Privacy Policy

This Privacy Policy of Reflexion Interactive Technologies INC ( “Reflexion”) applies to the Reflexion website located at https://reflexion.co/ and the webpages and other web addresses accessible from such site, including without limitation, Reflexion Store (collectively, the ”Website”); the software applications we make available for download at the Website, the Apple® App Store, other cell phone service provider locations or other locations we indicate or that may be accessed through computers or mobile devices (“Software Apps”); Reflexion products (“Reflexion Products”) and our data services available through the internet made available to users of Reflexion Products or Software Apps that provide and permit the access, collection, storage, processing, analysis and/or transmission of data generated by a Reflexion Product or Software App (“Data Services”); as well as any email or other messages that we send to you that link or refer to this Privacy Policy (collectively, including the Website, the Software Apps, the Reflexion Products, the Data Services, and the messages we send to you, the “Reflexion Products and Services”).

We refer to each user of our Products and Services, and any parent or guardian acting on behalf of such user, as “you” or as a “User.” We also refer to any company on whose behalf a User is using Reflexion Products or Services as “you” or a “User.” The Reflexion Product used by the User is referred to as the “User Device.” This Privacy Policy is subject to the applicable Reflexion Terms of Use located at https://reflexion.co/, and if there is a conflict between this Privacy Policy and the Reflexion Terms of Use, the terms of this Privacy Policy will control. By using any Reflexion Product or Service, you agree with the terms of this Privacy Policy.

Information We Receive.

The personal data we receive about you (which we refer to collectively as your “Personal Information”) includes Registration and Ordering Information, Feedback Information, Data Services Information, Use Information and Derived Information:

• “Registration and Ordering Information” is information you or another User who subscribes to Reflexion Products and Services and makes the Reflexion Products and Services available to you is required to provide in order to register with us when you or such other User registers with Reflexion in connection with the Reflexion Product or Service, or when you or another User submits information to Reflexion to order Reflexion Products or Services from Reflexion. This information may include your name, address, telephone number, email and other contact information, information regarding payment as well as information regarding your Designated Recipients and use of Reflexion Products and Services.
• “Feedback Information” is information you submit to us in connection with your use of Reflexion Products and Services, whether through our Website, through our Data Services, or otherwise, regarding Reflexion Products and Services, or other matters relating to us and our business, including the metadata relating to that information.
• “Data Services Information” is information we receive and transmit through our Products and Services, including:
  • Any of the data generated or used by Reflexion Products to produce other Data Services Information or otherwise available to us through Reflexion Products, such as data used for technical support;
  • Information provided by you or about you by another person you have designated to receive any of your Personal Information through functionality of a Reflexion Product or Service (we call each such person a “Designated Recipient”); and
  • Information from a third party data service that you authorize to be provided to us, either through that third party data service or through an option we make available to you through our Data Services (we call each such third party data service which you authorize to provide information to us, or to which you authorize us to provide your information a “Designated Third Party Service”).
• “Use Information” includes:
  • Information we receive from the computer, mobile phone or other device you use in connection with Reflexion Products and Services, and information we receive from those Products and Services regarding your use, which may include your IP address and other information regarding your computer, your internet service, the browser you use, and your activities while using Reflexion Products and Services, such as how often you open Software Apps, your settings and other activity regarding your use of the components of Reflexion Products and Services;
  • Information we receive from you in connection with our request for comments or feedback on third parties;
  • Information we may receive from advertisers and other third parties when you click on advertisements or links to third party websites while using Reflexion Products and Services, including the pages you visit, your activity on those pages and your purchases or other transactions with those third parties.
• “Derived Information” is information that we create by combining and/or analyzing some or all of your Personal Information.

If any of the Personal Information described above does not reveal your specific identity or relate directly to an individual, we may use such “Other Information” for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

Your Rights and Responsibilities.

