third parties to whom the personal information was shared; and
The categories of personal information that we disclosed about you for a business purpose.

We do not collect sensitive personal information other than account login and password from our users.

You may submit a request regarding your rights under CCPA/CPRA by sending an email to [email protected].

If we receive a CCPA or CPRA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. We will verify your request using information associated with your account, including your email. Further identification may be required. You may also designate an authorized agent to act on your behalf.

Please note that we may retain a record of your request to delete your personal information.

Virginia Privacy Rights

If you are a resident of Virginia, this section provides information about your privacy rights under the Virginia Consumer Data Protection Act ("VCDPA").

Subject to certain limitations, the VCDPA affords you the following rights:

To confirm whether we are processing your personal information, and to access that personal information;
To receive your personal information in a portable and readily usable format;
To correct inaccuracies in your personal information;
To delete your personal information;
To opt out of the processing of your personal information for targeted advertising, sale to third parties, or profiling where there is a legal or similarly significant effect on you.

Please note that we do not collect sensitive personal information as defined by VCDPA.

Nevada Privacy Rights

If you are a resident of Nevada, this section provides information about your privacy rights under the Nevada Privacy Law.

The Nevada Privacy Law affords you certain rights regarding your personal information:

To confirm whether we are processing your personal information.
To opt out of the sale of your personal information, if applicable.

Please note that the Nevada Privacy Law does not provide the right to access, correct, or delete personal information to the same extent as some other privacy laws. The scope of rights under this law may vary based on its specific provisions.

Colorado Privacy Rights

If you are a resident of Colorado, this section provides information about your privacy rights under the Colorado Privacy Act (CPA).

Subject to certain limitations and exceptions, the Colorado Privacy Act affords you the following rights:

To confirm whether we are processing your personal information, and to access that personal information.
To receive your personal information in a portable and readily usable format.
To correct inaccuracies in your personal information.
To delete your personal information.
To opt out of the processing of your personal information for targeted advertising, sale to third parties, or profiling where there is a legal or similarly significant effect on you.

Please note that the CPA provides similar rights to the CCPA, with some variations and nuances, so the scope and processes for these rights may differ.

To exercise any of these rights or for questions regarding this Privacy Policy, please contact us at [email protected]. If you make a request, we have one month to respond to you.

You also have the right to lodge a complaint with your local data protection authority or privacy regulator if you believe we have violated any applicable data protection laws. We encourage you to contact us first to resolve any complaints or disputes directly.

Children's Privacy

The Service is not directed to individuals under the age of 18, and Reletter does not knowingly collect personal information from anyone under 18. If Reletter becomes aware that a child under 18 has provided personal information, Reletter will delete such information.

International Data Transfer

If you are located outside the United States, in particular if you are located in Switzerland or the European Union (EU), please note that Reletter is a US based company. If you use the Service, all information, including personal information, will be transferred to Reletter (including third parties to which data was disclosed as described above) in the United States and any information made public via our website may be viewed by individuals located anywhere in the world. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal information than in your country, we will protect your information in accordance with requirements applicable to the law in your particular jurisdiction. By using the Service, you unambiguously consent to the transfer of your personal information and other information to the United States and elsewhere for the purposes and uses described herein.

Changes to this Privacy Policy

Reletter reserves the right to update or change this Privacy Policy at any time. Users are encouraged to review this Privacy Policy regularly for any changes. The effective date of this Privacy Policy is set forth at the beginning of this document.

Contact Information

Reletter welcomes your comments or questions regarding this Privacy Policy. Please contact us at: [email protected]

Third-Party rights

No third-party beneficiaries are intended. This Privacy Policy is solely for the benefit of you and Reletter.