Reelables, Inc. and its subsidiary, Reelables Europe, Ltd. (“Company,”we,” “us” or “our”) are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our website, located at www.reelables.com and any other website owned and operated by Company, any company hardware devices (“Hardware”), our mobile application (“App(s)”) (collectively, the “Site”) and online services (“Services”).

Who We Are

For the purpose of applicable data protection legislation, the data controller of your personal data is Reelables, Inc. at 814 Mission St., 6th Floor, San Francisco, CA, 94103, USA.

Subject to the next paragraph, we ask that you not send us, and you do not disclose special categories of data as defined in the General Data Protection Regulation: 2018 (information related to racial or ethnic origin, political opinions, religious or physiological beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership or data concerning data subject’s sex life or sexual orientation) (“Special Categories of Personal Data”) on or through Google the Site or Services or otherwise to us.

Must Read Sections

We draw your attention in particular to the sections titled “A Note to Users Outside of the United States” and “Your Rights.”

Changes to Privacy Policy

We will post any modifications or changes to the Privacy Policy on our Site and Services. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address you provided to us and/or posting notice of the changes on our Site prior to such change(s) taking effect.

Questions, Contacting Company, Reporting Violations

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us:

Reelables Europe, Ltd.Attn: Legal Team

14 Windsor Street, London, N1 8QG, UK. 

[email protected]

Complaints

We are committed to resolving any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at [email protected]. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention; however, if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.

A Note to Users within the EU

Your data, including Personal Data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.

Types of Data We Collect

We collect information about you in a range of forms, including Personal Data. As used in this Privacy Policy, “Personal Data” is as defined in the General Data Protection Regulation: 2018 as any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Anonymous Data” means data that does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or is no longer identifiable. Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Information You Provide to Us

• We collect information that you enter on our Site or otherwise provide to us, including when you make a purchase from us, request information, submit a review, or otherwise contact us. The type of information that we collect from you depends on your interaction with our Site and your use of our Services, but may include your: full name, mailing address, billing address, telephone number, email address, payment information (for purchases), location data, and any other information that you choose to provide. We may collect Personal Data from you, such as your first and last name, email and mail addresses, and password when you create an account to log in to our network (“Account”).
• If you use our Services on your mobile device, including through our App(s), we may collect your phone number and the unique device id number.
• If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either reinstall the App(s) or deactivate Bluetooth on your mobile device.
• Our Site lets you store preferences like how your content is displayed, your location, safe search settings, and favorite widgets. We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.
• When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
• Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
• Mobile Services. We may also collect information from your mobile device if you have downloaded our App(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the App(s), and information about the type of device you use. In addition, in the event our App(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual. Note, we collect information about the location of your device but no personal information is associated with that information. In addition, if you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use our mobile application, we may collect and use your geolocation information.
• If you make a purchase from us, you will be required to provide a credit or debit card number and related financial information (such as CVV, expiration date, and billing address), or other payment information (such as via PayPal or Apple Pay), depending on the form of payment you choose. We have implemented commercially reasonable precautions regarding the information we collect to protect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, in accordance with industry best practices and applicable laws, including encryption both during transmission and at rest.
• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• When you participate in one of our surveys, we may collect additional profile information.
• We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via email or our mobile app regarding support for the Services.

Information We Collect Automatically

We automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site and or use our Services; and the referring URL, or the webpage that led you to our Site. We use this information to enhance your online shopping experience and to enable us to provide you with an easier and more personalized level of service. On some of our Sites, we may combine this information with personal information that you have provided to us. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Cookies and Other Tracking Mechanisms

1. What are cookies?

We may collect information using “cookies.” Cookies are alphanumeric identifiers that are transferred to your computer’s hard drive through your web browser for record-keeping purposes. There are two types of cookies:

   a) Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Site.

   b) Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity and to display advertising both on our Site and on third-party sites.

2. Cookies We Use

We use two broad categories of cookies: (1) first-party cookies, served directly by use to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site or Services and (2) third-party cookies, which are served by service providers on our Site or Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites. Specifically, our Site and/or Services use the following types of cookies for the purposes set out below.

• Type of Cookies

Essential Cookies: These cookies are essential to provide you with services available through our Site and/or Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and/or Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies: These cookies allow our Site and/or Services to remember choices you make when you use our Site and/or Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Site and/or Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site and/or Services.

Analytics and Performance Cookies: These cookies are used to collect information about traffic to our Site and/or Services and how users use our Site and/or Services. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. It includes the number of visitors to our Site and/or Services, the websites that referred them to our Site and/or Services, the pages they visited on our Site and/or Services, what time of day they visited our Site and/or Services, whether they have visited our Site and/or Services before, and other similar information.

• We use this information to help operate our Site and/or Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Site and/or Services.
• We use Google Analytics and other third-party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site and/or Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
• You can prevent the use of Google Analytics relating to your use of our Site and/or Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.

Targeted and advertising cookies: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third-party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.

You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices, http://www.aboutads.info/choices or http://www.networkadvertising.org. If you choose to remove targeted or advertising cookies, you will still see advertisements but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral cookies are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

3. Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The “help” portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function, such as the shopping cart.