• You agree to keep your Registration and Ordering Information current at all times while your account is active.
• Through your Reflexion account (your “User Account”), you can review, update and delete certain Personal Information, and by terminating your User Account you can terminate your use of certain Reflexion Services. Through the features of certain Data Services, you may be able to review, update and delete certain sharing or use of Personal Information, and you can terminate your use of certain Data Services through the Data Service. You can also terminate your use of a Software App or a Data Service that requires a Software App by removing the Software App from your computer, phone or other device on which it is installed. There may be residual information that will remain within our databases and other records, which will not be removed.
• If you submit any Personal Information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
• Data Rights: You have a right to contact us to request access to or receive info about what Personal Information Reflexion collects from you. You may ask that we delete or change inaccurate Personal Information. Where otherwise permitted by applicable law, you may reach out to us at [email protected] to request access to or request deletion of your Personal Information held by Reflexion about you. Please provide your account email address, your full name, and whether you are requesting access to or deletion of your Personal Information. All requests will be reviewed and completed in accordance with local laws.

What We Do With the Information We Receive.

• Registration and Ordering Information: We use Registration and Ordering Information to manage your User Account and Reflexion Products and Services applicable to you, to authenticate you and authorize access to Reflexion Services and as otherwise described below. We also use your email address to contact you regarding your account. We do not make any Registration and Ordering Information public. We will use your User Account and Registration and Ordering Information to link your use of Reflexion Services and Software Apps with your use of Reflexion Products, and it may be accessible by our personnel providing Reflexion Services.
• Feedback Information: You are not required to give us any Feedback Information, but if you choose to do so, you are providing it to us for our use as we determine, so long as we do not identify you or include any information that could be used to identify you. Feedback Information may be used by us and provided by us to our customers and third parties, in the form you provide as well as in excerpted, aggregated and anonymized forms, with or without attribution to you as the source. We may also use Feedback Information in our advertising, marketing and other communications with the public and in our business relationships, as well as in our internal communications, in each case without attribution to you as the source. In addition, we may identify you as the source of Feedback Information to the extent you consent to that identification.
• Data Services Information: We collect Data Services Information and store it on our servers, process it using Data Services, and transmit it to the User and each Designated Recipient and Designated Third Party Service, where applicable for Reflexion Products and Services that are requested by you. We may use Data Services Information in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support in line with applicable data protection laws.
• Use Information: We collect Use Information and store it on our servers, process it using our systems, and analyze it for our business purposes. We do not disclose to third parties any Use Information that can identify you (except as permitted in this Privacy Policy).
• Derived Information: We may use Derived Information to determine information, including Solicitations (defined in the next section), to be sent to you, the public or to targeted groups, and for our business purposes in accordance with the applicable provisions of this Privacy Policy.
• Personal Information and Solicitations: As permitted by applicable law, we may use Personal Information of you and your Designated Recipients, if applicable, to determine which emails and notices we send to you and your Designated Recipients, if applicable, including emails and notices regarding opportunities relating to our Products and Services (we refer to these emails as “Solicitations”). You may opt out of Solicitations by contacting us by email at [email protected] and you may opt in again through that contact. Please keep in mind that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. As permitted by applicable law, we may share your email address or other Registration and Ordering Information with third party service providers acting on our behalf with which we contract for the purpose of providing you with Solicitations we think may be of interest to you. You may opt out of our sharing of your information with third parties for these purposes by contacting us by email at [email protected] or by mail at the address listed in the “Contact Us” section below. We will not share your Personal Information with third parties for them to contact you on their behalf without your consent.
• Personal Information and Your Reflexion Experience: We may use Personal Information belonging to you and your Designated Recipients, if applicable, to tailor to you and your Designated Recipients, if applicable, the experience when using Reflexion Products or Services and the content viewed when using Reflexion Products or Services. We may use Personal Information in accordance with applicable data privacy laws to manage our Products and Services, including the Website, to improve our business and provide new website and product and service features, and to otherwise manage our business.
• Other Third Parties: In the ordinary course of our business, we will use providers to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Information except for providing the services we have asked them to provide. We may provide your Personal Information to another company in conjunction with a corporate sale, merger, acquisition or dissolution involving Reflexion.
• Law Enforcement and Legal Proceedings: We will use and disclose Personal Information as we are required to do by applicable law, including laws outside your country of residence, and may disclose Personal Information when requested by law enforcement authorities or regulatory agencies, including public and government authorities outside your country of residence, or when we determine that such disclosure is appropriate under the circumstances; in each case in accordance with applicable data protection laws. We may use and disclose Personal Information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy; and to allow us to pursue available remedies or limit the damages that we may sustain; in each case in accordance with applicable data protection laws.
• De-Identification: We may “de-identify” your Personal Information by removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law.
• Advertisers: We do not share your Personal Information with any third-party advertisers or (other than hashed or device identifiers, to the extent they are Personal Information in some countries) ad networks for their advertising without your separate permission. However, if you click on an ad, the ad poster will know you visited the page that you clicked on. Also, advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies.
• Marketing: We use data and content about Users for invitations and communications promoting membership and network growth, engagement and our Services.
• Developing Services: We use data, including public feedback, to conduct research and development for the further development of our Products and Services in order to provide you and others with a better experience, drive User growth and engagement on our Products and Services.
• Customer Support: We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Product and Service issues (e.g., bugs).
• Aggregate Insights: We use your data to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our Users.
• Security and Investigations: We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Users.
• Other Uses: We may use your Personal Information for purposes other than those permitted in this Privacy Policy but only after you consent to such use.

