Reggie Inc. Privacy Policy

Reggie Privacy Policy

Effective Date: June 6, 2021

  • Reggie Privacy Statement
  • Personal Data Collected by Reggie
    • Types of Personal Data Collected
      • Personal Data received from Licensors and Data Brokers
      • Personal Data provided by our Customers
      • Data available in Public Sources
      • Personal Data that you Knowingly and Willingly Provide
      • Personal Data Collected by Cookies and Other Similar Technologies
    • How Is Your Personal Data Used?
    • Who Can Access the Personal Data We Collect?
      • Customers and Other Authorized Business Partners
      • Employees
      • Affiliates
      • Agents
      • To Comply with Legal Process, Protect Company, or Enforce our Rights
      • As Part of a Merger or Sale of Business
    • Your Rights Regarding Personal Data Reggie Processes
      • Correction & Removal
      • Your California Privacy Rights
      • Notice to California Residents
      • Notice to Nevada Residents
    • Minors and Children Privacy
    • Site-Specific Terms
      • Reggie’s Do Not Track Policy
      • Cookie Policy
      • Links to Third Party Services
      • Social Media Features
    • Security
    • Storage and Retention
    • International Users
    • Changes to this Privacy Policy
    • Privacy Inquiries

 

 

A.            Reggie Privacy Statement

Reggie (“Reggie”, “we”, “our”, “us”) offers certain services (the “Services”) to companies and businesses (“Customers”) that may benefit from such Services.  As part of the Services we collect, use and disclose Personal Data.

Reggie values and respects the privacy of individuals.  This Privacy Policy (“Privacy Policy”) describes the types of information, including Personal Data, that Reggie collects,  processes and uses as part of our websites including www.reggieapp.com (the “Sites”) and our Services.  This Privacy Policy outlines individual rights regarding Reggie’s use and disclosure of Personal Data.

As used in this Privacy Policy, the term “Personal Data” means information that identifies an individual, household, or place of business directly or indirectly, by reference to identifier(s) such as  name, identification number, location data, online identifier or one or more factors specific to an individual’s physical, physiological, genetic, mental, economic, cultural, educational, commercial, professional or social identity.

This Privacy Policy applies to our data collection and use related to the Sites and Services. This Privacy Policy is part of our Terms of Service, which is incorporated by reference. 

If there are questions about our privacy practices, please refer to the end of this Privacy Policy for information about how to contact us.

B.             Personal Data Collected by Reggie

1.              Types of Personal Data Collected.  Reggie collects Personal Data about individuals as described in this section.  In addition to the privacy practices in this Privacy Policy, our processing of data received from certain third parties (e.g., licensors and Customers) may be further described in contracts directly with such third parties.

a.            Personal Data received from Licensors and Data Brokers.  Reggie receives certain Personal Data licensed to us by third parties including data brokers.  This includes name and contact information, business name and contact information, address information, state or federal identification numbers and provider information.  We use the data received from these third parties as part of our Services. 

b.            Personal Data provided by our Customers.  Reggie collects and stores Personal Data provided to us by our Customers as part of the Services.  This includes name and contact information (phone number and e-mail). We use the data received from Customers as part of our Services. 

c.            Data available in Public Sources.  Reggie collects certain publicly available data including data available through . This includes name and contact information. We use the data received from these sources as part of our Services. 

d.            Personal Data Knowingly and Willingly Provided.  Reggie collects information that individuals knowingly and voluntarily provide when using our Sites (such as through web forms or profile screens).  This includes an individual’s name and contact information. We primarily use this information to make inquiries and respond to requests and as part of our Services.

e.            Personal Data Collected by Cookies and Other Similar TechnologiesReggie may obtain information about individuals by installing “cookies” on their computer's hard drive.  We use cookies to collect statistical information about the way visitors use our Sites including which pages they visit, which links they use, and how long they stay on each page.  Reggie also may use cookies to create a database of previous choices and preferences, saving users time and effort.  More information on our use of cookies can be found in Section G(2).

