Privacy Notice

Effective: January 1, 2025

Reflexive LLC (“Reflexive”) provides data protection and cybersecurity consulting services. We take seriously our responsibility to protect your personal information (including "personal data" as defined by applicable data protection law) in accordance with applicable laws and regulations.

This Privacy Notice describes how Reflexive collects, uses, and discloses personal information when you interact with us, including online and through other means.

UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time-to-time. If we make any material changes, we will revise the date at the top of this Privacy Notice and, in some cases, may provide you with additional notice. We encourage you to review our Privacy Notice whenever you visit https://getreflexive.com (the “Site”) or otherwise interact with us to stay informed about our privacy practices.

COLLECTION OF PERSONAL INFORMATION
We may collect or obtain the following categories of personal information through this Site or by other means, including through any email message, webform, chat box, survey, social media page, event, or other communication or correspondence:

Contact Data: Name, phone number, e-mail, mailing address, and country
Transaction Data: Billing and payment information and transaction details
Message Data: Messages and correspondences, including email, web chat, or web form messages, and any personal information therein
Telephone/Web Meeting Recordings: Telephone/web meeting recordings, including voice and video, when you connect with us or over the telephone or via web-based meetings
Survey Data: Information you may provide in a survey, poll, or the like, including your responses
Interaction Data: Information collected when you access our website, including (1) IP addresses, referral URLs, date and time, and crash data (collectively, "Log Data"); (2) information about your device, including type of device, operating system, application IDs, and unique device identifiers (collectively, "Device Data"); (3) information about your browser type and settings, language preferences, and cookie data (collectively, "Browser Data"); and (4) approximate location (e.g., course geolocation), information about your time of access, session and duration, and your interactions with the Site (collectively, "Analytics Data").
Social Media Data: Information and messages shared with us through our social media pages, including your associated profile information
Referral Data: Information about you provided to us from other sources, including your email address
Recruiting and Job Applicant Data: Information concerning your recruitment and/or application for employment, including resume data, references, education records, certificates, biodemographic information (e.g., race, ethnicity, gender, sexual orientation, nationality, veteran status), trade union membership, citizenship and residency information, SSN, and reputational information, as may be provided by you or through a recruiter, staffing agency, or other referring party, and background check information, as may be provided by you or supplied by a background verification service and/or consumer reporting agencies

USES OF PERSONAL INFORMATION
We may use personal information collected about you for the following purposes:

Presenting the Site and its contents to you;
Processing transactions for services;
Delivering services to you and those associated with you;
Operating, administering, and improving our business;
Corporate transactions;
Communicating by email, phone, and other means;
Business insights and product development;
Sales and marketing;
Recruiting and processing applications for employment;
Detecting and preventing abuse and security threats;
Complying with legal and regulatory obligations;
Providing you with information that you request from us;
Notifying you about changes to the Site, our Terms, or this Privacy Notice; and
For any other purpose that you may direct or consent.

COOKIES, "DO NOT TRACK" SIGNALS, AND UNIVERSAL OPT-OUT REQUESTS

Our website may use cookies (small data files placed on your computer), pixels, web beacons, and other third party technologies to track user interactions, target advertising, and personalize your browsing experience, which may involve the collection and disclosure of your information to third parties. For example, we may use Google Analytics to log and analyze website visitor data. While we have taken steps to limit the amount of data obtained by Google, you can learn how Google may use this data here: www.google.com/policies/privacy/partners/ To the extent that third parties receive data or personal information about you, the privacy policies of such third party providers, including Google and Wix (our website hosting provider), will govern how they may use and disclose your personal information.

To the extent available to you, you may adjust your cookie preferences when you visit our website through the cookie banner at the bottom of our website. Please note that your choices may need to be reestablished if you access our website from a new browser or device or clear your web browser's cookie history (cache).

Do Not Track (“DNT”) is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. At this time, our website is not configured to respond to DNT signals.

Under California's "Shine the Light" law, we do not share personal information, as defined by Cal. Civ. Code § 1798.83, with third parties for their direct marketing purposes.

Our website may not recognize universal opt-out requests configured through your web browser, such as Global Privacy Control.

DISCLOSURE OF PERSONAL INFORMATION
To the extent permitted by applicable law, we may disclose the following categories of personal information and Interaction Data for the purposes described below:

Subsidiaries and Affiliates: We may disclose personal information and Interaction Data to our subsidiaries and affiliates, including Relic Law PLLC, to operate and improve our business and for sales and marketing purposes
Business Services Providers: We may disclose personal information and Interaction Data to our IT services providers and others within our vendor base to operate the Site and our business and to process and fulfil sales orders
Specialized Services Providers: We may disclose personal information and Interaction Data to specialized services providers, including contractors, business and marketing consultants, security consultants, auditors, information services providers, and professional advisors
Advertising Services and Networks: We may disclose personal information and Interaction Data to our advertising services providers, advertising networks, and social media platforms to deliver advertising and promote our products and brands
Recruiting Services Providers: We may disclose personal information to recruiting and staffing service providers to identify job candidates and facilitate the evaluation and processing of applications for employment
Government and Legal Process: We may disclose personal information and Interaction Data to public authorities and third parties as may be required by applicable law, regulation, or legal process
Corporate Transaction: We may disclose personal information and Interaction Data as part of a corporate transaction e.g., to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, whether as a going concern or as a part of a bankruptcy, liquidation or similar proceeding

INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Your personal information may be transferred to countries other than the country from which it originated. Such countries may have different or less protective privacy and data protection laws than the originating country. Where required, we will ensure that international transfers of personal information are subject to an appropriate transfer mechanism or consent.

