Privacy Policy

Date: 13th March 2024

Version number: 1.3.7

Introduction

We will NEVER sell Your information to anyone.

Reflective Data never sells personal data and carries out all processing operations in strict compliance with European privacy laws. You are in control of Your personal information at all times.

Reflective Data values Your Privacy and strives for its services to be safe and enjoyable for everyone. This Policy sets out and explains how Reflective Data collects and processes personal data, the purposes for processing and how we protect it.

Policy Overview

Please read this Privacy Policy carefully so that you can better understand how Your personal data is used and shared. All capitalized terms that are not otherwise defined herein shall have the meaning given to them in Our Terms of Service which can be found at www.reflectivedata.com/terms.

This Privacy Policy applies to:

end-users (“End Users“) of Our Customers’ websites (“Customer Website(s)“) of Our Customers (“Our Customers“) which make use of Reflective Data Services as defined in this Policy, in respect of which, the End Users section of this policy applies; and
visitors (“Visitors“) of Reflectivedata.com (“Our Site“), in respect of which, the Visitors section of this policy applies.

The following sections describe who we are and what we do, the general rights applicable to both End Users and Visitors as well as certain specific terms which apply only to End Users or Visitors.

For the purposes of this Privacy Policy, End Users and Visitors may hereinafter sometimes be collectively referred to as “You” whilst the Customer Websites and Our Site may sometimes be collectively referred to as a “Reflective Data Enabled Site“.

Please do not hesitate to contact Reflective Data with any questions or issues you may have – we are happy to answer! You can reach out to Us by emailing us at info@reflectivedata.com.

This Privacy Policy forms an integral part of Our Terms of Service and describes Our privacy practices. Unless otherwise stated herein, any capitalised terms shall have the same meaning as those found in the Terms of Services.

Who is Reflective Data?

Reflective Data OÜ is a European startup headquartered in Tallinn, Estonia. It was founded in December 2017. Reflective Data complies with the Data Protection of the Laws of Estonia, (‘Applicable Law’), which transposes all the relevant European Union directives relating to data protection.

How does Reflective Data work?

Reflective Data Data Pipeline is a service that allows its users to transfer data from various marketing tools into a data warehouse (Google BigQuery, for example). The exact functionality depends on the data source and destination and can vary from project to project. For the pipeline service, Reflective Data never stores any data besides anonymous log files on their servers. After data is sent Our Customer’s data warehouse, it is deleted from the memory and Reflective Data can no longer access this data.

Reflective Data User Behavior Analysis is a service that analyzes the online behaviour and voice of website users. We do this by combining both analysis tools and feedback tools. Reflective Data gives the owners and operators of a Reflective Data Enabled Site the ‘big picture’ of how to improve the end user’s experience and performance of the Reflective Data Enabled Site.

The Analysis tools allows Us and Our Customers to measure and observe Your behaviour (what You do) while the Feedback tools allow us and Our Customers to hear what You have to say (Voice of User / Customer).

Reflective Data Enabled Sites insert a tracking code onto their respective website which is transmitted to Our servers. This tracking code contacts Reflective Data’s servers and provides a script to Your computer or device accessing the Reflective Data Enabled Site. The script will capture specific data related to the viewer’s interaction with that particular webpage. This information is then sent to Reflective Data’s servers for processing. Review Our Technical Information for more details.

Through these tools, Reflective Data assists the owners and operators of Customer Websites in providing their End Users with a better experience and service as well as assist them in diagnosing technical problems and analyse user trends. Most importantly, through Reflective Data’s code, software and services, the functionality of the Customer Websites can be improved, make them more user-friendly, more valuable and simpler to use by the End Users.

Information processed by Reflective Data

Depending on the product, tool, or service, Reflective Data may collect and process information which is automatically and passively collected, whilst You navigate through and interact with the content on a Reflective Data Enabled Site, together with information on Your device or computer (such as cookies).

The sole purpose of passively collecting Your information is to improve Your experience when using a Reflective Data Enabled Site.

Through the Reflective Data code embedded on a Reflective Data Enabled Site, the information collected and processed includes:

Device-specific data

The following information may be collected related to Your device and browser:

device’s IP address (captured and stored in an anonymized format);
device screen resolution;
device type (unique device identifiers), operating system, and browser type;
geographic location (country only);
preferred language used to display the Reflective Data Enabled Site.

User interactions

Mouse events (movements, location and clicks)
Keypresses

Log data

For a sampling of visitors, Our servers automatically record information which is collected from Customer Websites and Our Site. This data includes:

referring URL and domain;
pages visited;
geographic location (country only);
preferred language used to display the webpage;
date and time when website pages were accessed.

Cookies

Reflective Data does not introduce any new cookies to Our Customer websites but for some Data Pipelines may read existing cookies.

Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the Reflective Data Enabled Site.

