Privacy Policy

Last updated: December 17, 2024

Thank you for using our website, products and services.  This Privacy Policy contains important information on our information practices, including how and why we collect, use, disclose, share, store, and retain your personal information. It also explains your rights in relation to your personal information, and how to contact us or supervisory authorities in the event you have a complaint or request.

When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

1) Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Reflective Inc.
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information	Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.
Biometric Information	An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

2) Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	Real names, aliases, postal address, Internet Protocol address, email address, gender, company name
Information that identifies or relates to a particular individual	Names, age of user by bracket:  18-24, 25-34, 35-44, 45-54, 55-64, and 65+, interests, gender
Credentials allowing access to an account	Email address
Characteristics of protected classifications under law	Age of user by bracket, including 40 and older:  18-24, 25-34, 35-44, 45-54, 55-64, and 65+, gender
Commercial information	Company
Biometric information	None
Internet or network activity information	Browser from which user activity originated, browsing history, search history, application, device model name, information about site interactions: clicks, scrolls, mouse moves, window resizes, selections, inputs, diagnostic events (script and image errors, logs etc.), page events (document sizes, page visibility, page unload, metrics, and dimensions about the page), custom events (custom variables/events set by the website based on some event) ,
Geolocation data	City, country, continent, region, subcontinent
Audio, electronic, visual, thermal, olfactory, or similar information	Device model name, operating system
Professional or employment-related information	Company or professional affiliation
Education information	None
Inferences	Product use cases, e.g. reasons for using our products and services
Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status	None
Contents of a consumer’s mail, email, and text messages	None
Genetic data	None
Processing of biometric information for the purpose of uniquely identifying a consumer	None
Health information	None
Sex life or sexual orientation	None

If you do not provide personal information required to provide our products or services to you, it may delay or prevent us from providing those products or services to you.

3) How Your Personal Information is Collected. We collect personal information from the following categories of sources:

• You, via email, our website, products or services
• Third party with your consent 
• Data analytics providers
• Cookies on our website

4) How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

• To comply with our legal and regulatory obligations
• To provide our website, products and services
• For our legitimate interests or those of a third party, or
• Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you	In order to make our website, products, and services work or provide information contained therein
To prevent and detect fraud	For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to	For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business	For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating user records	To provide our website, products, and services To comply with our legal and regulatory obligations For our legitimate interests or those of a third party
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services	For our legitimate interests or those of a third party, i.e., to promote our business to existing and former users
External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.

Microsoft.  We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

5) EEA Data Subjects: Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never [sell OR share] it with other organizations [outside the [organization’s group name] group] for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• Contacting us at info@reflective.org
• Using the “unsubscribe” link in emails 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

6) Who We Share Your Personal Information With. We routinely share personal information with:

• Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, such as marketing agencies or website hosts
• Professional service providers
• Researchers
• Third parties to demonstrate our simulator’s performance

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7) Personal Information Shared. In the preceding 12 months, we have shared the following categories of personal information:

• Identifiers (e.g., a real name, alias, online identifier, Internet Protocol address, email address, company, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, location, gender, age bracket, and professional affiliation.
• Characteristics of protected classifications under California or federal law
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
• Geolocation data
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

8) Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, company, account name,, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, email address, employmentCharacteristics of protected classifications under California or federal law
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
• Geolocation data
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

9) How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf
• To show that we treated you fairly –or–
• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.  When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10) California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know, and request disclosure of: – The categories of personal information we have collected about you, including sensitive personal information – The categories of sources from which the personal information is collected – The categories of third parties to whom we disclose personal information, if any –and– – The specific pieces of personal information we have collected about you Please note that we are not required to: – Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained – Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or– – Provide the personal information to you more than twice in a 12-month period
Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose	In connection with any personal information we may share or disclose to a third party for a business purpose, you have the right to know: – The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and– The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sharing of your personal information, we will refrain from sharing your personal information, unless you subsequently provide express authorization for the sharing of your personal information. You may request to opt-out of the sharing of your personal information by writing info@reflective.org.
Right to Limit Use of Sensitive Personal Information	We don’t collect sensitive personal information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: – Delete your personal information from our records, and – Delete your personal information from our records, and – Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: – Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us – Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes – Debug to identify and repair errors that impair existing intended functionality – Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law – Comply with the California Electronic Communications Privacy Act – Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent – Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us – Comply with an existing legal obligation –or– – Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
Right of Correction	If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Protection Against Retaliation	You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: – Deny goods or services to you – Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties – Provide a different level or quality of goods or services to you, or – Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

11) EEA Data Subjects: Your Rights Under the EU GDPR.

Right to Be Informed	The right to know or be notified about the collection and use of your personal information.
Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: – At any time to your personal information being processed for direct marketing (including profiling) – In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the EU General Data Protection Regulation.

12) How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please email us at info@reflective.org.

• Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
• If you choose to contact us directly by email, you will need to provide us with:
  • Enough information to identify you 
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and
  • A description of what right you want to exercise and the information to which your request relates
• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
• Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

13) EEA Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.  Please email us at info@reflective.org.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

14) Changes to This Privacy Notice. We may change this privacy notice from time to time–when we do, we will update our website.

15) How to Contact Us. Please contact us by email at info@reflective.org if you have any questions about this privacy policy or the information we hold about you.