1. Introduction

RECENT.COM, (hereinafter, the “Company”, “RECENT.COM”, “we”, “us”, “our”) is a legal entity incorporated under the laws of the State of DELAWARE. Our registered address is: 24A TROLLEY SQUARE #2166, WILMINGTON, DE 19806.

This Privacy Policy (the “Policy” or the “Privacy Policy”) explains how RECENT.COM collects, processes and discloses personal information through its website available at recent.com (the “Website”) and other online products and services that fall under this Policy (collectively, the “Services”) or when you otherwise interact with us.

RECENT.COM is responsible for the protection of the privacy and the safeguarding of the personal data of the following categories of data subjects:

1. our clients that sign up for the Services via the account registration link (the “Clients”); and
2. visitors on our Website; hereinafter, each separately or collectively referred to as “you” or “your”.

Your privacy is important to us. This Privacy Policy outlines how we collect, process, manage the personal data we collect from your use of our Services, through your interaction with us on social media or your other dealings with us.

Should you have any questions or concerns regarding your personal data, please contact us at: contact@recent.com. We have appointed a Data Protection Officer to assist us with compliance with applicable privacy regulations. To communicate with our DPO, please email to dataprotectionofficer@recent.com.

2. What kind of personal data do we collect?

• The Client’s account data includes first and last name, email address, password, company name, address (city, state/province, ZIP/postal code, country), secondary emails, phone number.
• Payment information includes bank information, crypto details, PayPal email.
• Tax information includes W9 US or W9 variant, or W8 non-US or W8 variant, or other.
• Client Usage data includes internet protocol (IP) address, browser user agent, activity (web pages visited), user account history/changes, storing all changes/account history, cookies for auth/sessions.
• Communication data includes name, email address, message/subject, our website user activity.
• The Visitors on Our Website Recent.com data includes internet protocol (IP) address, browser user agent, browser request headers/metadata, referring URL/site, user activity on the landing page (which ad clicked, what sort of ad/category the visitor has shown interest in), session cookies.

3. Purposes for which we use personal data

RECENT.COM, as a data controller, may only use your personal data if there is a lawful basis for such use. The most common lawful bases used by RECENT.COM are:

• consent: in some cases, we may process your personal data only if we obtain your prior consent;
• performance of a contract: we will require your personal data to be able to offer you the Services in accordance with the contract terms between you and us;
• compliance with a legal obligation: due to the nature of the Services we provide, the laws applicable to our activities require us to collect and store certain data about you; and
• legitimate interests: sometimes we rely on our legitimate interests to process your data (e.g., to improve our Services) and we will do so except where such interests are overridden by your interests or fundamental rights and freedoms.

Below you will find a table describing how we may use your personal data and which of the legal bases are used by the Company to ensure lawful data processing.

If you fail or refuse to provide your personal data we need to provide the Services to you or if the processing of personal data is necessary for compliance with our legal obligations, you will not be able to access the Services.

4. Cookies

We may use cookies for various purposes when you access or use the Services.

Third-party vendors, including Google, use cookies to serve ads based on your prior visits to our Website or other websites.

Google’s use of advertising cookies enables it and its partners to serve ads to you based on your visit to our sites and/or other sites on the Internet.

You can opt out of a third-party vendor’s use of cookies for personalized advertising by visiting aboutads.info.

5. Sources of personal data

Most of the personal data we process about you is received directly from you. For example, when you register to use the Services or communicate with us, we may receive your Client account data from you.

In other cases, we may receive personal data about you from various third parties and publicly accessible sources, including but not limited to banks, payment service providers, advertising networks, analytics providers, etc.

When you use the Services, we may also automatically collect Usage data through the use of cookies and similar technologies.

6. How do we protect your personal data?

We take all reasonable and appropriate technical and organisational measures to protect all personal data collected by us from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.

7. How long do we keep your personal data?

Generally, we will retain your personal data for as long as necessary to fulfil the specific purpose we collected it for, including the purpose of satisfying any legal, accounting, reporting requirements and our legitimate interests. For example, most of your data will be retained up to 3 years after the end of the business relationship with us. However, we may need to keep certain information (e.g., Payment and Tax information) for longer in order to comply with our legal obligations.

In certain cases, the authorities may require us to store the personal data longer if they deem necessary (e.g., in case of an ongoing investigation).

8. Your rights

With regards to our collection and processing of your personal data, you have the right to (subject to applicable exceptions):

1. Obtain confirmation from us as to whether we process your personal data.
2. Access your personal data processed by RECENT.COM.
3. Correct your personal data.
4. Withdraw consent and remove your personal data we collected on the basis of your consent (e.g., to opt out from marketing communications from us).
5. Obtain restriction of processing, for instance, where you contest the accuracy of your personal data for a period enabling us to verify the accuracy of the personal data.
6. Have your personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
7. Erasure of your personal data under certain circumstances. See more information about our data retention obligations in section “How long do we keep your personal data” above.
8. Object to our processing of your personal data when the processing is related to the performance of our task carried in the public interest or the exercise of official authority vested in us.

If you wish to make use of any of the above rights, please contact us stating your name and question related to any of the above rights at: contact@recent.com.

