Effective as of February 12, 2015
This Privacy Notice describes the principles and practices that apply to the use of personal information (defined below) that Reach150 Social (“Reach150,” “we,” “us”) collects from users of the website, www.reach150.com, our mobile app and any sites we have now or in the future that reference this Privacy Notice (collectively, the “Services”).
By using the Services, you consent to our processing of your information as set forth in this Privacy Notice.
1. Your California Privacy Rights: Under California Civil Code Section 1798.83, California residents have the right to request in writing that we provide (a) a list of the categories of personal information, such as name, email and mailing address, and the type of services provided to the customer, that we have disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year, for the third parties direct marketing purpose and (b) the names and addresses of all such third parties.
To request the above information, please contact us as indicated in the “How to Contact Us” Section of this Privacy Notice, with a reference to California Shine the Light Law.
We will respond to such requests within 30 days following receipt of the letter or email sent to the address provided in the “How to Contact Us” Section. If we receive your request at a different email or mailing address, we will respond with a reasonable period, but not to exceed 150 days from the date received. Please note that we are only required to respond to each individual once per calendar year.
2. Definitions and Background: For ease of use of this document, certain terms have been associated with the specific meaning provided below.
a. “Client” means the company who contracts with Reach150. From time to time, the Client is also the Subscriber.
b. “Device” means a smart phone, tablet, and any other similar mobile or connected equipment that is used for online activities.
c. “Personal Information” means information that identifies an individual or that, when combined with other information available to the data holder may allow identifying an individual with reasonable certainty. “Personal information” includes any information that is collected from the Services or from any communication between us and an individual, such as contact information that a visitor might provide when asking for information about the Services. It also includes an individual’s name, address, or contact information.
d. “Recommendation” means the content a User provides to a Subscriber via the Recommendations entry form. All content submitted in this form constitutes the recommendation and currently includes recommendation body, name, title or role, and photo of you, the User. It also includes time and date of submission.
e. “Subscriber” means individuals and Reach150 Clients that solicit Recommendations.
f. “User” means individuals who provide Recommendations of Reach150 Subscribers. It also means individuals who read Recommendations and contact Reach150 Subscribers and Reach150 Clients.
3. Scope: This Privacy Notice applies to information that we collect or receive from Users, Subscribers and Clients of the Services.
4. Consent: By using the Services, you consent to our processing of your information as set forth in this Privacy Notice.
Your continued use of the Services, or continued interaction with us after we have notified you of a material change in our Privacy Notice in accordance with the Updates will be deemed an acceptance of these new terms.
5. Our Policy Towards Children and Minors: Reach150 does not intend that any portion of the Services will be accessed or used by children under the age of thirteen, and such use is prohibited. The Services are designed and intended for Subscribers and Clients that are at least 13 years of age. By using the Services, you represent that you are at least 13 years old. If you are 13 or older but under the age of majority (which is 18 years old in most states), then your parent or guardian may be liable for some or all of your activities on the Services. Because of this, and because it is prudent for your parent or guardian to be aware of your activities, including the websites that you visit, you should make your parent or guardian aware that you are using the Services.
6. Reach150’s Privacy Practices for Users 13 Or Older
a. The Information We Collect: The Services are a platform through which Subscribers and Clients may solicit and publish Recommendations from Users. Therefore, although Users do not have to share any Personal Information to use the Services, Subscribers and Clients will provide us with certain Personal Information, for instance if you include your name, email address, credit card information or a photo of yourself in your profile.
b. How We Collect Personal Information:
i. From You: We collect Personal Information in a number of ways. First, you provide us with Personal Information when you subscribe to the Services and complete your profile.
iii. We also use technology to collect certain information automatically, like your Internet Protocol (“IP”) address (which is the automatic number assigned to your computer by your Internet service provider when you surf the Web; computer operating system (e.g., Microsoft Windows, Mac OS); your browser (e.g., Internet Explorer, Firefox); websites visited before or after you visit the Services; pages viewed and activities on the Services; and advertisements shown or clicked on.
Our website analytics service provider may combine usage data regarding how Users use our Services (e.g. which page a User visits more frequently) with other data that it has collected independently and has associated to a User’s Device. This other data may include demographics data (age range, gender), or data about interests (e.g. interest in automobile, or interest in athletic apparel). These service providers may combine usage data with this other data to produce reports regarding the use of our Services, such as how many users of a certain gender, or in a certain age range, visit specific pages or areas of our Services. These reports do not contain specific information regarding a specific User. They are produced by using only aggregated data, and only present statistical data. Each such report does not recognize a specific individual. You may opt out from sending navigation information about your visit to our website to Google Analytics by using the Google Analytics Opt-out page.
