Privacy Policy

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data: such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
• Account data: such as the username and password that you may set to establish an online account on the Service and any other information that you add to your account profile.
• Communications data: based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Marketing data: such as your preferences for receiving our marketing communications and details about your engagement with them.
• Payment and transactional data: needed to complete your orders on or through the Service (including payment card information and billing information) and your purchase history.
• Other data: not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Public sources: such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources: such as data providers, social media platforms and data licensors.
• Our affiliate partners: such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
• Marketing partners: such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data: such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data: such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Location data: when you authorize the Service to access your device’s location.
• Communication interaction data: such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies: which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies: like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons: also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• Provide, operate and improve the Service and our business;
• Personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
• Establish and maintain your user account on the Service;
• Facilitate your invitations to contacts who you want to invite to join the Service;
• Facilitate social features of the Service, such as by identifying and suggesting connections with other users of the Service and providing chat or messaging functionality;
• Enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• Communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• Communicate with you about events or contests in which you participate;
• Understand your needs and interests, and personalize your experience with the Service and our communications; and
• Provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

• As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect.
• We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you.
• We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing: We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising: Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising.
• We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the Service; and
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Affiliates: Our corporate parent, subsidiaries, and affiliates.
• Service providers: Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
• Payment processors: Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Shopify, who may use your payment data in accordance with that payment processor’s Privacy Policy, for example, https://www.shopify.com/legal/privacy.
• Advertising partners: Third-party advertising companies for the interest-based advertising purposes described above.
• Professional advisors: Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others: Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Business transferees: We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Reach-Social.io, financing of Reach-Social.io, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Reach-Social.io as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

In this section, we describe the rights and choices available to all users. Users who are located Europe can find additional information about their rights below.

• Access or update your information: If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
• Opt-out of communications: You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies: For information about cookies employed by the Service and how to control them, see our Cookie Notice.
• Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• Declining to provide information: We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us.

• These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party.
• We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.
• We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

The Service is not intended for use by anyone under 18 years of age.

• If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us.
• If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

We reserve the right to modify this Privacy Policy at any time.

• If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means.
• Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).
• In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

• Email: privacy@reach-social.io
• Mail: Reach-Social.io, Inc. 1874 Silverado Trl. Napa, CA. 94558, USA

General

Where this Notice to European users applies: The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller.

Personal information: References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.

Controller: Reach-Social.io is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the How to contact us section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

• Where we need to process your personal information to deliver our Services to you (including our Site)(“Contractual Necessity”)..
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below(“:Legitimate Interests”).
• Where we need to comply with a legal or regulatory obligation(“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the Purpose in question(“Consent”).

Specific Legal Bases by Purpose. We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see How we use your personal information above.

Service delivery and operations

• Contact data
• Account data
• Communication data
• Payment and transactional data
• Contractual Necessity

• (Contact data, Account data, Communication data, Payment and transactional data): Legal basis is Contractual Necessity.
• Research and development (Any and all data types relevant in the circumstances): Legal basis is Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.
• Direct marketing (Contact data, Account data, Payment and transactional data, Communication data, Marketing data): Legal basis is Legitimate Interests (promoting our operations and goals as an organisation and sending marketing communications for that purpose) or Consent (where required by applicable laws).
• Compliance and protection (Any and all data types relevant in the circumstances): Legal basis is Compliance with Law or Legitimate interest (participating in legal process, cooperating with authorities, enforcement of rights, protecting safety/property).
• Further uses: The original legal basis relied upon if compatible, or Consent if not compatible.

Research and development

• Any and all data types relevant in the circumstances Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.

Direct marketing

• Contact data
• Account data
• Communication data
• Payment and transactional data
• Communication data
• Marketing data

Legitimate Interests.

• We have a legitimate interest in promoting our operations and goals as an organisation and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.

Compliance and protection

• Any and all data types relevant in the circumstances
• Compliance with Law.

Legitimate interest

• Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities.
• We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Further uses

• Any and all data types relevant in the circumstances.
• The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.
• We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

• When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other Information

• No obligation to provide personal information: You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.
• No sensitive personal information: We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.
• No Automated Decision-Making and Profiling: As part of the Services, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

Security. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.

Your rights.

General

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

• Access: Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct: Update or correct inaccuracies in your personal information.
• Delete: Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.
• Portability: Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances.
• Restrict: Restrict the processing of your personal information in specific scenarios (e.g. establishing accuracy, unlawful use, legal claims, verification of overriding grounds).
• Object: Object to our processing of your personal information where we are relying on legitimate interests and there is something about your particular situation that makes you want to object. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent: When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to privacy@reach-social.io.

• We may request specific information from you to help us confirm your identity and process your request.
• Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
• We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

• For users in the European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en.
• For users in the UK: The Information Commissioner’s Office, Water Lane, Wycliffe House Wilmslow - Cheshire SK9 5AF Tel. +44 303 123 1113 Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe. We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Services, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR. Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:

• Transfers to territories with an adequacy decision; or
• Transfers to territories without an adequacy decision using specific appropriate safeguards (e.g. standard-form contracts) or relying on an exception (e.g. explicit consent).

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.