We may also use cookies to record login details on Your device or computer. This helps to determine whether a particular device previously visited a specific Reflective Data Enabled Site so that the login details would not have to be re-entered each time You visit that Reflective Data Enabled Site.

Most browsers allow You to choose whether to accept cookies or not. If You do not wish to have cookies placed on Your computer, please set Your browser preferences to reject all cookies, before accessing any Reflective Data Enabled Site. Please note that by doing so, some features of certain Reflective Data Enabled Sites may become unavailable.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

For more info about the cookies We make use of, please contact us at info@reflectivedata.com.

How Reflective Data secures data

Reflective Data has implemented various measures to ensure that the information is adequately protected against unauthorised access, use, disclosure and destruction. Please keep in mind that risk can never be eliminated but can be significantly mitigated and reduced. All measures which Reflective Data has taken significantly reduce the risk. Reflective Data shall not be held liable by any Third Party, including You, in any event of unauthorized access, use and/or disclosure of information provided that such is not due to Gross Negligence, willful misconduct, fraud or bad faith by Reflective Data.

Security measures adopted by Reflective Data include:

Reflective Data’s employees don’t have access to the data that runs through its servers for the Data Pipeline services.
access to the information stored within Reflective Data’s servers is restricted to a limited number of Reflective Data employees and to users designated on our Customer’s accounts and Third Parties who can access the information only in specific and limited circumstances and are bound by confidentiality;
Reflective Data’s servers are protected by a) firewalls establishing a barrier between Our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to whitelisted IPs;
each Customer may only access information pertaining to its Customer Website that it is tracking and to the specific End Users visiting such Customers Website;
we use HTTPS for Reflective Data’s Services providing secure transfer of data to prevent wiretapping and man-in-the-middle attacks;
Reflective Data reviews its information collection and processing practices periodically and will review and amend this Privacy Policy accordingly. Please review our Technical Information for more details.

Access and Disclosure

Reflective Data does not rent or sell Your information, but we do disclose Your information to a limited set of trusted Third Parties in the situations explained below, for which You, by using our Services, hereby explicitly consent.

we will disclose Your personal information where We are bound to do so, at law or via a court order as well as to meet any legal or regulatory requirement or obligations. We will use all reasonable efforts to ensure that those requirements or obligations are in accordance with Applicable Law;
we reserve the right to disclose Your information to any Third Party if We have reasonable information to believe that the disclosure is necessary for the purpose of an investigation and/or for the enforcement of any breaches of the Terms of Service (if applicable), to detect, prevent or otherwise address fraud, security, technical issues or other irregularities or illegalities, protect the rights and interests as well as the property of Reflective Data;
we may also share aggregated anonymized, non-personal information with the public or with any Third Party for publishing industry trends related to Reflective Data’s Services.

Reflective Data’s business and Services are constantly developed and improved and the Privacy Policy and the Terms of Service will thereby also change to take account of any related changes to the Customers’ Websites.

We may revise this Privacy Policy from time to time. The most current version of the policy, found at www.reflectivedata.com/privacy will govern Our use of Your information collected and processed from a Reflective Data Enabled Site.

We will provide You with advance notice of the modifications via email to the email associated to Your account and by posting a written notice on Our Site and You hereby agree that this shall constitute adequate notice in this regard. All changes to this Privacy Policy automatically take effect on the sooner of the day You use the Site and/or Services, or 30 calendar days after they are initially posted on the Site. Your use of the Site and/or Services following the effective date of any modifications to this Agreement will constitute Your acceptance of the Agreement, as modified.

End Users

If you are a visitor of a website which is running the Reflective Data Service, this section applies to you.

This section of our Privacy Policy explains the details of how Reflective Data collects information from Your browser and device when you access the Customer Websites. For the purposes of the services that Reflective Data provides to Customer Websites, Reflective Data acts as Data Processor and solely processes all personal data in accordance with the instructions received from Our Data Controllers, the owner and/or operator of the Customer Websites. This includes how Reflective Data collects information from the End User’s browser and device when an End User accesses the Customer Website.

The following information may be collected related to the End User’s device and browser:

device’s IP address (captured and stored in an anonymized format as described in our Technical Information);
device screen resolution;
device type (unique device identifiers), operating system, and browser type;
geographic location (country only);
preferred language used to display the Reflective Data Enabled Site.

User interactions

Mouse events (movements, location and clicks)
Keypresses

Log data

For a sampling of visitors, Our servers automatically record information which is collected from Reflective Data Enabled Sites. This data includes:

referring domain;
pages visited;
geographic location (country only);
preferred language used to display the webpage;
date and time when website pages were accessed;

Cookies

Reflective Data Enabled Sites use cookies to collect non-personal information including standard internet log information and details of the End User’s behavioural patterns upon visiting a Reflective Data Enabled Site. This is done to enable the Reflective Data Enabled Site to provide You with a better experience, identify preferences, diagnose technical problems, analyse trends and generally to help Our Customers improve their website.

Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the Reflective Data Enabled Site.