Some cookies are managed by us, and others by our service providers. These cookies are used for a variety of purposes.
Some cookies enable services that you have specifically asked for. Other cookies are used to remember the choices you made (for example, the size of the font, or the language you prefer) in order to make it easier for you to use our Services when you return. Other cookies collect information about how Users use the Services. Finally, other cookies are used to collect information about your perceived interests so that we can arrange for advertisements regarding these products or services to display in the Services or other sites that you visit on the Internet. This way, when you visit other sites that display advertisements, the advertisements that you see are more relevant to you.
These cookies are not linked to any contact information or identifying information, thus cookies do not tell us who you are, but they may identify your Device.
If you have any other questions about cookies and other technologies, please visit http://www.allaboutcookies.org/ or http://networkadvertising.org/ or contact us as indicated in the How to contact us section.
v. Advertising Cookies: We use advertising and retargeting cookies from the following third-parties to present you with advertising on other websites based on your interaction on our Sites and other websites:
c. How We Use the Personal Information We Collect
i. For Marketing and Business Development: When not precluded from doing so, we may use the Personal Information we have received from you or about you to solicit feedback from you, including through surveys or to send you marketing communications and promotional material about other products and services.
ii. Analytics: We may aggregate (or have third parties aggregate) the Personal Information we collect from Users, Subscribers and Clients together with usage data in order to obtain statistical information. We use aggregated Personal Information to understand how the Services are used, for research or product development, for example, to measure interest in, or monitor the use of any content, product, services or promotions that we provide through the Services, to improve the content, products, services or promotions, and for the technical administration of the Services.
iii. Investigations: We may use your Personal Information to prevent or investigate potentially prohibited or illegal activities, claims regarding Users, Subscribers or Clients.
iv. To Defend or Enforce our Rights: We may use or share your Personal Information to establish or exercise our legal rights; to respond to a breach of our Terms of Service; when we believe it is appropriate to protect the Services, our property and rights or those of a third party; to protect ourselves and the security and safety of our company, our Users, Subscribers, Clients or others; and to investigate, prevent, take action against, or stop any fraudulent, illegal, unethical, or legally actionable activity, in connection with the Services.
d. Who We Share Your Personal Information With
i. Business Partners: We may share Personal Information with affiliates of Reach150 as well as with our business partners.
ii. Our Workforce: Reach150 employees and independent contractors need to have access to the Personal Information we have collected about you to carry out their duties and obligations, such as to provide customer support, respond to inquiries, or correct an error. Only the minimum amount of Personal Information will be made available to them as needed, and in accordance with their responsibilities. They are required to ensure at all times the confidentiality and security of your Personal Information.
iii. Service Providers: We may engage certain third parties to perform services including, without limitation, hosting and maintenance, customer relationship, storage, database management, collection, fraud prevention, business analytics, chat, website analytics, website optimization, lead scoring, retargeting, direct marketing campaign, or similar services. We use an outside credit card processing company to bill users for goods and services and an email service provider to send emails to you on our behalf.
We will share your Personal Information with these third parties, but only to the extent that this Personal Information is necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
iv. If Reach150 is Sold or Goes Bankrupt: If any or all of the assets of Reach150 are acquired by, or if Reach150 merges with, another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of your Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, and we may transfer your Personal Information after the transaction has been consummated, so that the successor entity can continue providing the Services. If the recipient of the Personal Information has practices regarding Personal Information that do not substantially meet the substance of this Privacy Notice, you will be given the opportunity not to continue to use the Services and to have your Personal Information deleted.
v. Compliance with Laws and Third Party Requests: Reach150 cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any Personal Information about you to government or law enforcement officials or private parties as we, in our reasonable discretion, believe necessary or appropriate to respond to and defend against legal claims, respond to legal process (including a facially valid subpoena, warrant, court order or other legal process), or otherwise as required by law.
vi. Please note that we may not be able to notify you of a request for the disclosure of your Information as described above, either because it might be prohibited by law, or because doing so would jeopardize an investigation of illegal or fraudulent activity, or because we do not have your contact information.
7. User’s rights: We want our Subscribers and Clients to enjoy their visit to and use of the Services, and we respect their privacy. To this end, we provide numerous privacy choices.