C.            How Is Personal Data Used?

We process Personal Data, including sharing with third parties, where processing is necessary for the purposes of our legitimate commercial interests and performance of the Services, except where otherwise required by law.

We may use or sell Personal Data we collect on its own or combine it with other information we have about an individual to:

  • Achieve our business purpose in providing the Services
  • To perform and improve the Services (including providing Personal Data to our Customers and other business partners);
  • Perform internal operations, such as tracking and improving the effectiveness of our Services;
  • Conduct research;
  • Conduct audits;
  • Provide information to our suppliers;
  • Provide information to our representatives and/or advisors, such as our attorneys, accountants, and others to help us comply with legal, accounting, or security requirements;
  • Resolve disputes between users and/or a user and the company as set forth in our Terms of Service;
  • Transfer information, such as to servers outside of the United States, or as part of a merger or sale of the business;
  • Protect the rights, safety, and information of our members, third parties, as well as our own. This includes fraud prevention, business or product recalls, prosecuting and defending a court arbitration or similar proceeding, and more; and
  • Comply with legal requirements, such as in response to a subpoena or similar investigative demand.

Reggie may aggregate, combine, anonymize and/or pseudonymize any data that we collect and process, including Personal Data.  This may be done for the purpose of performing the Services, correcting data currently held by Reggie, expanding data sets, research, and other data modeling.

D.            Who Can Access the Personal Data We Collect?

Reggie will only disclose Personal Data as set forth in this Privacy Policy, as permitted by law, or with your consent.

Where third parties are processing Personal Data on our behalf, they will be required to agree, by contractual means or otherwise, to process the Personal Data in accordance with the applicable law and to act only on our instructions.

Reggie may disclose Personal Data to the following entities and for the listed purposes:

1.              Customers.  For the purpose of providing the Services, we share Personal Data with our Customers.

2.              Employees.  Only authorized employees have access to your Personal Data.

3.              Service Providers.  We employ other companies and individuals to perform functions on our behalf.  Examples of such functions include fulfilling orders, delivering packages, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing technical support, providing search results and links (including paid listings and links) and providing customer service.  We may share Personal Data with these agents as we deem necessary for such third parties to perform their functions.

4.              To Comply with Legal Process, Protect Company, or Enforce our Rights.  We may further disclose your Personal Data when it is necessary to: (i) conform to legal requirements or comply with legal process; (ii) enforce or apply our conditions of use and other agreements; (iii) protect the rights, safety or property of Reggie, our affiliates, our Customers, service providers, you or the public, or (iv) prevent a crime or protect national security (including exchanging information with other companies and organizations for fraud protection and credit risk reduction).

5.              As Part of a Merger or Sale of Business.  We may disclose or transfer Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

E.             Your Rights Regarding Personal Data and Reggie Processes

1.              Correction & RemovalIf any of the information that we have about you is incorrect, or you wish to have information (including Personal Data) removed from our records, please contact us at info@reggieapp.com.  We will respond to such inquiries within thirty (30) business days.  

2.              Your California Privacy Rights. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits individuals with whom we have a business relationship who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please e-mail [ ].

3.                Notice to California Residents.   The California Consumer Privacy Act of 2018 (“CCPA”) provides several rights to California residents with regards to the collection, disclosure, sale, and deletion of their Personal Data. The Reggie Privacy Notice for California Residents  describes in more detail Reggie’s compliance with CCPA and how residents of California may exercise their CCPA Rights.   If you have questions about exercising your CCPA Rights, please contact us as set forth in Section L.