Collection of Data by Third-Party Advertisers

1. Third Party Advertisers

We use third parties such as network advertisers and others to assist us in advertising, including displaying our advertisements on other websites and through social media platforms; we also may use network advertisers, third parties that display advertisements based on your visits to our Site as well as other websites, and other third parties to assist us in identifying relevant advertising on our Site. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Site and our Services, as well as anonymous information about visitors to our Site and users of our service.

2. Do Not Track Signals

Our systems do not honor browser do-not-track requests, but several of these third parties enable you to opt out of targeted advertising practices. You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”), and in Europe, the European Interaction Digital Advertising Alliance (“EIDAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI, DAA and EIDAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI),www.aboutads.info/choices (DAA), and www.youronlinechoices.com.

3. Effect of Opting Out of Member Networks

Opting out of one or more NAI, EIDAA or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI, EIDAA or DAA opt-out may no longer be effective. Additional information is available on NAI’s, EIDAA’s and DAA’s websites accessible by the above links.

4. Analytics Services and Interest-Based Advertising

In order to serve offers and advertisements that may interest you, we may display targeted advertisements on the Site or Services or other digital applications or properties in connection with our content based on information provided to us by our users and information provided to us by third parties that they have independently collected. We do not provide Personal Data to advertisers when you interact with an advertisement. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site. This includes third party analytics services, including but not limited to Google Analytics (“Analytics Services”), that we engage to help analyze how users use the Site, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at [email protected]. We may also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests. If you don’t want to take advantage of these services, you may be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/.

5. Location Information

We collect your location information to make a map available to link your device to your location. If you do not want this information collected by us, you can disable Location Services on your phone.

How We Use Your Information

1. Why do we need your Personal Data?

We will only process your Personal Data in accordance with applicable data protection and privacy laws. We need certain Personal Data in order to provide you with access to the Site and/or Services. If you created a profile/registered with us, you will have been asked to check a tick box indicating your agreement to provide this data in order to access our services, purchase our products, view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your Personal Data in line with this policy, please do not use our Site and/or Services.

2. General Use

In general, Personal Data you submit to us is used either to respond to requests that you make or to aid us in serving you better. We use your Personal Data in the following ways:

• facilitate the creation of and secure your Account on our network;
• identify you as a user in our system;
• provide improved administration of our Site and Services;
• provide the Services and support you request;
• improve the quality of experience when you interact with our Site and Services;
• send you a welcome email to verify ownership of the email address provided when your Account was created;
• send you administrative email notifications, such as security or support and maintenance advisories;
• respond to your inquiries related to employment opportunities or other requests;
• make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback; and
• send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.

3. User Testimonials and Feedback

We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. If users make any comments on a blog or forum associated with our Site, they should be aware that any Personal Data they submit there can be read, collected, or used by other users of these forums, and could be used to send the users unsolicited messages. We are not responsible for the personally identifiable information users choose to submit in these blogs and forums.

4. Creation of Anonymous Data Records

We may create Anonymous Data records from Personal Data by excluding information (such as user’s names) that makes the data personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

How We Share Collected Data

1. Third Party Service Providers

We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate the creation of accounts; to provide technical support; and/or to provide other services to the Company.

2. Corporate Restructuring

We may share some or all of your Personal Data in connection with or during the negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving a sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

3. Other Disclosures

Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

4. Third Party Websites

Our Site may contain links to third-party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

5. Your Choices Regarding Your Personal Data

You have several choices regarding the use of your information on our Service:

   a) Email Communications. We will periodically send you emails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.

   b)Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know by contacting us at [email protected]

   c) Changing or Deleting Your Personal Data. You may review, update, correct or delete the Personal Data in your user account (including any imported contacts) by contacting us. If you completely delete all of your Personal Data, then your user account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

   d) Applications. You can stop all collection of information by the App(s) by uninstalling the App(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You may at any time opt-out from further allowing us to have access to your location data by disabling item history within the App.

6. Your Rights

   a) Opt-out. You may contact us anytime to opt-out of (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your Personal Data that we may carry out beyond the original purpose; or (v) the transfer of your Personal Data outside the EEA. Please note that your use of some of the Site and/or Services may be ineffective upon opt-out.

   b) Access. You may access the Personal Data we hold about you at any time by contacting us directly.

   c) Amend. You can also contact us to update or correct any inaccuracies in your Personal Data.

   d) Move. Your Personal Data is portable – i.e. you have the flexibility to move your data to other service providers as you wish.

   e) Erase and forget. In certain situations, for example, when the Personal Data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

You may contact us via email at [email protected] any time for any other questions you may have about your personal data and our use of such personal data.

If you wish to exercise any of these rights, please contact us using the details in the section titled Questions; Contacting Company; Reporting Violations above. In your request, please make clear: what Personal Data is concerned, and (ii) which of the above rights you would enforce. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your requests as soon as reasonably practicable, and in any event, within one month of your request. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Retention of Your Personal Data

We will only retain your personal data as long as reasonably required for you to use the Site/Application(s) and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes).