Reflection IT Apps Privacy Policy

Last updated: June-29-2023

Reflection IT BV ("us", "we", or "our") is a game development studio that creates applications, websites, and other digital properties (collectively “Properties”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Properties, and the choices you have associated with that data.

We use your data to provide and improve our Properties. By using these, you agree to the collection and use of information in accordance with this policy.

Definitions

Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data: Usage Data is data collected automatically either generated by the use of our Properties or from our technical infrastructure (for example, the duration of game session or delivery of an advertisement).

Cookies: Cookies are small files stored on your device (computer or mobile device).

Data Controller: Data Controller means the natural or legal person or entity who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person or entity who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively and to operate our Properties.

Data Subject (or User): Data Subject is any living individual who is using our Properties and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Properties.

Types of Data Collected

Personal and Usage Data

While using our Properties, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data
• IP Address

We may collect information that your device or browser sends us whenever you visit or access our Properties, or when you interact with a Property ("Usage Data").

This data may include, but is not limited to, information such as your computer's Internet Protocol address (e.g. IP address), operating system version, browser type, browser version, the Property you interact with, the pages that you visit, the time and date of your visit to those pages or Properties, the time spent on those pages or Properties, unique device identifiers, and other diagnostic data. This data may also be combined and linked with data from other sources, devices, and Properties that you use.

Cookies and Similar Tracking Technology Data

We use cookies and similar tracking technologies, including statistical or other identification methods, to track the activity and to provide our Properties to you.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as device identifiers, beacons, tags and scripts to collect and track information and to improve, analyze, and deliver our Properties.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Properties.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Properties.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
• Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests. Opting out of interest-based advertising or changing the privacy settings in your browser may reduce the relevancy of the ads you see, but not the number or frequency of ads. To learn more and to opt out of interest-based advertising, as delivered by partners of ours who participate in the following organizations, please follow the instructions at:
  • Digital Advertising Alliance - https://optout.aboutads.info/?c=2&lang=EN
  • Network Advertising Initiative - https://www.networkadvertising.org
  • European Interactive Digital Advertising Alliance - https://www.youronlinechoices.eu/

Use of Data

We use the collected data for various purposes:

• To provide and maintain our Properties.
• To provide advertising, including but not limited to interest-based, contextual, and cross-device or application ad targeting.
• To notify you about changes to our Properties.
• To allow you to participate in interactive features of our Properties when you choose to do so.
• To provide customer support.
• To gather analysis or valuable information so that we can improve our Properties.
• To monitor the usage of our Properties.
• To detect, prevent and address technical, security, or fraud issues.

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA) or the United Kingdom, our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We or one of our Service Providers may collect and/or process your Personal Data because:

• We need to perform a contract with you.
• You have given us, as a Data Controller or Data Processor, consent in compliance with applicable laws to do so.
• The processing is in our legitimate interest, except where such interest is overridden by your data protection interests or fundamental rights or freedoms.
• To comply with the law.

IAB Europe Transparency & Consent Framework

We participate in the IAB Europe Transparency & Consent Framework and comply with its Specifications and Policies. We use the Consent Management Platform provided by Consent Desk LLC.

Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Properties, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation.
• To protect and defend our rights or property.
• To prevent or investigate possible wrongdoing in connection with our Properties.
• To protect the personal safety of users of our Properties or the public.
• To protect against legal liability.

Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

If you are a resident of California, you have the following rights:

• Right to Know and Access Information: You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To make such a request, please contact us.
• Right to Delete: You have the right to request the deletion of your personal information. To make such a request, please contact us.
• Right to Opt-Out of Sale of Personal Information: If we sell personal information, you have the right to opt-out. If we do not sell personal information, we will state this clearly. If applicable, a link titled "Do Not Sell My Personal Information" will be provided on our website.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA or CPRA rights.
• Minors Under 16 Years of Age: If we have actual knowledge that we collect or maintain the personal information of minors under 16 years of age, we will provide specific protections.

For more information on how to exercise these rights, please contact us.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Rights under the Colorado Privacy Act (CPA)

If you are a resident of Colorado, you have the following rights under the CPA:

• Right to Access, Correct, or Delete: You have the right to access your personal data, to request that we correct inaccurate personal data, and to delete your personal data under certain circumstances. To exercise these rights, please contact us.
• Right to Data Portability: You have the right to receive your personal data in a portable and readily usable format.
• Right to Opt-Out: You have the right to opt-out of the processing of your personal data for targeted advertising purposes, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CPA rights.

Your Rights Under the Virginia Consumer Data Protection Act (VCDPA)

If you are a resident of Virginia, you have the following rights:

• The right to access the personal data we have collected about you during the past 12 months, including the categories of personal data; the categories of sources; the business or commercial purpose; the categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about you.
• The right to delete personal data we have collected from you, subject to certain exceptions in the VCDPA.
• The right to opt out of our sale or sharing of your personal data.
• The right to not be discriminated against for exercising any of your rights under the VCDPA.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

Your Rights Under the Connecticut Data Privacy Act (CTDPA)

If you are a resident of Connecticut:

• You have the right to request the specific pieces of personal data we have collected about you in the past 12 months, including the categories of personal data, the sources from which the personal data was collected, the purposes for collecting or selling the personal data, and the third parties with whom we share personal data.
• You have the right to request deletion of your personal data.
• You have the right to opt out of the sale or sharing of your personal data.
• You will not be discriminated against for exercising your privacy rights under the CTDPA.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

Your Rights Under the Utah Consumer Privacy Act (UCPA)

If you are a resident of Utah:

• You have the right to request access to the personal data we have collected about you in the past 12 months, including the categories of personal data, the sources of personal data, the business or commercial purposes for collecting the personal data, the categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about you.
• You have the right to request deletion of your personal data.
• You have the right to opt out of the sale or sharing of your personal data.
• You will not be discriminated against for exercising your privacy rights under the UCPA.

To exercise any of these rights, please contact us using the contact details provided in this policy. We may ask you to verify your identity before responding to your requests.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA) or the United Kingdom, you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA) or the United Kingdom.

Service Providers

We may employ third party companies and individuals to facilitate the delivery and operations of our Properties ("Service Providers"), provide the Properties on our behalf, process Personal Data, perform Property -related services or assist us in analyzing how our Properties are used.

We may provide these third parties with access to your Personal Data only to perform these tasks on our behalf as a Data Processor and are obligated not to disclose or use it for any other purpose.

These third parties may also collect data directly from you for their own use and subject to their own privacy policies.

Other Sites and Digital Properties

Our Properties may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children's Privacy

Our Properties do not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a notice on our Properties, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Content policy

Our Properties will not contain any indecent, obscene or pornographic material, hate speech, subject matter that a reasonable person would consider highly objectionable, any material which improperly references illegal activities. It can contain third party advertisments which content we can not control. Notwithstanding the foregoing, we will have no liability for any claim when third parties uses content in our Properties, as described above.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: support@reflectionit.nl

By mail:
Reflection IT BV
Polderweg 52
5721 JG  Asten
Netherlands

To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO) who is contactable using the details provided above.