Reflektion, Inc.

Effective Date:  March 14TH, 2020

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 (the “Corporate Site”) or use the Reflektion CEC (Customer Engagement Console) and CEXP (Customer Experience/Engagement Platform) 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. 


Information You Provide To Us

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.


Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that Reflektion combines together so that it no longer identifies or references an individual customer).

Reflektion may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. Reflektion may perform our own analytics on anonymized data or enable analytics provided by third parties.

Types of data Reflektion may anonymize includes transaction data, click-stream data, performance metrics, and fraud indicators.

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

For example,

  • Joint Marketing Partners & Resellers: unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that Reflektion can better understand which of our Services may be of interest to you.
  • Advertising Networks & Analytics Providers: Reflektion works with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation – for more information on how you can manage collection of this data, please see our Cookie Policy below.  


Reflektion does not and will not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. 


  • 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.
  • TO CONTACT OUR CONSUMERS: subject to applicable law, Reflektion or our third-party service and business providers may send you communications. Such communications are designed to make your experience of our Services more efficient and may include, but are not limited to: notifications about our Services and other communications (including important news that could affect your relationship with us), communications about promotions and our mobile application features. Where required under applicable data privacy laws, Reflektion will not send you marketing communications without your prior consent.
  • LEGAL PURPOSES: Reflektion may use and share Personal Information for legal purposes, including financial, regulatory, tax, and other legal obligations, and to respond to governmental or regulatory requests or subpoenas or for litigation purposes. Our Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. In addition, Reflektion uses third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. If you do not provide personal information required by law, Reflektion will have to close your account immediately.
  • FOR OUR LEGITIMATE BUSINESS INTERESTS AND THOSE OF A THIRD PARTY: Reflektion may use your Personal Information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations.
  • FOR OUR BUSINESS PURPOSES:  Reflektion may use your Personal Information to help us efficiently operate the Services, to count and recognize visitors to our Services, to enable certain features on or in our Services, and for other purposes related to managing our business  Reflektion handles sensitive information, so it is very important for us and our customers that Reflektion actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other services. In addition, Reflektion collects information about your account usage and closely monitors your interactions with our Services. Reflektion may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account. 
  • FOR FRAUD PROTECTION AND DETECTION: Reflektion processes your personal information in order to help detect, prevent, and mitigate fraud and abuse of our Services.
  • FOR COMMUNICATION  WITH OUR CONSUMERS: Reflektion sends administrative or account-related information to you to keep you updated about our Services, informs you of relevant security issues or updates, or provides other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
  • TO PROVIDE CUSTOMER SUPPORT: Reflektion processes your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, Reflektion cannot respond to your support questions and ensure your uninterrupted use of the Services.
  • FOR QUALITY CONTROL: Reflektion processes your personal information for quality control and staff training to make sure Reflektion continues to provide you with accurate information. If Reflektion does not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
  • FOR CYBERSECURITY: Reflektion processes your personal information in order to enhance security, monitor and verify identity or Service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that Reflektion have accurate and up-to-date information about your use of our Services. Without processing your personal information, Reflektion may not be able to ensure the security of our Services.
  • FOR RESEARCH AND DEVELOPMENT: Reflektion processes your personal information to better understand the way you use and interact with the Services. In addition, Reflektion uses such information to customize, measure, and improve Reflektion’s Services and the content and layout of our website and applications, and to develop new services. Without such processing, Reflektion cannot ensure your continued enjoyment of our Services.
  • TO IMPROVE  THE CONSUMER EXPERIENCE: Reflektion processes your personal information to provide a personalized experience and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, Reflektion may not be able to ensure your continued enjoyment of part or all of our Services.
  • IN THE CASE OF  CORPORATE ACQUISITIONS, MERGERS, OR TRANSACTIONS: Reflektion may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal information processed for such purposes.
  • TO PROMOTE MARKETING: Based on your communication preferences, Reflektion may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
  • DIRECT MARKETING: Direct marketing includes any communications to you that are only based on advertising or promoting our products and Services. Reflektion will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or with your consent. To the extent Reflektion can rely on legitimate interest under the applicable law, Reflektion will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, Reflektion will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, update your email preferences here.
  • You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services.

THIRD-PARTY MARKETING: Reflektion will obtain your express consent before Reflektion shares your personal information with any third parties for marketing purposes.


Subject to applicable law, Reflektion may use your Personal Information for additional purposes in connection with the Services, where you have provided your prior consent.

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.  

