Reflektion, Inc.

Reflektion, Inc., a Delaware corporation, (“Reflektion,” “we,” or “our”) is committed to protecting the privacy of individuals and organizations who visit our web site at www.reflektion.com (the “Corporate Site”) or use the Reflektion Xplorer™ services (the “Services”) either through our Corporate Site or through our corporate clients’ websites or mobile websites (collectively, the “Web Sites”).

This Privacy Policy describes the privacy practices of Reflektion and how we collect, use, and disclose the information that we collect from users of the Web Sites. By your use of the Services through the Web Sites and/or your registration on the Web Sites, you expressly consent to our collection, use and disclosure of your information in the manner described in this Privacy Policy and the privacy policies of our corporate clients’ sites. If you do not agree to the terms of this Privacy Policy, please do not use the Services or the Web Sites.

Reflektion reserves the right to modify this Privacy Policy at any time and without prior notice. The date of the most recent revision will appear on this page, and your continued use of the Services or the Web Sites will constitute your acceptance of any revisions of this Privacy Policy. 

The effective date of this Privacy Policy is December 31, 2014.

INFORMATION COLLECTED

If you choose to use the Web Sites and/or the Services, we may require you to provide personal contact information, whether in connection with your request for a demonstration or in connection with use of the Services. The information we may require you to provide might include your name, company name, address, phone number, email address, financial qualification or billing information such as credit card numbers, billing name and information about the size of your organization and related information (“Personal Information”). We request Personal Information when you use or access the Services, request information about the Services or correspond with us or engage in certain other activities through Web Sites.

As you navigate Web Sites, we may also collect comments, reviews, images, other content uploaded on the Web Sites or through the Services including “wall” posts and online training courses, questions and answers to public and private tests or other community boards, discussion area posts and other messages and feedback associated with the Services. Other information, such as statistics on page views and Web Site traffic, is automatically collected whenever you interact with Web Sites or the Services.

You make the decision whether to proceed with any activity that requests Personal Information.  If you do not wish to provide the requested Personal Information, however, this may affect your ability to use the Services or certain features of the Web Sites.

Any Personal Information you elect to make publicly available on our Web Sites by posting comments or otherwise will be available to other visitors. If you remove information that you have made public, copies may remain viewable in cached and archived pages.

We may use your Personal Information as follows:

  • to provide the Services;
  • to verify your identity when you sign in;
  • to encourage safe online experiences and enforce our policies;
  • to customize users’ experience, analyze usage of the Web Sites, improve and measure interest in the Services;
  • to inform users about services and updates;
  • to communicate announcements and marketing or promotional offers to you; or
  • to provide customer service.

We also collect information used to track online usage patterns of users to enable more accurate reporting, improve the effectiveness of our Services and improve the Web Sites. This information is not Personal Information, but anonymous data collected in the aggregate (“Anonymous Information”).

USE OF INFORMATION

Reflektion does not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. However, we may disclose your Personal Information as follows:

  • to affiliates of Reflektion that we control and that are subject to this Privacy Policy or similar privacy practices;
  • to identify your feedback, comments or reviews as your own;
  • to third parties to enforce the Reflektion Terms of Use and other Reflektion agreements and policies, or to protect a user’s rights, property, or safety;
  • to third parties to respond to claims that photos or other content that you upload violates other’s rights;
  • to service providers who help with our business operations and assist in the delivery of Reflektion services under obligations of confidentiality;
  • to operate and improve Web Sites or the Services; or
  • to third party service providers to manage credit card processing.

We reserve the right to use or disclose your Personal Information if required by law or if Reflektion reasonably believes that use or disclosure is necessary to protect Reflektion’s rights and/or to comply with a judicial proceeding, court order or legal process.

Occasionally, we may share your Personal Information with business partners for the purpose of providing you with improved services. If you prefer that we not provide your Personal Information, you may let us know by using one of the methods described below in this Privacy Policy.  We also retain the services of outside contractors to provide services for us.  They may be used to provide training services, technical support, to develop improved services, to handle order processing or to perform other services. We require that these contractors keep the Personal Information of customers secure and confidential.  

COOKIES, WEB BEACONS AND LOG FILES

When you visit Web Sites or use our Services we may store information about your session and assign you one or more “cookies.” Your browser will store these cookies on your computer in a small text file. Permanent cookie files remain on your computer’s hard drive until you delete them manually using your browser or operating system software. Our cookies will be shared across the Web Sites to aggregate your data. You can enable your browser to refuse cookies, but doing so may disable access to some services and tools that we offer.

We may also use web beacons and cookies to collect information about:

  • your use of our corporate clients’ sites, including what products you view and other online navigation data;
  • your purchases on our corporate clients’ sites;
  • your interaction with emails sent by our corporate clients or by us on our clients’ behalf, including opening emails and clicking on recommendations in the emails;
  • your clicks on advertisements sent by our corporate clients or by us on our clients’ behalf;
  • your email address if you have consented to receive emails from our corporate clients;
  • information from our corporate clients whose privacy policies allow them to share Personal information and/or Anonymous Information about their customers with us, such as purchase history; and
  • information from marketing partners and other third party data providers whose privacy policies allow them to share Anonymous Information about their customers with us, such as consumer’s interest or purchase behavior.

Further, a large amount of the information that we collect is automatically generated by your computer and/or browser. This includes information such as Internet Protocol (“IP”) addresses, the date and time, whether one of our cookies is already set on your browser, your browser type, your interactions with our services, referring and exit pages, clicks, and pages viewed.

LINKS TO THIRD PARTY WEB SITES

The Web Sites may contain links to other third-party web sites. We do not necessarily share your Personal Information or Anonymous Information with those web sites and are not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.  

STORAGE AND PROCESSING

Information we collect may be stored and processed in the United States or any other country in which we or our subsidiaries, affiliates or service providers maintain operations. We may transfer information that we collect, including Personal Information, to affiliated entities or to third parties across borders around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that has data and privacy protection laws which differ from the laws of your jurisdiction and you consent to the transfer of information to the United States and to any other country in which our subsidiaries, affiliates or service providers maintain operations.

MANAGING COMMUNICATIONS AND OPT-OUT

You may manage your receipt of non-transactional communications from us. We provide a number of ways for you to “opt-out” of receiving additional information from us or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your Personal Information. If you no longer wish to receive our promotional communications you may opt-out of receiving these communications by replying to an email communication and writing “unsubscribe” in the subject line in the email or by emailing us at support@reflektion.com.

PRIVACY AND CHILDREN

Anyone using the Web Sites or the Services warrants and promises that they are 13 years of age or older. We do not knowingly collect Personal Information from anyone under the age of 13. If you are under the age of 13, please do not use the Web Sites or the Services.

SECURITY MEASURES

We are committed to protecting your Personal Information, but we cannot ensure or warrant the security of any information you transmit to us. We cannot guaranty that your information may not be disclosed, accessed, altered or destroyed by breach of any of our industry standard safeguards. No method of transmission over the Internet or electronic storage is full-proof. We cannot guaranty absolute security.

CHANGING OR UPDATING INFORMATION

To the extent that you do provide us with your Personal Information, we wish to maintain accurate Personal Information. Where we collect Personal Information from you on Web Sites, our goal is to provide a means of contacting us should you need to review, update or correct your Personal Information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections about your Personal Information by email to support@reflektion.com and we will make reasonable efforts to incorporate the changes in your Personal Information that we hold as soon as practicable.

QUESTIONS

Any questions about this Privacy Policy should be addressed to support@reflektion.com.