Privacy Notice

Simple navigation and consultation of the website do not generally involve the gathering of users personal data and only relate to the processing in anonymous form of so-called navigation data.

This Notice applies to the processing of Personal Data collected by us when you:

1. Use our Services
2. Visit our websites
3. Visit our Offices
4. Receive communications from us
5. Register for, attend or take part in events, webinars or contests

1. International Compliance

This Privacy Notice is primarily based on the requirements of the EU General Data Protection Regulation (GDPR). However, we aim to offer a comparable level of transparency and protection to all users, regardless of their place of residence.

• For residents of California (USA), additional rights under the California Consumer Privacy Act (CCPA/CPRA) are described in the section “California Residents”.
• For users in the United Kingdom, data is processed in accordance with the UK GDPR and the Data Protection Act 2018.
• For users located outside these regions, we process Personal Data in accordance with this Privacy Notice and apply safeguards consistent with internationally recognised privacy standards.

By offering a global framework, we ensure a high and uniform level of data protection for all users.

2. Definitions

Representative24: means brand/services operated by Onpipeline Limited.

Services: means our software-as-a-service platform and related features, websites, dashboards, APIs, integrations, communications, events and support that we provide to Clients and Users at representative24.com.

We/Us/Our: means “Onpipeline Limited” and its affiliates. 

Client/Customer: means the business entity (company, organization, sole proprietor) that contracts with us to use the Services. For Client-entered data, the Client acts as the data controller (or “business” under CCPA/CPRA).

End User: means any individual who interacts with a Client’s channels (e.g., websites, apps, messaging interfaces) where our Services are implemented.

User: means any individual who visits our websites, uses our Services, attends our events, or otherwise communicates with us (including Client personnel and prospects).

Personal Data/Personal Information (PII): means any information relating to an identified or identifiable natural person, as defined under applicable law (e.g., GDPR, UK GDPR, CCPA/CPRA). This may include identifiers (e.g., name, email), online identifiers (e.g., IP address, device ID), and other information reasonably linked to an individual.

Processing: means any operation performed on Personal Data, such as collection, recording, organisation, storage, adaptation, retrieval, use, disclosure or deletion.

Controller/Processor: have the meanings set out in the GDPR. The Controller determines the purposes and means of processing Personal Data; the Processor processes Personal Data on the Controller’s behalf and under documented instructions.

3. Data controlled and processed by us

Personal data we control includes information relating to identified or identifiable natural persons, for example first and last names, postal address, e-mail address and telephone number.

3.1 Purposes of processing

We process personal data for the following purposes:

• Performance of contractual obligations and management of business relationships with Clients
• Administrative purposes and compliance with legal obligations
• Sending service or transactional communications related to the Services
• Sending marketing communications (e.g., newsletters, product updates) with Users’ consent
• Processing curriculum vitae (CVs) exclusively for recruitment and selection purposes

3.2 Legal Basis for processing

Depending on the context, we process personal data on one or more of the following legal bases:

• Performance of a contract: to provide the Services and manage accounts/support
• Compliance with legal obligations: e.g., accounting, tax, lawful requests
• Legitimate interests: to improve and secure the Services, prevent misuse/fraud, and defend legal claims, without overriding Users’ rights and freedoms
• Consent: where required by law (e.g., newsletters/marketing) 

3.3 Methods of processing & Data Accuracy

Processing for the aforementioned purposes occurs manually or electronically, depending on the purposes for which the data are communicated. The User must provide personal data which are true and accurate and up-to-date for purposes of creating and managing the contractual relationship with us and of utilising the Service.

3.4 Data Retention

Data shall be stored for a term that is strictly necessary for the management of the purposes for which the data was collected, in compliance with the law in force and the legal obligations. In any case, we have enacted practices that prohibit the storage of data for an indeterminate term and therefore limit the storage term in compliance with the principle of minimising data processing.

3.5 Data Sharing and Recipients

Data-gathering will also be with a view to transferring the data to associated companies, subsidiaries, or companies carrying out functions closely connected with and instrumental to the Service we provide.

Collected data, if necessary or fundamental to execute the indicated purposes, may be used by external third-party Processors, or depending on the case, disclosed to the same independent controllers and more specifically: The companies belonging to our corporate group, individuals, companies, associations or groups of professionals that provide assistance and advice to our Company, entities or associations that provide services connected and instrumental to carrying out the above-mentioned purposes.

Personal data is not publicly disseminated. Any sharing occurs only as described above and in accordance with applicable law and contractual safeguards.

4. Data collected and entered by Clients

Representative24 Clients (Customers) may store or upload into our application 3rd party data. Representative24 has no direct relationship with individuals, companies and organizations whose data it hosted. Clients are responsible for the manner in which they collect, distribute and process such information.

Each Client is responsible for providing a notice to third parties concerning the purpose for which their Personal Data is collected and how this Personal Data is processed through our application.
Representative24 does not know the use of personal information contained within its Clients Data, is not acting as data controller and does not have the responsibilities under the GDPR. Representative24 shall be considered only as a “processor” on behalf of its Clients.

