Privacy Policy

Effective Date:  January 1, 2020

React2Media recognizes that when you choose to provide us with personal information about yourself, you trust us to treat it responsibly.

This Privacy Policy explains the types of personal information that React2Media and its affiliated companies collect about you, how we use, share, and protect this personal information, and the choices you can make about how we use and share this personal information.  This Privacy Policy governs personal information collected by any means, including, but not limited to, websites and other online services that refer or link to this Privacy Policy, as well as information collected by other business functions of React2Media, such as when you speak with a customer service representative (collectively, the “Services”).

It is important that you read this Privacy Policy carefully, because anytime you use our Services you consent to the practices we describe in this Privacy Policy.  Key California-specific information about our privacy practices is available in our policy here.



Information Covered by this Privacy Policy

This Privacy Policy is applicable to information collected by React2Media and its affiliated companies.  This includes information collected:

  • Through websites and other online services that refer or link to this Privacy Policy.
  • Through the other business functions of React2Media, such as by customer service representatives.

Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by such third parties. You should exercise caution, and review the privacy statements applicable to such third parties.



Information We Collect

We may collect information about you and others and, if applicable, the computer or device you use to access our Services in a variety of ways:

  • You may provide us information directly.
  • We may collect information about you when you use our Services or view our online advertisements.
  • We may collect additional information about you in accordance with applicable law.

The manner of our collection and the type of information collected may vary by jurisdiction to accommodate local legal requirements.



Information you provide us directly

We collect information directly from you when you choose to register for our Services or otherwise provide information directly to us.  The following are examples of information you may provide us directly:

  • Name.
  • E-mail address, physical address and/or zip code, and phone number.
  • Occupation and other demographic information.

You can choose not to provide us with certain types of information, but doing so may affect your ability to use some of the Services.



Information we collect when you use our Services or view our online advertisements

We collect information about your computer or device and your online activity, including through the use of standard Internet technologies, such as cookies, web beacons, and local stored objects.  The following are examples of the types of information that we may collect:

  • Your browser type and operating system.
  • IP address and/or device ID.
  • Your browsing behavior on our Services, such as the amount of time spent viewing our online Services, and the links you click within our online Services.
  • Websites you visit before or after our websites.
  • React2Media e-mails you open and/or forward.
  • React2Media offers or links you connect to via e-mails.
  • Depending on your device settings, location information, such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers


Additional information we may collect about you

We may receive information about you from publicly and commercially available sources in accordance with applicable law.  In addition, we may collect other information you allow a third party to provide to us.  For example, if you choose to access or use social networking services, we may receive and store information that you allow us to receive through those services, such as your e-mail address.

We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection or otherwise with your consent.

All of the information we collect about you may be combined to help us enhance and improve our products and services and tailor our communications to you.



Use of Information

We may use the information we collect about you:

  • To communicate with you about our products and services.
  • To customize your experience with our Services, including by providing you with relevant advertising on our Services and elsewhere.
  • To send you promotional materials and offers.
  • To manage and improve Services and offerings, including analyzing the use of our services, and determining the effectiveness of our advertising.
  • To protect the security and integrity of our Services.
  • To enforce our legal rights.
  • Otherwise with your consent.

Please see Your Choices & Rights in Your Information below for information about the choices you may have in relation to our use of your personal information.



Sharing of Information

React2Media may disclose your information in the following circumstances:

  • We may share information within React2Media among our various businesses and affiliated companies, including, for example, to provide you with our product and service improvements.
  • Service Providers.  We rely on third-party service providers to perform a variety of contractual services on our behalf.  To do so, we may need to share your information with them.  For example, we may rely on service providers to fulfill our product and service requests, process your credit card and other payments, answer your questions, send e-mails on our behalf, and analyze data to improve our products and services.
  • Other Parties When Required by Law or as Necessary to Protect Our Services.  There may be instances when we disclose your information to other parties:
    • To comply with the law or respond to legal process or a request for cooperation by a government entity.
    • To prevent fraud or verify and enforce compliance with the policies governing our Services.
    • Where permitted by law, to protect the rights, property, or safety of React2Media, or any of our respective affiliates, business partners, customers or employees.
  • Other Parties In Connection With A Corporate Transaction.  We may disclose your information to a third party in the event we sell or transfer all or a portion of a business or our assets to a third party, such as in connection with a merger or in the event of a bankruptcy reorganization or liquidation.  In certain jurisdictions, consent is required for this sharing of information.  We will collect your consent when required by applicable law.
  • Other Parties With Your Consent At Your Direction.  In addition to the disclosures described in this Privacy Policy, we may share information about you with third parties when you consent to or request such sharing.
  • Aggregated and Non-Personal Information.  We also may share data in a manner that does not identify you (for example, information that has been aggregated with other records) for general business purposes.  For example, we may disclose the number of visitors to our websites or other Services.