The following chart summarizes how Reflektion uses the categories of personal information Reflektion collects:

 Purpose of Processing  Legal Bases for Processing
  • To enforce our terms in our Reflektion terms of service agreement and other agreements
  • To provide Reflektion’s Services
  • To provide Service communications
  • To provide customer service
  • To ensure quality control

  • Based on our contract with you or to take steps at your request prior to entering into a contract.
  • For research and development purposes
  • To enhance your experience
  • To facilitate corporate acquisitions, mergers, or transactions
  • To engage in direct marketing activities
  • Based on our legitimate interests. When Reflektion process your personal
  • Information for our legitimate interests Reflektion always ensure that Reflektionconsider and balance any potential impact on you and your rights under data protection laws.


  • To maintain legal and regulatory compliance
  • To detect and prevent fraud and/or funds loss
  • To ensure network and information security

  • Based on our legal obligations, the public interest, or in your vital interests.
  • To enhance your experience
  • To engage in third-party marketing activities
  • For any purpose
  • Based on your consent.


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.


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.  

This Privacy Policy does not apply to those websites, and Reflektion recommends reviewing those websites’ privacy policies individually.  Our Services may contain products and services of third parties, so when you use the third party products or accept third-party services, they may be able to obtain your personal information. Please read the privacy policies of these third-party companies, as their policies govern their collection and use of your personal information.


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.


California law permits customers who are California residents to request certain information about our disclosure of personal information during the prior calendar year to third parties for their own direct marketing purposes. However, we do not sell or rent your Personal Information to any third party for their own marketing.  For questions, please contact us at 

As of Jan. 1, 2020:

If you are a California resident, you also have the right to access any personal information we have collected about you and inquire about our collection, sale and disclosure of your personal information by calling us at 866-REFLEKT or emailing

As of Jan. 1, 2020,:  California residents have the right to opt-out of the sale of their personal information by calling us at 866-REFLEKT or emailing

Specifically, if you are a California resident, you have the right to request information from us regarding whether Reflektion shares certain categories of your personal information with third parties for the third parties’ direct marketing purposes. To the extent Reflektion shares your personal information in this way, you may receive the following specific information:

  • (a) the categories of information Reflektion disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and
  • (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
  • For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. Reflektion will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, Reflektion will not deny you services, charge you different prices for services or provide you a different level or quality of services.
  • To the extent Reflektion sells your personal information to third parties, you also have the right to request that Reflektion disclose to you: (i) the categories of your personal information that Reflektion sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. Reflektion does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.

Should Reflektion engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you by contacting us via so that Reflektion may consider your request.

If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. Reflektion will respond to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. Reflektion may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf or are unable to verify their identity.


Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Reflektion has absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

  • Access and portability. You may request that Reflektion provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
  • Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by Reflektion that is inaccurate. You may do this at any time by logging in to your account.
  • Erasure. You may request to erase your personal information, subject to applicable law. If you close your Reflektion Account, Reflektion will mark your account in our database as “Closed,” but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Reflektion’s compliance and legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law or regulatory agencies, or in accordance with this Privacy Policy.
  • Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Reflektion’s processing based on consent before your withdrawal.
  • Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. Reflektion may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
  • Automated individual decision-making, including profiling. Reflektion relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.


You can make privacy rights requests relating to your personal information by contacting us via  Reflektion strongly encourages you to make any individual rights requests because it ensures that you have been authenticated already. Otherwise, when Reflektion receives an individual rights request via other intake methods, Reflektion may take steps to verify your identity before complying with the request to protect your privacy and security. You will have to prove your identity to receive a complete set of your personal data. 


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


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.


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 guarantee 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 guarantee absolute security.


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 and we will make reasonable efforts to incorporate the changes in your Personal Information that we hold as soon as practicable.


Reflektion is transparent about the ways in which Reflektion collects and uses Personal Information, and welcome your questions and concerns. If you have any concern or complaint about the way Reflektion handles your Personal Information, please contact us as described below. To the extent you believe Reflektion has not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see  

If you believe that Reflektion has infringed your rights, Reflektion encourages you to first submit a request via, so that Reflektion can try to resolve the issue or dispute informally. If that does not resolve your issue, you may contact the Reflektion Data Protection Officer. 

If you wish to complain about the handling of your Personal Information outside of Reflektion you may, under applicable data privacy laws, have the right to raise a complaint with the supervisory authority in your country of residence.

IF YOU RESIDE IN THE EU, you can file a complaint with the International Centre for Dispute Resolution by phone at +1.212.484.4181, or by visiting the website, or your relevant data protection authority.

IN THE UK, the relevant data protection authority is Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113,

IN IRELAND, the relevant data protection authority is the Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois; phone: +353 (0761) 104 800; LoCall: 1890 25 22 31; Fax: +353 57 868 4757; email:


If you have any questions or complaints about our privacy practices or policies and our collection, use or disclosure of personal information please submit your request to

If you have any concerns regarding how Reflektion is handling your Personal Information, please contact us immediately.  Reflektion will strive to deal with your concerns promptly.