5. Integrated Services

Our Clients have the option to integrate certain services provided by third parties (i.e. calendars provided by Google, Microsoft, etc.). By authorizing us to connect with a third party, Clients authorize us to access and store information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. We consider data from integrated services as “data collected and entered by Clients”. Please refer to privacy settings and terms of use of each Integrated Service to understand what information they make available to us.

Some features of our Services rely on artificial intelligence (AI) technologies provided by third-party vendors (such as language models or data classification tools). You acknowledge and agree that the information you submit may be processed by such AI services to generate responses, insights, or other automated outputs. While we strive to partner only with reputable providers that comply with industry-standard data protection practices, we do not control how third-party AI vendors process, store, or use the submitted data.

Data processed through AI features is treated as “Client-entered data” under our policies, but may be subject to the privacy terms of the specific AI provider. We recommend reviewing the terms and privacy policies of any third-party AI technologies integrated into the Services for further detail:

• ChatGPT (OpenAI) https://openai.com/policies/row-privacy-policy/
• Gemini (Google) https://gemini.google/policy-guidelines/
• Claude (Anthropic) https://www.anthropic.com/legal/privacy

6. Data processors

We may rely on external service providers for activities such as hosting, development, security, communications, analytics and system maintenance. These third parties may process personal data solely on our behalf and under our documented instructions. We always limit the information provided to what is reasonably necessary, and our agreements require them to maintain confidentiality and comply with data protection obligations.

If applicable, data transfers outside the European Economic Area are carried out in compliance with Chapter V of the GDPR and based on appropriate safeguards (such as Standard Contractual Clauses).

A detailed list of our current processors and sub-processors is available to customers, contractual partners or supervisory authorities upon legitimate request.

7. Rights of the User

It is possible to access, object to the processing or request the erasure, the modification or the updating of all the personal data collected by us, at any time, by exercising the right to limit the data processing and the movement of data, by sending an email to: privacy@onpipeline.com

8. Security

Representative24 undertakes to maintain the security of all data gathered using technical and organisational tools. The safety measures are aimed at reducing to the minimum the risk of destruction or loss of data and the risk of unauthorised access, and they include the possibility of limiting access to the data to authorised Representative24 personnel alone. Representative24 employees acknowledge that they are bound by standards of data security and data confidentiality.

9. California Residents (CCPA/CPRA)

The rights described in the section “Rights of the User” apply to all users, including California residents. In accordance with the California Consumer Privacy Act (CCPA),  California residents have the right to:

• request information about whether their Personal Information has been shared;
• opt out of any sale or sharing of Personal Information, if applicable;
• be free from discrimination for exercising their privacy rights.

We do not sell or share Personal Information for monetary or commercial purposes as defined under the CCPA/CPRA. California residents may exercise their rights using the same contact details and procedures indicated in the “Rights of the User” section. We may need to verify the requester’s identity before responding, in accordance with the CCPA.

10. Children’s Privacy

Our Services are not directed to minors, and we do not knowingly collect or process personal sata from children. In providing our services, we act as a data processor on behalf of our Clients (data controllers) and do not have the ability to verify the age of end users. Each Client is responsible for ensuring compliance with applicable laws regarding minors, including obtaining any required parental consent. If you believe that a minor has submitted personal data through our services, please contact us immediately.

11. Cancellation of data

All data is held only for a period of time strictly necessary for the purposes for which the data was gathered. Without prejudice to the right to immediately block the use of data for commercial and marketing purposes, it may prove necessary to hold the data for a further period of time for purposes of satisfying legal provisions or for accounting and administrative purposes.

12. Cookies

Cookies are fragments of text sent by a server to a client (browser) and then sent back by the client to the server whenever the client accesses the same server.

Data obtained from cookies are utilised by Representative24 itself or by companies that collaborate with us in order to ensure simpler access to the Service.

When you access our website, we use only technical and statistical cookies to collect aggregated information about site usage, such as pages visited, session duration, and anonymized IP addresses. This data helps us improve the website and enhance the user experience, without collecting any personally identifiable information.

The user may always decide whether or not to accept the cookies of a particular website. These rules are defined autonomously by the User at browser level.

13. Modifications

In the future, modifications to this Privacy Policy may be introduced for purposes of ensuring ongoing compliance with applicable legal rules. We invite Users to carefully read the rules applied by ourselves for the gathering and processing of personal data.

14. Applicable law and court

The parties agree that, to the extent permitted by applicable legal rules and international agreements, any disputes that happen to arise shall be submitted to the exclusive jurisdiction of the court of the area in which the Onpipeline Limited registered office is located.

15. Contact Information

Onpipeline Limited – 3 Cavendish Row – Dublin 1 – Ireland
For any questions and/or inquiries: please send an e-mail to: privacy@onpipeline.com

16. Language

In the event of any discrepancy or inconsistency between translated versions of this Privacy Notice and the English version, the English version shall prevail.

Current as of July 15, 2025