4.                Notice to Nevada Residents.  We currently do not transfer personal information for monetary consideration.  If in the future our approach to transferring personal information changes and you would like to tell us not to sell your information at that time please email us at https://reggieapp.com/pages/reggie-inc-privacy-policy with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

F.             Minors and Children Privacy

Reggie does not knowingly collect Personal Data from children under the age of 16.  If we learn that Personal Data of persons less than 16 years-of-age has been collected through our Service, we will take the appropriate steps to delete this information.  If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Data to us without your consent, then you may alert us at [ ] so that we may take appropriate action to remove the minor's Personal Data from our systems.

Site-Specific Terms

1.  

1.              Do Not Track Policy.  Reggie does not respond to web browser “do not track” signals on our Sites.  As such, your navigation of our Sites may be tracked as part of the gathering of quantitative user information described above.  If you arrive at our Sites by way of a link from a third party site that does respond to “do not track” requests, the recognition of any “do not track” request you have initiated will end as soon as you reach our Sites.

2.              Cookie Policy.  When you first access the Sites, you will receive a message advising you that cookies are in use. By continuing to browse the Sites, you agree to our use of cookies as described in this Privacy Notice.  If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer.  If you limit or disable the use of cookies when you visit the Sites, you may be unable to use the full functionality of our Sites.  For more information about our specific use of cookies, please reference our Cookie Policy  which is incorporated herein by reference. We may also permit select third parties to use cookies to collect information about our Site visitors’ online activities across other websites or over time in order to assist us with advertising or Site analytics. The use of cookies by third parties is not covered by our Privacy Policy, as we do not have access to or control over their cookies.

3.              Links to Third Party Services.  Our Sites may contain links to third party websites, applications and services not operated by Reggie.  These links are provided as a service and do not imply any endorsement by Reggie of the activities or content of these sites, applications or services nor any association with their operators.  Reggie is not responsible for the privacy policies or practices of any third party including websites or services directly linked to our Site. 

4.              Social Media Features.  Our Sites may include social media features, such as the Facebook “Like” button and widgets, such as the “Share This” button or interactive mini-programs that run on our Sites.  These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly.  Social media features and widgets are either hosted by a third party or hosted directly on ourSites.  Your interactions with these features are governed by the privacy policy of the company providing it.

H.            Security

Reggie takes the security of Personal Data seriously.  We utilize industry-accepted reasonable security practices and have implemented reasonable technical and organizational measures to protect the confidentiality, security and integrity of your Personal Data.  The measures we have implemented take into account the current available security technologies, cost, and risk presented by the type of Personal Data we collect, process and use.     

Although we use reasonable security measures to help protect Personal Data against unauthorized disclosure or loss, we cannot guarantee the security of Personal Data transmitted to us over the Internet.  While we strive to use commercially acceptable means to protect Personal Data, there is no guarantee that information may not be accessed, disclosed, altered or destroyed. 

I.              Storage and Retention

The Personal Data that we store is generally stored on Reggie’s servers located in [ ].  If you are located in another jurisdiction, you should be aware that once your Personal Data is submitted through our Service, it will be transferred to our servers in [ ] [and that the United States currently does not have uniform data protection laws in place].  We will retain Personal Data for as long as necessary to fulfil the purpose for which it was collected or to comply with legal requirements.

J.              International Users

We are headquartered in [ ].  Personal Data may be accessed by us or transferred to us in the [ ] or to our affiliates, partners, merchants, or service providers who are located worldwide.  If you are visiting our Sites or using our Service from outside [ ], be aware that your information may be transferred to, stored, and processed in [ ]  where our servers are located, and our central database is operated.  By using our Sites or Service, you consent to any transfer of this information.

We will protect the privacy and security of Personal Data according to this privacy statement, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that Personal Data stored or processed in [ ] will be subject to the laws of [ ] , including the ability of governments, courts or law enforcement or regulatory agencies of [ ]to obtain disclosure of Personal Data.

K.            Changes to this Privacy Policy

Reggie reserves the right to update or modify this Privacy Policy from time to time.  If we make any material changes to this Privacy Policy or the way we use, share or collect Personal Data, we will revise the “Effective Date” at the top of this Privacy Policy and prominently post an announcement of the changes on our website prior to the new policy taking effect.  The changes to the Privacy Policy will become effective within the period of time posted, but in any event a reasonable period of time.  We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Reggie’s current practices. 