Cookies, Web Beacons, and Other Internet Technologies

We, as well as certain third parties, including those that provide content and other functionality on our Services, may use cookies, web beacons and other similar technologies on our online Services and the information collected from such technologies.  By using our online Services, you are consenting to our use of cookies, web beacons, and other tracking technologies as described in this Privacy Policy.   If you are a U.S. user, click here for information about Do-Not-Track signals and similar mechanisms.


Cookies

A cookie is a small file that may be stored on your computer or other device.  A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions.

When you use a web browser to access the Services, you may configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.  Click the “Help” menu of your browser to learn more about how to change your cookie preferences.  The operating system of your device may contain additional controls for cookies.   Please note that disabling cookies may affect your ability to access and use certain features of the Services.


Web Beacons

Web beacons and similar technologies are small bits of code, which are embedded in web pages, ads, and e-mail, that communicate with third parties.  We may use web beacons, for example, to count the number of users who have visited a particular web page, to deliver or communicate with cookies, and to understand usage patterns.  We also may include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. 


Other Technologies

There are other local storage and Internet technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, that operate similarly to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences across different services and sessions.  Please note that these technologies are distinct from cookies, and you may not be able to control them using standard browser tools and settings.  For information about disabling or deleting information contained in Flash cookies, please visit the Flash website operated by Adobe.


How We Use These Technologies

Our online services use these technologies for the following general purposes:

Type of Cookie

What Do They Do

Examples

Technical

Enable our online Service to work correctly.

For example, these cookies remember previous actions (e.g., entered text) when navigating back to a page in the same session and balance website traffic.

Performance

Help us measure and understand how visitors interact with the online Services and our content and any issues encountered to help us improve the performance of the Services.

For example, these cookies gain insight into how visitors use our websites so we can make improvements to usability and content.

Functionality

Allow our online Services to remember choices you make (such as your user name, language, or the region you are in) to provide a more personalized online experience.

For example, these cookies maybe enable you to store your sign-in credentials and preferences so that you don’t have to enter those credentials and preferences each time you log on.

Targeting/Advertising

Help us and third parties provide you with relevant content and advertising by collecting information about your use of our Services and other websites and online services.

These cookies may be used to deliver targeted advertising or to limit the number of times you see an advertisement.  They also help us measure the effectiveness of ad campaigns. We may include web beacons in e-mails, for example, to understand whether messages have been opened, acted on, or forwarded.



Third Parties That Provide Content or Functionality on Our Services

Some of the content and functionality on our Services may be provided by third parties that are not affiliated with us.  For example, we enable you to share certain materials on our Services through social networking services, such as Facebook and Twitter.  Third-party advertisers also may have a presence on some of our Services.  These and other third parties may collect or receive certain information about your use of our Services, including through the use of cookies, web beacons, and Internet technologies, and this information may be collected over time and combined with information collected across different websites and online services.

Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.  Please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance to learn more.  (Canadian users may also visit the website operated by the Digital Advertising Alliance of Canada.  Further information in local languages may be available at that site.)



International Transfer of Data

React2Media and its service providers may collect, transfer, store and process your information outside of your country of residence, including to the United States.  Please note that other countries’ data protection and other laws may not be as comprehensive as those in your country.



Collection of Information From Children

We do not knowingly collect personal information online from children as defined by local law.  If we learn that a child has provided us with personal information, we will delete it or otherwise comply with applicable law.



