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Privacy Policy.

Reflexion.ai (hereinafter “Reflexion”, “we”, “us”, “our”) recognises the importance of the privacy of its users and also in maintaining the confidentiality of the information provided by its users.  Please read this Privacy Policy to learn how we treat your personal data. This Privacy Policy is applicable to any person (‘User’) who uses any product(s) or service(s) made available by Reflexion through any of Reflexion’s customer interface channels including its website, mobile site, and mobile app. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.


Remember that your use of Reflexion.io’s Services is at all times subject to our Terms of Service , which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

  1. 1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not apply to any website(s), mobile sites, and mobile apps of third parties, even if their websites/products are linked to our Website. Users should take note that the information and privacy practices of Reflexion’s business partners, advertisers, sponsors, or other sites to which Reflexion provides hyperlink(s), may be materially different from this Privacy Policy. Accordingly, it is recommended that you review the privacy statements and policies of any such third parties with whom they interact.


  1. 2. Information we collect

We collect information  about you from the following categories of sources:


  1. a) Information you provide to us
    We collect information about you when you input it into the Services or otherwise provide it directly to us. For instance -
  • - When you create an account or use our tools and Services. We collect information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information, when you register for the Services. You also have the option of adding a display name, profile photo, job title, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.

  • - When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

  • - When you send us an email or otherwise contact us.

  1. b) Information collected automatically when you use our Services

  • Use of Services:  
    -We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on; the type, size, and filenames of attachments you upload to the Services; frequently used search terms; content using analytics techniques that hash, filter, or otherwise scrub the information to exclude information that might identify you or your organization.

  • - If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

  • - If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you with the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
  1. c) Information from Third Parties
  • We receive information about you from other Service users, from third-party services, from our related companies, social media platforms, public databases, and from our business and channel partners. We may combine this information with information we collect through other means described above. This helps us to update and improve our records, identify new customers, create more personalized advertising and suggest services that may be of interest to you.
  • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us. For example, if you create an account or log into the Services using your Google or Twitter credentials, we receive your name and email address as permitted by your Google or Twitter profile settings in order to authenticate you.

3.  3. How we use the information we collect


  1. a). Providing, Customizing, and Improving the Services
  • - Creating and managing your account or other user profiles.
  • - Processing orders or other transactions; billing.
  • - Operating and maintaining our features and Services.
  • - Providing you with the products, features, services, or information you request.
  • - Meeting or fulfilling the reason you provided the information to us.
  • - Providing support and assistance for the Services.
  • - Responding to user inquiries.
  • - Improving the Services, including testing, research, internal analytics and product development.
  • - Providing and monitoring the effectiveness of the Services.
  • - Personalizing the Services, website content, and communications based on your preferences.
  • - roubleshoot, to identify trends, usage, activity patterns, and areas for integration to improve Services, and to develop new products, features, and technologies that benefit users and the public.
  • - Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Services;
  • - Monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services;
  • - Maintaining interoperability with third-party services.
  • - Doing fraud protection, security, and debugging.
  • - Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

  1. b). Marketing the Services
  • -We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying PlatformIO ads on other companies' websites and applications. These communications may be informed by audits of interactions (like counting ad impressions), and are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new Services, product offers, promotions, and contests. You can control whether you receive these communications as described below under "Opt-out of communications."

  1. c). Communicating with You
  • -We use your contact information to send transactional communications via email and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions, and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings.

  1. d). Meeting Legal Requirements and Enforcing Legal Terms
  • -Where required by law or where we believe it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.


4. How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data.


  1. a). Service Providers: These parties help us provide the Services or perform business functions on our behalf. They include:

  • - Hosting, technology and communication providers.
  • - Security, spam, and fraud prevention consultants and providers.
  • - Analytics providers
  • - Monitoring service providers.
  • - Data management platforms.
  • - Support and customer service vendors.
  • - Product fulfilment and delivery providers.
  • - Payment processors.
  • - Our payment processing partner collects your voluntarily provided payment card information necessary to process your payment.
  • - Please see Reflexion AI LLC’s terms of service and privacy policy for information on its use and storage of your Personal Data.

  1. b). Advertising Partners: These parties help us market our services and provide you with other offers that may be of interest to you. They include:

  • - Ad networks.
  • - Marketing partners and providers.
  1. c). Business Partners:  These parties partner with us in offering various services. They include:

  • - Businesses that you have a relationship with.
  • - Companies that we partner with to offer joint promotional offers or opportunities.

  1. d). Parties You Authorize, Access, or Authenticate

  • - Third parties you access through the services.
  • - Social media services.
  • - Other users.

  1. e). Legal Obligations: We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

  2. f). Business Transfer: All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

  3. g).Data that is Not Personal Data: We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.  

5.Tracking Tools, Advertising, and Opt-Out


The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs an,d JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.


We use the following types of Cookies:


  • - Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

  • - Functional Cookies: Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

  • - Performance/Analytical Cookies: Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy.

  • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.


To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/


Information about Interest-Based Advertisements


We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.


We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/  or www.aboutads.info/choices.


6. 6. Data Security and Retention


We seek to protect your Personal Data from unauthorized access, use, and disclosure using appropriate physical, technical, organizational, and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.


We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services, and for an additional two years or until we receive a request to delete it. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.


8. 7. California Resident Rights


If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.


If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@reflexion.ai


Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent the disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at info@reflexion.ai


Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com .


  1. a). Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:


  • - The categories of Personal Data that we have collected about you.
  • - The categories of sources from which that Personal Data was collected.
  • - The business or commercial purpose for collecting or selling your Personal Data.
  • - The categories of third parties with whom we have shared your Personal Data.
  • - The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. We do not currently sell any Personal Data, and we have not done so over the past 12 months.


  1. b). Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.


  1. c). Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information (like your account credentials) to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.


We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.


You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.


  1. d). We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you with a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.


9. 8. Nevada Resident Rights


If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.


10. 9.Changes to this Privacy Policy


We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any material changes by placing a notice on the Reflexion website, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. The use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.


11. 10. Contact Information


If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at: info@reflexion.ai