Privacy Policy

Effective Date: June 18, 2019

Introduction

Reflection is committed to protecting your privacy.  This Privacy Policy applies to www.reflectionamerica.com (“Website”) and Reflection’s mobile application (“Mobile App”), and subscription services, all of which are owned and operated by Reflection International Inc.  (collectively referred to herein as "Reflection").  This Policy details the steps Reflection takes to protect your personal information when you use our Website, Mobile App, products, other software applications, and subscription services.  This Privacy Policy describes how Reflection collects, uses, shares and secures the personal information you provide.  It also describes your choices regarding use, access and correction of your personal information.  By accessing Reflection’s Website, Mobile App, and subscription services and using our products, you are consenting to the information collection and use practices described in this Privacy Policy.  The use of information collected through Reflection’s services shall be limited to the purpose of providing the service for which you have engaged Reflection.

 

Changes to this Privacy Policy

Reflection may occasionally update this Privacy Policy.  Changes and updates may be by posting notice of such changes on our Website and/or Mobile App and revising the "last updated" date at the top of the Privacy Policy or by other means, consistent with applicable law.   YOU UNDERSTAND THAT YOU HAVE THE AFFIRMATIVE OBLIGATION TO CHECK THIS PRIVACY POLICY PERIODICALLY FOR CHANGES, AND YOU HEREBY AGREE TO PERIODICALLY REVIEW THIS PRIVACY POLICY FOR SUCH CHANGES.   THE CONTINUED USE OF OUR SERVICES FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY CONSTITUTES AN ACCEPTANCE OF THOSE CHANGES. 

Reflection may collect information about how you use our services by using cookies and similar technologies, and our servers may collect similar information when you are logged in to the Website or Mobile App.  The personal information we collect may include:

  • contact details, such as your name and email address, etc.;
  • your email marketing preferences;
  • payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by Reflection’s third-party payment processor on its behalf;
  • financial information (including credit card or account information);
  • information used to customize and facilitate your use of our website, including login and technical information;
  • inquiries about and orders for our products and services;
  • information that assists Reflection in identifying the products and services that best suit your requirements;
  • information that assists us in improving Reflection’s products and services;
  • feedback from you about Reflection’s website, application, and its products and services generally; and
  • any information as collected pursuant to the description under "information collected automatically" below. 

Reflection may collect the following information, including personal information while you are using Reflection products and services as defined in Terms of Use, including but not limited to the Reflection’s Site, Mobile App, and subscription services:

  • Setup information and account information you provide;
  • Data from the sensors built into the device;
  • Video and audio signals and data;
  • Technical, usage and performance information from the device;
  • Shared content.

You are not required to provide any of this information, but if you do not, we may not be able to provide you the requested service or complete your transaction.

 

Information collected automatically

Reflection collects information about your visit to our site, including what pages you view, the number of bytes transferred, the links you click, the materials you access, and other actions taken within Reflection's site.  On a site that you enter with a login, Reflection may connect this information with your identity to determine your potential interest in our products and services.  Reflection also collects certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site, and the website from which you linked to our site to analyze trends in the aggregate and administer the site.  Reflection does not link this information to your identity.

 

Cookies and Tracking Technologies

Reflection and its partners use cookies or similar technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole.  You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

 

How does Reflection use your personal information?

Reflection uses the information we collect about you in a number of ways, such as:

  • Providing you with products and services as well as any support or information you have requested;
  • Better understanding how products and services are being used so we can improve them;

Diagnosing problems in our products and services;

  • Sending you business messages such as those related to payments or expiration of your subscription;
  • Sending you information about Reflection, such as new application releases, special offers, and similar information;
  • Reducing fraud, software piracy, and protecting our customers as well as Reflection;

To administer our services or website (including any searches or requests for information about our products or services);

  • For assessment and analysis of our market, customers, products and services, including asking you for your opinions on our products and services and carrying out customer surveys;
  • To enable us to monitor, review and improve the products and services which we offer;
  • For internal record keeping.

 

Mobile Application

When you download and use Reflection’s Mobile App, we automatically collect information on the type of device you use, operating system version and system and performance information.

We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running.  If you no longer wish to receive these types of communications, you may turn them off at the device level.  To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. 