Reflective Data also uses cookies to determine if someone has opted out of being tracked by Reflective Data services.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

For more info about the cookies We make use of, please visit Cookie Information.

Reflective Data, at all times, undertakes to ensure that by sharing Your behavioural patterns and any other information generated from You visiting the Customer Website, Your Privacy rights are respected at all times.

You may opt-out from having Reflective Data collect Your information when visiting a Customer Website at any time by visiting our Opt-out page and clicking ‘Disable Reflective Data’.

Our Privacy Policy should always be read in conjunction with the specific privacy policy of the Customer Website which will contain further details regarding the processing of Your personal data by the Customer Website. In addition to the general terms relating to the notices and revisions of this Privacy Policy as explained herein, any changes to the privacy policies regulating the Customer Website shall be notified to You in accordance with Reflective Data’s Customers’ respective privacy policies available on the Customer Website.

Visitors

If you are a visitor to Reflectivedata.com, this section applies to you.

This section of our Privacy Policy explains the details of how Reflective Data collects information from Your browser and device when you access www.reflectivedata.com (“Our Site“). By visiting Our Site, or by signing up via Our Site, You acknowledge that You accept and consent to Our privacy practices as outlined in this Privacy Policy.

In addition to any other personal data referred to in this Privacy Policy, when You sign up and open an account with Reflective Data, You are providing us directly with certain information about You. When creating a Reflective Data account or signing-up for content or offers, We may ask You to provide Us with your name, email address and details about your organization. We will solely use this information to provide You with the service that You signed-up for. Where We would like to use the contact details You have provided Us with for any other purpose We will inform You and obtain Your consent before proceeding, unless otherwise provided for in Applicable Law. For more information as to how to deactivate Your account and/or unsubscribe from receiving content or offers, simply submit a request using our Contact Us form.

Reflective Data may obtain contact details for electronic mail in relation to the sale of its Services and may therefore use such details for direct marketing of its Services. In all correspondence, You shall have the opportunity to unsubscribe from receiving direct marketing free of charge.

You may access a broad range of information about Your interactions with Our Site, including updating of your Account details and information. As a data subject, You may ask Reflective Data, as the Data Controller, to confirm whether any of Your personal data is being processed.

You may opt-out from having Reflective Data collect Your information when visiting a Customer Website at any time by visiting our Opt-out page and clicking ‘Disable Reflective Data’.

You may deactivate Your Reflective Data account and/or unsubscribe from receiving content or offers from Us at any time, by using our Contact Us form. Following termination of Your account, we shall retain your personal information for a limited time for customer service issues only.

We use a select number of trusted Third Party providers to help us provide Services to You. We only share information with the Third Party that is required for the service they are offering and contractually bind these providers to keep any information We share with them as confidential and to be used only for particular purposes. For example, amongst others, We have providers that process Our credit card transactions, support Our internal ticketing/support system, and manage Our marketing communications. Similarly, it may be necessary to share Your personal information or part of it, with Google which stores the information within their servers, solely related to the storage facilities. By using Reflective Data, You explicitly consent to, and authorize us to sub-contract in this manner.

In addition to the general terms relating to the notices and revisions of this Privacy Policy as explained herein, we will notify You of any material changes to this Privacy Policy via email to the email associated to Your account. By continuing to access or use Reflective Data, its Site and Services after those changes become effective, or not notifying Reflective Data of Your objection to the changes, You tacitly agree to be bound by the revised Privacy Policy.

Which data is being collected from Reflective Data customers?

Reflective Data customer is someone who has signed up for a free or paid plan of our platform. When creating a new account You will be prompted to enter Your name, email, website URL, and password. For paid plans also the credit card details are required. Reflective Data never stores any credit card information on our servers, instead, we are using a secure third party (Stripe Payments Europe, Ltd or Maksekeskus AS) service to handle our payments. During the period of using our service, You may be prompted to enter your phone number, tax information, and a name of the company.

Notices and Revisions to Privacy Policy

If You have any concern about Your privacy, You are kindly requested to forward an email to Reflective Data at info@reflectivedata.com containing a detailed description of Your concerns. Reflective Data will do its best to resolve such issues within a reasonable time.

You have the right to object to the processing and collection of Your personal data, and to withdraw Your consent at any time, except where otherwise determined by Applicable Law. Whenever You withdraw consent, You acknowledge and accept that this may have a negative influence on the quality of the Reflective Data Enabled Site and/or Services as well as may cause the impossibility of access to the Reflective Data Enabled Site and/or Services. You further agree that Reflective Data shall not be held liable with respect to any loss and/ or damage to Your personal data.

Governing Law and Dispute Resolution

This Privacy Policy forms an integral part of Our Terms of Service. The Governing Law and Dispute Resolution mechanism found in Our Terms of Service shall also apply to Our Privacy Policy.

Further Information

If you have any questions about our Privacy Policy or our privacy practices, please Contact Us.