What Happens to Information You Share With Others.

• We have no control over Designated Recipients, and once a Designated Recipient receives your Data Services Information, use by the Designated Recipient is between you and the Designated Recipient. We do not verify the contact information you provide for each Designated Recipient. Once you provide such contact information, until you terminate the designation, we will send Data Services Information to the contact information you have provided, and you are responsible for the accuracy of that information.
• Your Designated Recipients may share your Personal Information with Reflexion for purposes relating to their use of Reflexion Products and Services, and we will use such Personal Information of yours in accordance with this Privacy Policy. If your Designated Recipients have your Personal Information, you hereby authorize them to provide such Personal Information to us as each determines.
• Once you share any Personal Information with a third party, including Designated Third Party Services, we have no control over that Personal Information and how it is used by any such third party. You should refer to the terms of service, privacy policy and other provisions of the websites for each third party to whom you provide any Personal Information yourself, and for any Designated Third Party Service you authorize.
• You may elect in your sole discretion for certain of our Software Apps to share Personal Information with Designated Third Party Services that store or transfer such information. Once our Software App shares such information, we no longer have any control over and the use of such, so you should understand the terms for the use of each third party products and the privacy policy applicable to each before you elect for our Software App to share any of your Personal Information with such third party or Designated Third Party Services.

Cookies and Other Technologies.

• Cookies: Please see our Cookie Policy for information about our use of cookies and other tracking technologies with respect to your use of our Products and Services.
• Tracking: Our Products and Services do not currently have the ability to recognize or honor browser do-not-track signals.
• Analytics: We may use third-party analytics, such as Google Analytics, in connection with the Products and Services. Such third-party services may use cookies and similar technologies to collect and analyze information about use of the Products and Services and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online services.
• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some of our Products and Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns, and compile statistics about use and response rates.
• Interest Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Products and Services and other websites or online services, based on information relating to your access to and use of the Products and Services and other websites and services. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags).

HIPAA and HITECH.