PRIVACY RIGHTS OF EUROPEAN DATA SUBJECTS
Under the EU General Data Protection Regulation (“GDPR”), Data Protection Act 2018 (“UK GDPR”), and Swiss Federal Act on Data Protection, as amended (“FADP”) (collectively, the “European Data Protection Laws”), we may process your personal data on the following lawful basis:

As necessary to perform a contract with you;
As necessary for our legitimate interests or that of a third party, except where overridden by your interests or fundamental rights and freedoms;
As necessary for compliance with a legal obligation to which we are subject; and
Upon your consent, where applicable.

European data subjects are entitled to certain data protection rights, such as, the right to:

Withdraw Consent. If processing is on the basis of consent, you may have the right to withdraw consent to our processing at any time.
Access and Rectification. You may have the right to access, correct, and update your personal information.
Deletion/Erasure. You may have the “right to be forgotten” through the erasure or deletion of your personal information.
Portability. You may have the right to move, copy, and/or transfer certain Personal Information from our service to another service.
Stop Processing. If processing is on the basis of legitimate interests, you may have the right to object to the processing of your personal information and to ask us to restrict the processing of your personal information, subject to certain limitations.
Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your Personal Information. Contact details for EU, UK, and Swiss data protection authorities, respectively, can be found at:

Exercising your rights under the European Data Protection Laws
You, or an authorized agent, may exercise your rights by submitting a request to Privacy Inquiries.

We respond to and process requests promptly and within the timeframes required by the European Data Protection Laws, typically, this means within 30 days from receipt. Please note that all requests are subject to proper prior verification before processing. If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Transfer of European personal data
Your personal information may be transferred to third countries, including to the United States. By providing personal data to us, you consent to the transfer of your personal data to such third countries. Where applicable, we have adopted appropriate transfer mechanisms to safeguard the transfer of your personal data in accordance with applicable laws, including, the EU Standard Contractual Clauses and UK International Data Transfer Addendum.

Retention of European personal data
We retain personal information for a period commensurate with the purposes for which the personal information was collected or obtained. The criteria used to determine the retention of personal information includes any time necessary for legal and compliance purposes. Personal information may be retained in archival format (e.g., data backups) beyond its retention period.

PRIVACY RIGHTS OF CANADIAN RESIDENTS
Under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Provincial Privacy Acts (collectively, the “Canadian Privacy Laws”), and their respective amendments and implementing regulations, Canadian residents may be entitled to certain privacy rights. If you are a Canadian resident, subject to certain limitations, you have the following rights concerning your Personal Information:

Openness and Transparency. You may have the right to know the personal information we collect about you and the purposes for its collection.
Access. You may have the right to access personal information we maintain about you, subject to certain exceptions.
Correction. You may have the right to correct inaccuracies in personal information we maintain about you.
Deletion. You may have the right to request that we delete personal information we have collected or maintain about you.
De-indexing. You may have the right to request your personal information be “de-indexed” from certain types of distribution.
Withdraw Consent. You may have the right to withdraw consent to our use of your personal information, subject to certain exceptions.

Exercising your rights under the Canadian privacy laws
You, or an authorized agent, may exercise your rights by submitting a request to Privacy Inquiries.

We respond to and process requests promptly and within the timeframes required by the Canadian Privacy Laws. Please note that all requests are subject to proper prior verification before processing. If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.

Transfer of Canadian personal information
Your personal information may be transferred to third countries where an adequate level of data protection can be ensured. By providing personal information to us, you consent to the transfer of your personal information to such third countries.

THIRD-PARTY SITES, BLOGS, AND SOCIAL MEDIA
Our Site may include links to other websites, social media widgets, such as the Facebook “Follow Us” button, and other interactive features, blogs, and videos hosted by third parties whose privacy practices may differ from our own. When you use a link to go from our Site to an unaffiliated website, or interact with any such features, the privacy policies of those respective third parties will apply to the processing of your personal information.

USE BY MINORS
We do not knowingly collect personal information from or about minors. Minors should not use the Site or otherwise provide us their personal information. If we learn that we have collected or received personal information from a minor without parental consent, we will delete that information.

SECURITY OF PERSONAL INFORMATION
Taking into account the nature and scope of the processing and the particular risks to personal information, we utilize reasonable technical and organizational measures to help protect personal information.

PRIVACY INQUIRIES
For inquiries concerning this Privacy Notice, you may contact us at Privacy Inquiries.

Last revised: December 27, 2024 at 01:10 UTC.