Privacy statement

This statement explains which personal data Repmanager processes, why, for how long and with whom we share it. It covers the website www.repmanager.ai, the app app.repmanager.ai and our research into public reviews.

1. Who we are

Repmanager is a service of Dibbes Group B.V., Dynamostraat 44, 1014 BK Amsterdam, the Netherlands, Chamber of Commerce number 80407374. Dibbes Group B.V. is the controller for the processing described here. Send questions or requests to [email protected]. We have not appointed a data protection officer; we are not required to.

2. What data, for what purpose and on what legal basis

• Your account and use of the app. Name, email address, organisation, locations, your role in the team, login details and settings. Purpose: providing the service. Legal basis: performance of the contract.
• Payments and invoices. Company name, billing address, VAT number and payment details. Payments are handled by Stripe; we never see full card numbers. Legal basis: the contract and our legal retention obligation.
• Contact, demos and requests, such as a reputation scan or your position in the Reputation Index. What you fill in, usually name, email address, phone number and organisation. Purpose: handling and following up your request. Legal basis: your own request and our legitimate interest in responding to it.
• Online meetings. In online meetings, such as demos and customer calls, we may use Fireflies to record and transcribe the conversation, so we can follow up properly. Fireflies then joins visibly as a participant. Rather not be recorded? Tell us, also during the call, and we switch it off. Legal basis: legitimate interest.
• Email and newsletter. Your email address and how you interact with our emails, sent via Brevo. Legal basis: consent, or for existing customers our legitimate interest. You can unsubscribe at any time via the link in every email.
• Website visits. Which pages you view, your device and browser, and your IP address. If you accept cookies, also session recordings of your visit (Microsoft Clarity and Leadinfo) and, for Meta, encrypted details you enter in a form to link your visit to a Facebook or Instagram account. All tools and retention periods are in the cookie policy. Without cookies we only count visits anonymously, with Cloudflare Web Analytics. Legal basis: consent.
• Company recognition. If you accept cookies, Leadinfo recognises which company visits our site from the IP address of its network. We use this to approach companies that show interest. This concerns company data, not you as a person. Legal basis: consent.
• Security and server logs. IP address and technical data, to prevent abuse and find errors. Legal basis: legitimate interest.

3. Reviews and AI in the app

As a customer you connect your review sources in Repmanager, such as Google, Klantenvertellen and Kiyoh. We retrieve those reviews, including the name a reviewer chose to show and the review text. Your organisation is responsible for that data; we process it on your behalf to provide the service.

Repmanager uses an AI language model to draft replies to reviews. Those drafts are suggestions: you, or the rules you set, decide what gets posted. We make no decisions about people based solely on automated processing that have legal effects.

We use anonymised data, without names or anything else that identifies a person, to improve the product and the AI and for statistics, as described in our terms and conditions.

4. Research into public Google reviews

For market research, such as our automotive study and the Reputation Index, we collect public Google reviews of business locations, via the Apify service and the Google Places API. Purpose: aggregated figures on how companies handle reviews, such as response rate, response time and unanswered complaints.

• Legal basis: legitimate interest. We have assessed and documented this.
• We no longer collect reviewer names or profiles and have removed them from earlier sets. A review text may still contain a name, for example a signature.
• We only publish totals. Never reviewer names or quotes that can be traced back to a person.
• We do not profile or contact reviewers.
• We delete or anonymise the working files no later than 12 months after the research is published.
• Might your review be in our dataset and would you rather it wasn't? Email [email protected] and we will remove it within a month.

We do not inform reviewers one by one. That is impossible without collecting even more data, which is why this explanation is public.

5. Who we share data with

We do not sell data. We only share it with parties that help us provide the service, and we agree security and confidentiality terms with them.

• Hosting and infrastructure: Microsoft Azure (app and database), Webflow (website) and Cloudflare (security and network).
• Payments: Stripe.
• AI: a provider of AI language models for the draft replies.
• Review sources: Google (Business Profile), Klantenvertellen and Kiyoh, when you connect them.
• Email: Brevo.
• Meeting notes: Fireflies.
• Analytics and marketing, only with consent: Google (Analytics, Ads and Tag Manager), Microsoft Clarity, Meta, LinkedIn, Leadinfo and Promptwatch.
• Research: Apify and the Google Places API.
• Authorities or regulators when the law requires it.

6. Data outside the EU

Some of these parties are based or operate in the United States, such as Google, Microsoft, Meta, LinkedIn, Stripe, Webflow, Cloudflare and Fireflies. Transfers only take place under the EU-US Data Privacy Framework or the European Commission's standard contractual clauses.

7. How long we keep data

• Account and data in the app: as long as you are a customer. After cancellation we delete it within 30 days, as stated in our terms and conditions.
• Invoices and accounts: 7 years, because Dutch tax law requires it.
• Contact requests and leads: as long as needed to handle and follow up your request. If no collaboration follows, we clear them.
• Newsletter: until you unsubscribe.
• Cookies and website data: see the cookie policy.
• Research data: no later than 12 months after publication, see section 4.

8. Security

We protect data with measures including encrypted connections, role-based access and secure hosting. Only people who need it for their work have access. If we discover a data breach that puts you at risk, we report it to the Dutch Data Protection Authority and, where needed, to you.

9. Your rights

You can ask us to access, correct, delete or transfer your data, and to restrict processing. You can object to processing based on legitimate interest, and always to direct marketing. You can withdraw consent whenever you like; for cookies via the cookie policy.

Email your request to [email protected]. We respond within a month. To make sure it is really you, we may ask for extra information, but never for a copy of your passport. You can also file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

10. Children

Repmanager is a business service and not intended for children under 16. We do not knowingly process children's data.

11. Changes

If anything changes in how we process data, we update this statement and the date at the top. For major changes we also inform customers by email.

12. Contact

Dibbes Group B.V. (Repmanager)
Dynamostraat 44
1014 BK Amsterdam, the Netherlands
Chamber of Commerce 80407374
Email: [email protected]