While we have tried to provide all tools necessary so that Subscribers and Clients can manage their interaction with us, as listed below, you may prefer to interact directly with us. In this case, be aware that you can contact us at any time with your questions or requests for assistance. Please refer to the How to contact us section.
a. Right to Access Your Personal Information: You may access the Personal Information we have regarding you by contacting us as indicated in the How to Contact Us. In addition, you may obtain a copy (electronic or physical) of this information by requesting it in the same manner. If the requested Personal Information is no longer available or cannot be produced using reasonably commercial means, or if the burden or expense of accessing it would be disproportionate to the risks to you, we may deny your request and we will provide you an explanation for this denial.
b. Right to Amend, Correct, Substitute or Delete Personal Information
You may request that we amend, correct, substitute, or delete information maintained and/or stored by us if you believe that it is not accurate, timely, complete, relevant, or necessary to accomplish our services. To do so, please let us know what you need, by contacting us as indicated in the How to Contact Us. If the requested Personal Information is no longer available or cannot be modified or deleted using reasonably commercial means, or if the burden or expense of deleting it would be disproportionate to the risks to you, we may deny your request and we will provide you an explanation for this denial.
c. Right to Block Marketing Communications: If you no longer wish to receive marketing information or communications from us or from our affiliate entities, you must contact us at email@example.com.
8. California Disclosures
a. Do Not Track: California law requires that website operators disclose how they respond to a “Do Not Track” signal. However, because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signals, if any, that we might receive from browsers. We will continue to work with the online industry to define a common understanding of how to treat Do Not Track signals.
To learn more about online behavioral advertising, and/or to opt-out of this type of advertising, please visit the Network Advertising Initiative website or theDigital Advertising Alliance website. You can also contact us as indicated in the How to Contact Us section.
We do not share with these third parties any Personal Information that would readily identify you, such as an email address, but these third parties may have access to information about your Device, such as an IP or MAC address. We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests.
9. Security: Reach150 employs administrative, physical, and electronic measures designed to protect your information from unauthorized access, loss, misuse, disclosure, alteration, and destruction.
When we need to transfer Personal Information out of our firewall, we use industry-standard technological means to protect your information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, please remember that no security system on the Internet is perfect.
10. Limitation of Liability: We exercise reasonable efforts to safeguard the security and confidentiality of your information; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. We will not be liable for unauthorized disclosure of your Personal Information that occurs through no fault of Reach150 including, but not limited to, errors in transmission, uses of your data by a third party, your failure to comply with your security obligations, and the unauthorized acts of Reach150’s employees.
11. Links to Other Websites: This Privacy Notice addresses only the use and disclosure of Personal Information that we collect from you through the Services, through our interaction with you or from interaction with our business partners. The Services may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data, or solicit personal information from you. They follow their own rules regarding the use or disclosure of the personal information you submit to them. We recommend that you to read the privacy policies or statements of these other websites.
12. Disputes: If you have any concerns or claims with respect to our Privacy Notice, please contact us as indicated in the How to Contact Us section. We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of your information.
If the complaint or dispute cannot be resolved through our internal process, or Reach150 does not adequately respond to your question, the parties agree to resolve the dispute solely by binding arbitration. The arbitration will be conducted in Santa Clara County, California under the auspices of JAMS by an arbitrator selected by both parties within ten (10) days after either party has notified the other in writing that it desires that the dispute between them be settled by arbitration. In the event the parties cannot agree on an arbitrator within such ten (10) day period, JAMS shall select an arbitrator and inform both parties in writing of such arbitrator's name and address within five (5) days after the end of such ten (10) day period. Each party shall pay its own expenses associated with such arbitration, including the expense of any arbitrator selected by such party, if applicable, and the parties share equally the expenses of a jointly selected arbitrator or arbitrator selected by JAMS. The decision of the arbitrator shall be binding upon the parties and judgment in accordance with that decision may be entered in any court having jurisdiction thereover. Punitive damages shall not be awarded.
13. Updates: This Privacy Notice may be updated from time to time in order to reflect changes in our practices. We will notify you of any material changes by posting the new Privacy Notice on the Services, and will obtain the necessary consents as may be required under applicable law if we seek to collect, use or disclose personal data for purposes other than those for which consent has been obtained.
Except as stated above, all changes will apply to the information that we have are already collected, and to information that is collected after the effective date of the revised Notice. If any proposed change is unacceptable to you, you will have the right to ask for the deletion of your information. You are advised to consult this Privacy Notice regularly for any changes.
14. How to Contact Us: If you have any questions, comments, concerns, complaints or claims with respect to the website, other users of the Services, if your account has been compromised by a hacker or scammer, if another user is abusing, harassing, or stalking you, if you find that certain content displayed on the Services is inappropriate or prohibited by this Privacy Notice, or if you have any other concern, please contact us as indicated below. We will investigate and attempt to resolve the matter.
If you have any questions regarding this Privacy Notice or the Services, please contact us by email at firstname.lastname@example.org, or by mail at Reach150, 289 S. San Antonio Rd, Suite 200, Los Altos, CA 94022.