We use mobile analytics software to allow us to better understand the functionality of our Mobile App on your phone.  This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.  We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

 

Disclosure of your personal information 

Except as described below, personal information you provide to Reflection will not be shared outside of Reflection and its controlled subsidiaries and affiliates without your permission. 

Disclosure to service providers.  Reflection contracts with other companies to provide services on our behalf, such as hosting websites, sending out information, processing transactions, analyzing our websites, and providing cloud storage.  We provide these companies with only those elements of your personal information they need to deliver those services.  These companies and their employees are prohibited from using that personal information for any other purpose.

Disclosure to distributors.  In responding to a request made by you, we may share your personal information with companies that distribute our products.  In those cases, we provide these companies with only those elements of your personal information they need to respond to your request, and these companies and their employees are prohibited from using that personal information for any other purpose.  In some cases, we may seek your permission to share your information with distributors for marketing purposes other than responding to a request from you.  However, we will not share your information for such marketing purposes unless we have obtained your express consent to do so.

Disclosure in connection with transactions.  In connection with certain transactions, we may disclose some or all of your personal information to financial institutions, government entities, and shipping companies or postal services involved in fulfillment. 

Disclosures in connection with acquisitions or divestitures.  Circumstances may arise where for strategic or other business reasons Reflection decides to sell, buy, merge or otherwise reorganize businesses in some countries.  Such a transaction may involve the disclosure of personal information to prospective or actual purchasers or receiving it from sellers.  It is Reflection's practice to seek appropriate protection for information in these types of transactions.

Disclosure for other reasons.  We may disclose personal information if required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual.

We may also disclose your personal information to any other third party with your prior consent.

 

Minors

Reflection does not knowingly collect or store any personal information about children under the age of 13.

 

Security

We are committed to ensure that your personal data is kept and stored securely, and we maintain reasonable physical, technical and organizational measures and procedures to safeguard and secure the information we collect through our services.

This has been done with a view to preventing unauthorized or unlawful processing of your personal data and accidental, unauthorized or unlawful access, use, processing, copying, alteration, transfer, loss or destruction of, or damage to your personal data.  Whilst we have done all of this, and comply with the standards required by applicable laws, we cannot guarantee that your personal data is secure when submitted or otherwise communicated through insecure means.  We protect the security of your personal data by:

  • using encryption where appropriate;
  • using password protection where appropriate; and
  • limiting access to your personal data (for example, only our staff or employees who need access to it for the purposes described in this Privacy Policy will have access to it).

However, these measures do not release you from taking appropriate steps to keep your personal data safe and secure, in particular by avoiding obvious user ID's or passwords, by changing your password regularly and by ensuring that you do not disclose your password(s) or grant any other person access to your user account and your personal data.

We endeavor to protect the privacy of your account and other personal information we hold in our records, but we cannot guarantee complete security.  Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.  If you have any questions about the security of your personal information, you can contact us at service@reflectionamerica.com.

 

Reviewing your personal information

Upon request Reflection will provide you with information about whether we hold any of your personal information.

In some cases, you can review, correct, request deletion of personal information provided through our websites by going to the page on which you provided the information.  In all cases, you can make a request to review and/or correct your personal information collected via our website or asks Reflection to stop using it by contact us at service@reflectionamerica.com.  We may take steps to verify your identity before providing you access to your personal information.  You can help us to maintain the accuracy of your information by notifying us of any change to your email address.  We will respond to your request within a reasonable timeframe.

Note that we need to retain certain records for legal or internal business reasons and that some of your information may remain on backup systems, in compliance with applicable law.  We will retain your personal information for as long as necessary to provide you with the website and application you are eligible to use with login and password, or as needed to comply with our legal obligations, may need to retain your personal information in order to continue providing a service or enforce our agreements.

 

Email Preferences

You may sign-up to receive email or other communications from us.   If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you or at your member profile on our website or by contacting us at service@reflectionamerica.com.

If you have questions regarding this statement or our handling of your personal information, please contact us.  We will promptly address your concern and strive to reach a satisfactory resolution.  Reflection International Inc., 1502 Foothill Blvd., #103-222, La Verne, CA  91750.

Email: service@reflectionamerica.com