ReflectivEdu's Privacy Policy
Thank you for choosing to be part of our community at ReflectivEdu. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at contact@reflectivedu.com
When you visit our website https://reflectivedu.com/ and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. We hope you take some time to read through it carefully as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Sites and our services.
This privacy policy applies to all information collected through our website, including any site with the domain www.reflectivedu.com and/or any related services, sales, marketing, or events. (We refer to them collectively in this privacy policy as the “Services.”)
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- WITH WHOM WILL YOUR INFORMATION BE SHARED?
- DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- DATA BREACH
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us:
We collect personal information that you provide to us, such as your name, address, contact information, and payment information. We collect this information when you voluntarily provide it to us, such as when expressing interest in obtaining information about us or our products and services, participating in activities on the Services, or contacting us. The specific personal information we collect depends on the context of your interactions with us and the choices you make. It may include publicly available personal information, such as phone numbers, first name, maiden name, last name, nickname, email addresses, business phone number, business email, and similar data. It is important that any personal information you provide to us is true, complete, and accurate, and that you notify us of any changes to such information.
Information automatically collected:
Some information, such as IP address, browser, and device characteristics, is collected automatically when you visit our Services. We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (such as your name or contact information), but it may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. We primarily collect this information to maintain the security and operation of our Services, as well as for internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. These may include online identifiers, such as IP addresses, cookie identifiers, or others used for analytics, marketing, and similar purposes.
2. HOW DO WE USE YOUR INFORMATION?
We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use the personal information collected through our “Services” for various business purposes, as described below. We process your personal information for these purposes based on our legitimate business interests, the necessity to enter into or perform a contract with you, your consent, and/or compliance with our legal obligations. Next to each purpose listed below, we indicate the specific grounds on which we rely for processing.
We use the information we collect or receive for the following purposes:
- To send you marketing and promotional communications: We may use the personal information you provide to us for marketing purposes, in accordance with your marketing preferences. You have the option to unsubscribe from our marketing emails at any time (see “WHAT ARE YOUR PRIVACY RIGHTS” below).
- To send administrative information to you: We may use your personal information to send you information about products, services, new features, and changes to our terms, conditions, and policies.
- To fulfill and manage your orders: We may use your information to process and manage your orders, payments, returns, and exchanges made through the Services.
- To deliver targeted advertising to you: We may use your information to develop and display tailored content and advertising based on your interests and/or location, and to measure its effectiveness. We may work with third parties for this purpose.
- To request feedback: We may use your information to request feedback and contact you regarding your use of our Services.
- To deliver services to the user: We may use your information to provide you with the requested services.
- To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and resolve any potential issues you may encounter while using our Services.
- For other business purposes: We may use your information for data analysis, identifying usage trends, evaluating the effectiveness of promotional campaigns, and improving our Services, products, marketing, and user experience. This information may be used and stored in an aggregated and anonymized form that does not identify individual end-users or include personal information. We will not use identifiable personal information without your consent.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal bases:
- Consent: We may process your data if you have given us specific consent to use your personal information for a particular purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: When we have entered into a contract with you, we may process your personal information to fulfill the terms of our agreement.
- Legal Obligations: We may disclose your information if we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process. This includes responding to court orders, subpoenas, or requests from public authorities to meet national security or law enforcement requirements.
- Vital Interests: We may disclose your information when we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on your behalf and require access to such information to carry out their work. This may include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. Selected third parties may use tracking technology on the Services to collect data about your interactions with the Services over time for purposes such as analyzing and tracking data, determining the popularity of certain content, and better understanding online activity. However, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, ensuring that they can only process your personal information as instructed by us. They are prohibited from sharing your personal information with any other organization and are required to hold it securely and retain it for the instructed period.
- Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company
4. WITH WHOM WILL YOUR INFORMATION BE SHARED?
We only share and disclose your information with the following third parties. We have categorized each party to help you understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.
- Content Optimization: Google AdSense, and OptinMonster
- Search Functionality: Bing Site Search
- Ad Retargeting: Facebook Custom Audience, Google Ads Remarketing,
- Social Media Sharing and Advertising: Facebook Advertising, Instagram Advertising
- User Commenting and Forums: Google Analytics, Website Hosting:
Please note that this list is not exhaustive, and there may be other third-party service providers that we engage with for specific purposes. We ensure that these parties are reliable and have appropriate data protection measures in place.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies such as web beacons and pixels to access or store information. Detailed information on how we use these technologies and how you can refuse certain cookies is outlined in our Cookie Policy.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy, unless otherwise required by law. We will retain your personal information only for as long as it is necessary to fulfill the purposes stated in this privacy policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than 7 years.
When we no longer have a legitimate business need to process your personal information, we will either delete or anonymize it. In cases where deletion is not immediately possible (for example, if your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion becomes possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
We strive to protect your personal information through a combination of organizational and technical security measures. We have implemented appropriate technical and organizational security measures to safeguard the security of any personal information we process. However, it’s important to remember that no method of transmission over the internet or electronic storage is completely secure. While we make every effort to protect your personal information, the transmission of such information to and from our Services is at your own risk. We recommend accessing our services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In most cases, we do not intentionally collect personal information directly from children under the age of 16 on our websites. However, when children take the ETS® TOEFL® tests and Writing Ideas Diagnostic®, we collect their first name, last name, age, grade in school, and their responses to test questions. This information is collected solely for the purpose of analyzing their writing and reading skills. The test results are provided to the schools and parents who purchase the tests. If parents or teachers have any questions regarding how ReflectivEdu handles children’s data, they can contact us by sending an email to contact@reflectivedu.com or by calling 1-210-399-3489.
9. WHAT ARE YOUR PRIVACY RIGHTS?
You have the right to review, change, or terminate your association with ReflectivEdu at any time.
If you are a resident in the European Economic Area and you believe that we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject them. However, please note that if you choose to remove or reject cookies, certain features or services of our Services may be affected.
10. DATA BREACH
A privacy breach occurs when there is unauthorized access to or collection, use, disclosure, or disposal of personal information. You will be notified about data breaches when ReflectivEdu believes you are likely to be at risk of serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that ReflectivEdu becomes aware of a security breach that has resulted or may result in unauthorized access, use, or disclosure of personal information, ReflectivEdu will promptly investigate the matter and notify the applicable supervisory authority no later than 72 hours after becoming aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers, some mobile operating systems, and mobile applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to indicate your privacy preference and signal that you do not want your online browsing activities to be monitored and collected. However, no uniform technology standard for recognizing and implementing DNT signals has been finalized. Therefore, at present, we do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted in the future that we are required to follow, we will inform you about that practice in a revised version of this privacy policy.
12. DO WE MAKE UPDATES TO THIS POLICY?
Yes, we will update this policy as necessary to ensure compliance with relevant laws. We may periodically update this privacy policy. The updated version will be indicated by a revised date, and it will become effective as soon as it is accessible. If we make significant changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy regularly to stay informed about how we protect your information.
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have any questions or comments regarding this policy, you can email us at contact@reflectivedu.com.
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
In accordance with the laws of certain countries, you may have the right to request access to the personal information we collect from you, make changes to that information, or delete it under certain circumstances. To request a review, update, or deletion of your personal information, please submit a request by emailing us at contact@reflectivedu.com. We will respond to your request within 30 days.
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