RECENT.COM will endeavour to provide you with information on the actions it has taken on your request related to your rights, specified above, within 1 (one) month of receipt of the request. That period may be extended by 2 (two) further months if the request is complex, or if RECENT.COM is in the process of resolving a large number of requests. We will inform you if any such extension is required within 1 (one) month of receipt of the request, together with the reasons for the delay.

9. California residents privacy rights

Pursuant to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act, this section applies to certain personal data collected about California individuals where RECENT.COM controls how and why the personal data is processed (which the CCPA calls a “business”) and supplements the rest of our Policy above.

The CCPA requires that we detail the categories of personal information that we disclose for certain “business purposes”, such as to service providers that assist us with securing our services or marketing our products, and to such other entities. We collect the personal information for the business and commercial purposes as described in the “Purposes for which we use personal data” section above. We share this information as described in the “How do we share your personal data?” section below.

We do not knowingly sell or share any personal data of minors under the age of 16. We do not collect or process “sensitive personal information”, as defined by the CCPA, to infer characteristics about you.

Subject to legal limitations, California residents may have the below rights:

• Right to Know. You have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting the personal data, the categories of third parties to whom we have disclosed your personal data, and the purpose for which we disclosed your personal data. You may also request information about the specific pieces of personal data we have collected about you.
• Right to Delete. You have the right to request that we delete personal data that we have collected from you.
• Right to Correct. You have the right to request that we correct inaccurate personal data that we maintain about you.
• Right to Opt Out of Sale or Sharing. We do not sell personal data to third parties in exchange for money. You may still email us using the information below to exercise your right to opt out of sale under applicable law. You may still email us using the information below to exercise your right to opt out of sale under applicable law. California residents may make a request pursuant to their rights under the CCPA by contacting us at: contact@recent.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. You can also designate an authorized agent to exercise these rights on your behalf. Authorized agents must submit proof of authorization.

10.Colorado, Connecticut, Utah, and Virginia residents privacy rights

The Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, and the Utah Consumer Privacy Act – each provide certain rights to residents of Colorado, Connecticut, Virginia, and Utah, respectively. This section applies to you if you are a natural person who is a resident of the States of Colorado, Connecticut, Utah or the Commonwealth of Virginia and use our Services (each and all of whom shall be referred to collectively, as the “Consumer”). This section supplements the information in the Privacy Policy. Certain terms used below have the meanings given to them in the respective laws.

11. Other Privacy Rights

In addition to your rights of access, correction, deletion and data portability, as described in the Privacy Policy, the Consumers may have certain additional rights in connection with the personal data we collect about you, many of which are subject to exceptions under applicable law:

• The right to non-discrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise your rights.
• The right to opt out of the sale and/or processing of your personal data. You have the right to opt out of the sale of your personal data to a third party and/or the processing of your personal data for the following purposes: (i) targeted advertising; and (ii) profiling. We do not sell your personal data as defined under applicable law. If you are a Colorado, Connecticut, Utah, or Virginia resident, you may nevertheless email us using the information below to exercise your right to opt out of sale under applicable law.

To submit a request under this section, contact us at: contact@recent.com. To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

12. How do we share your personal data?

We do not share your personal information with third parties, except as described in this Privacy Policy.

RECENT.COM may engage service providers and partners to assist with delivery of the Services:

Category Purpose Support/communication tools

• Email/messengers communication
• Internal communication and task management
• Incoming mail scan

Hosting providers

• Hosting of personal data

IT service providers

• IT outsourcing
• Monitoring and access to cloud services
• Storage/Backup

CRM

• Automation of customer support processes

Analytics

• Product analytics
• Marketing analytics and reporting

Payment service providers

• Payment processing
• Anti-fraud/risk check system
• Application logs for payment system

Ad service providers

• Ad monetization

In case your personal data is provided to service providers outside the EEA and where applicable, we will implement appropriate safeguards to protect your personal data, including Standard Contractual Clauses as adopted by the European Commission. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. Moreover, RECENT.COM requires its service providers to implement appropriate security measures to ensure the protection of your personal data in accordance with applicable data protection legislation.

In other cases, we may disclose your personal data:

• to the relevant government agencies and regulatory authorities when required by the applicable laws;
• with affiliates and subsidiaries within the RECENT.COM group, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they are made part of the RECENT.COM group;
• in the event of any merger, acquisition, sale or change of control or a similar transaction or proceeding;
• with professional advisors, such as lawyers, accountants, and auditors;
• if you have consented to the disclosure;
• to establish, exercise or defend legal claims.

13. Age limitations

RECENT.COM does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

14. Privacy Policy updates

RECENT.COM may update this Privacy Policy from time to time. In the event we materially change this Policy, including how we collect, process or use your personal information, active Clients will be notified as in accordance with the RECENT.COM General Terms of Service. Potential clients are notified by means of the publication of the updated Privacy Policy on our Website.

15. Contact information

If you have questions about this Privacy Policy or our privacy practices, or if you are seeking to exercise any of your rights, you may contact us at contact@recent.com. You can also reach out to our Data Protection officer by email: dataprotectionofficer@recent.com.

If you are a resident of the EEA, you have the right to lodge a complaint with the data protection supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

Last Updated July 7, 2023