Your Choices & Rights in Your Information

Where permitted by law, we may send you offers or promotions.   However, we give you choices about how we communicate with you.

  • E-Mail: If you no longer wish to continue receiving commercial emails from React2Media, you may follow the instructions contained in any such message.
  • Other:  If you no longer wish to continue receiving other commercial communications from a particular React2Media brand or group, you may follow the instructions or use the contact information contained in any such message.

Please note that, despite your opt-out selections, where permitted by applicable laws, we may send you communications regarding transactions or services you have specifically requested or to inform you of important changes to our Services, products or policies.

You may have certain rights as a data subject under local law.  For example, local law may afford you the right to access, update, restrict, oppose, erase, port and/or correct inaccuracies in your personal information under our control, subject to certain exceptions prescribed by law. 

If you would like to exercise your legal rights, please contact us at info@react2media.com.  We will respond to requests in accordance with applicable law and subject to legal and contractual restrictions.



Information Security & Retention

We have in place various procedures to safeguard your information, including technical, administrative and physical procedures intended to keep your information secure.  However, please note that although we take reasonable steps to protect your information, no website, Internet transmission, computer system or wireless connection is completely secure.

In addition, we take steps to retain personal information about you only for so long as is necessary for the purpose for which it was collected, as required under contract, or as required by or permissible under applicable law.



How to Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact React2Media.  You may contact us at info@react2media.com.  In addition, you may contact us at the following address:

React2Media Inc.

35 West 36th Street, Suite 4E
New York, NY 10018



Changes to This Privacy Policy in the Future

Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. We recommend that you revisit this Privacy Policy periodically to ensure that you are aware of our current privacy practices, although we may also elect to notify you by e-mail or by posting something on some or all of our online services. Your continued use of our Services following any changes signifies your acceptance of these changes.



Your California Privacy Rights

CCPA Consumer Notice

Effective Date: January 1, 2020

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”), and supplements other React2Media privacy policies and notices.  In the event of a conflict between any other React2Media policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA.  This Notice describes our collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”), as well as rights California Consumers have under the CCPA.  For purposes of this Notice, in some places we have abbreviated or summarized CCPA terms or language.  Terms defined in the CCPA that are used in this Notice shall have the same meanings as in the CCPA. 



COLLECTION, USE, & SHARING OF PERSONAL INFORMATION

We collect PI about California Consumers as described in the table below. We may share PI with our affiliates, service providers and qualified vendors including those that facilitate interest-based advertising and other advertising and marketing, and other parties as described in the table below.

Category of PI

 

Examples of PI Collected

 

Sources of PI

 

Purpose for PI Collection

 

Categories of Recipients

 

Identifiers

Name,
postal address,
Internet Protocol (IP) address, email address

Consumers,
public information, affiliates,
other third parties

We use this information for the Business Purposes of: auditing related to interactions and transactions; detecting security incidents and protecting against fraud; debugging or repair of systems; short-term transient use (for example, contextual advertising); providing services; internal tech research; and quality and safety control. We also use this information for the Commercial Purposes listed under Use of Information above.

Marketing service providers (such as ad networks, ISPs, analytics providers), government entities, operating systems and platforms, social networks.

Customer Records

Name,
address,
telephone number,
email address

Consumers,
public information, affiliates,
other third parties

We use this information for the same purposes listed above for Identifiers.

Marketing service providers (such as ad networks, ISPs, analytics providers), government entities, operating systems and platforms.

Internet Usage Information

Browsing history,
search history,
information regarding interactions with our websites or advertisements

Consumers,
public information, affiliates,
other third parties

We use this information for the same purposes listed above for Identifiers.

Marketing service providers (such as ad networks, ISPs, analytics providers).

Sensory Data

Audio recordings of customer service calls

Customer service calls are sometimes recorded, with customers notified at the beginning of the call.

We us this information for the Business Purposes of detecting security incidents and protecting against fraud; and quality and safety control.

None

Professional Information

Employment information

Consumers

We use this information for the Business Purposes of providing services and internal tech research.  We may also use this information for the Commercial Purposes listed under Use of Information above.

Marketing service providers.