• We may receive certain health information of yours that is “protected health information” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). When we receive protected health information, such information will be subject to the requirements under HIPAA and the Health Information Technology for Economic and Clinical Health (“HITECH”) Act of 2009, and the regulations effective under each of those Acts.
• When you elect to share your protected health information with a Designated Third Party Service, you are electing to provide your data to a third party that may not be subject to the requirements of HIPAA, the HITECH Act and the regulations effective under each of those Acts. You control the information that is provided, and your authorization continues until you revoke it through the Software App, Reflexion Service or other component where you made the election. What the Designated Third Party Service may do with your protected health information is determined by the terms applicable to the Designated Third Party Service, and we do not control that use. You understand that your revocation will not affect information previously provided to the Designated Third Party Service, but will terminate further provision of information. Whether or not you elect to share your protected health information with a Designated Third Party Service will not have any effect on the Reflexion Products and Services you may have the right to use.

More on Privacy.

• Children’s Online Privacy Protection: Reflexion does not permit any person under 13 to subscribe directly to Reflexion Services or Software Apps or to directly purchase Reflexion Products. A parent or legal guardian may subscribe for a User who is under 18, but no person under 18 is permitted to use Reflexion Products or Services without the express agreement of a parent or legal guardian to the terms of the Agreement which require, among other things, that the parent or legal guardian is responsible for designating Designated Recipients, connecting the User Device to Reflexion Services or Software Apps, interacting in all ways with Reflexion Services and Software Apps, and ensuring that all communications with us come from the parent or legal guardian and not from the person under 18.
• Adults with Guardians, Conservators or Other Legal Supervision: Reflexion does not permit any person to subscribe directly to Reflexion Services, or Software Apps or to directly purchase Reflexion Products if that person lacks the legal competence to enter into a contract and be bound to the terms of the Agreement. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence to enter into a contract and be bound to the terms of the Agreement, but no such User is permitted to use Reflexion Services or Software Apps without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the terms of the Agreement, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Reflexion Services and Software Apps, interacting in all ways with Reflexion Services and Software Apps, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.
• Phishing: do not and will not, at any time, request Registration and Ordering Information in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website.
• Security: Reflexion uses commercially reasonable standards of technology and operational security to protect Personal Information within our organization. Personal Information transmitted through Reflexion Products and Services is transmitted in encrypted form. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section, below.
• Links to Third Party Sites: Reflexion Products and Services may contain links to third- party websites, applications or other items. We assume no responsibility for the information practices of those websites, applications or other items, and the inclusion of a link does not imply our endorsement of the linked site or service. In addition, this Privacy Policy does not apply to the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our Products or Services link or any third-party provider of an app, social media platform, operating system, wireless service or device. We encourage you to review each third-party’s privacy policy before disclosing any personal information to any third party or using its products or services.
• Do Not Track Disclosure: In accordance with the Do-Not-Track amendments to the California Online Privacy Protection Act, we inform you that we do not currently respond to “do not track” signals or similar messages from your browser.

Retention: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a different retention period is required or permitted by law.

Terminating Your Account.

• You may terminate your User Account by following the instructions at the appropriate page at our Website.
• When you terminate your User Account, we may retain your Personal Information, and we may continue to use your Personal Information, but only as authorized in this Privacy Policy and by applicable law. You may contact us at the email or mailing address listed in the “Contact Us” section below to request that we delete your Personal Information, and we will seek to remove your information from our active systems expeditiously.

Changes.

We may change this Privacy Policy by posting a new version of this Privacy Policy at https://reflexion.co/privacy-policy. To the maximum extent permitted by applicable law, any changes will become effective when we post the updated Policy on our Website, and .your use of our Products and Services following these changes means that you accept the updated Policy. If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further Personal Information. Where applicable law requires your consent to a specific change in this Privacy Policy that you have previously consented to, such change will not be applicable to you until you provide your consent.

Contact Us.

If you have any questions about this Privacy Policy or wish to “opt-out” of Solicitations, please: (1) send us an email at privacy@ reflexioninteractive.com; or (2) write to us (and include your email address) at the following address:

Reflexion Interactive Technologies INC

ATTN.: Privacy Officer

355 E Liberty Street, Suite 300

Lancaster, PA 17602

Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.

Version.

This Privacy Policy is dated August 12th, 2021.