 



CALIFORNIA PRIVACY RIGHTS

Under the CCPA, California Consumers have certain rights they may exercise either independently or through an authorized agent.  CCPA rights requests are subject to an identification and verification process.  We will not fulfill a CCPA request unless we have been provided sufficient information for us to reasonably verify that the requestor is the Consumer about whom we collected PI. 

Some PI we maintain about Consumers (e.g., clickstream data) is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI.  Accordingly, we will not include such information in response to Consumer requests.  If we cannot comply with a request, we will explain the reasons in our response.  You are not required to create an account with us to make a request. We will use PI provided in your request only to verify your identity or authority to make the request and to track and document request responses, unless you also provided the PI to us for another purpose.

We will make commercially reasonable efforts to identify Consumer PI that we collect, use, store, disclose, or otherwise process, and to respond to your California Consumer privacy rights requests.  In some cases, particularly with voluminous or typically irrelevant data, we may provide you with a summary of your PI and give you the opportunity to elect whether you want us to provide the entire data set.  Or we may direct you on how to access and copy responsive PI yourself.  We may charge a reasonable fee or refuse to act upon a request if the request is excessive, repetitive, unfounded, or overly burdensome.  If we determine that the request warrants a fee, or that we may decline to comply with the request, we will give you notice explaining why we made that decision.  In the case of a fee, we will provide a cost estimate and the opportunity to accept such fees before charging you for responding to your request.

California Residents – Your Rights and Contacting Us

Your California Consumer privacy rights are described below.  To make a request, you can email us at  info@react2media.com and promptly respond to any follow-up inquires so that we may confirm your identity.  If you request that we provide you with specific pieces of information about you, we will apply heightened verification standards.  Authorized Agents may submit requests on behalf of Consumers by following these steps and providing appropriate documentation.

Disclosure Rights

You have the right to request that we disclose the following information for the 12-month period prior to the request date.  Consumer requests of this nature may be made no more than twice in a 12-month period.  With respect to (1) and (2) below, we will provide this information in a portable and, if technically feasible, readily usable format.

  1. The categories of PI we have collected about you.
  2. The categories of sources from which we collected your PI.
  3. The business or commercial purpose(s) for our collection of your PI.
  4. The specific pieces of PI we have collected about you.
  5. The categories of third parties to whom we have disclosed your PI.
  6. A list of the categories of PI disclosed for a business purpose in the prior 12 months (or a statement that no such disclosure occurred).
  7. A list of the categories of PI sold about you in the prior 12 months, including the categories of third parties to whom we sold your PI and the business or commercial purposes for the sale (or a statement that no such sale occurred). 

Verification for Disclosure

Customers without an on-line account or React2Media charge account cannot be reasonably validated.  Please see chart above to understand what PI we may have collected, the purpose of collection and with whom we may have shared it with.  Customers with an on-line account will be asked to log into their account in a specific time frame.  After successful log in, we will provide you with the categories of PI we have collected specific to you.  Customers with a React2Media charge account may be asked for up to three unique pieces of account-related information and may also be required to return a signed legal verification document.  After successful verification of information, we will provide you with the specific pieces of PI we have collected about you.

“Do Not Sell” Rights

You have the right to direct us to not sell your PI. 

While there is not yet a consensus, data practices of third party cookies and tracking devices associated with our websites and mobile apps may potentially constitute a “sale” of your PI as defined by the CCPA.  You can exercise control over browser-based cookies by adjusting the settings on your browser.  In addition, third party tools enable you to search for and opt-out of some of these devices, such as the Ghostery browser plug-in available at https://www.ghostery.com/.  You can learn more about your choices regarding certain kinds of Online Advertising here.  We do not represent that these third party tools, programs or statements are complete or accurate.

We do not have actual knowledge of the age of Consumers under 16 and do not knowingly link PI with the age of Consumers under age 16.  Consumers who opt-in to PI “sales” may opt-out at any time.

Deletion Rights

You may request that we delete your PI that we have collected directly from you.  Under the CCPA, we may decline to delete your PI under certain circumstances, for example, if we need the PI to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims.  Note also that we are not required to delete your PI that we did not collect directly from you. 

Non-Discrimination and Financial Incentive Programs

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.