L.             Privacy Inquiries

If you have any questions or concerns about this Privacy Policy or our privacy practices please contact us as follows:

  • By emailing the Privacy Department at info@reggieapp.com
  • By mail post to:

 

© 2021 Reggie - All Rights Reserved.

 

 

Reggie Privacy Notice for California Residents

Effective Date: June 6, 2021

This Privacy Notice for California Residents (“CA Privacy Notice”) supplements the information contained in Reggie’s Privacy Policy (“Privacy Notice”) and applies solely to all individuals who reside in the State of California (“consumers” or “you”). We adopt this CA Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. Terms capitalized herein but not defined, have the meanings assigned in the Privacy Notice. 

Under the CCPA California residents have the following rights (“CCPA Rights”):

  • You have the right to request and receive information on Reggie ’s data collection practices during the preceding twelve (12) months, including the categories of Personal Information we have collected, disclosed for a business purpose and/or sold; the sources from which we collected Personal Information; our business use of Personal Information; and the categories of third parties to whom we disclosed your Personal Information.
  • You have the right to request and receive information on Reggie ’s data sharing practices including the categories of Personal Information we have shared for a business purpose or sold and the categories of third parties receiving such information.
  • You have the right to request and receive the specific pieces of your Personal Information that we have collected.
  • You have the right to have your Personal Information that we have collected deleted, subject to certain exceptions, including legal compliance.
  • You have the right to opt-out of the sale of your Personal Information to third parties.
  • You have the right not to be discriminated against because you exercised any of your CCPA Rights.
  1. Personal Information We Collect

Reggie  collects the categories of Personal Information described in this Section A.  We obtain the categories of Personal Information from Customers and individuals who provide information about themselves and through technology we employ such as cookies and similar technologies. We use the Personal Information as described in Section C of this Privacy Notice.

  1. Recent Disclosures of Personal Information for a Business Purpose
  2. Personal Information Disclosed: In the preceding twelve (12) months, Reggie may have disclosed the following categories of Personal Information for a business purpose as described in Section C of the Privacy Notice.
  3. Identifiers.
  4. California Customer Records Personal Information categories.
  5. Commercial information.
  6. Internet or other similar network activity.
  7. Geolocation data.
  8. Inferences drawn from other Personal Information.
  9. Third Parties Disclosed To: We may disclose your Personal Information for a business purpose to the following categories of third parties:
  • Our Customers and Other Authorized Business Partners
  • Employees who are authorized
  • Agents and Service Providers such as payment processors, employee benefits providers, professional services providers, marketing partners.
  • Third parties to comply with legal process, to protect the company’s, our affiliates’, customers’, and others’ rights, property and safety, to enforce our rights and to provide security and fraud prevention.
  • Government regulators to comply with our legal obligations.
  1. Recent Sale of Personal Information

Personal Information Disclosed:  In the preceding twelve (12) months we may have shared the following categories of Personal Information for monetary consideration or for other valuable consideration such as sharing with a third party that provides us with advertising, data analysis and security services, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CCPA:

  1. Identifiers.
  2. California Customer Records Personal Information categories.
  3. Commercial information.
  4. Internet or other similar network activity.
  5. Geolocation data.
  6. Inferences drawn from other Personal Information.
  7. Your CCPA Rights and Choices

This section describes how to exercise your CCPA Rights.

  1. Access to Specific Information and Data Portability Rights. Once we receive and confirm your verifiable consumer request (see Section D(3) below (Exercising Access, Data Portability, and Deletion Rights)), we will disclose to you:
  • The categories of Personal Information we collected about you.
  • The categories of Personal Information we sold about you.
  • The categories of Personal Information we disclosed about you for a business purpose.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we sold, disclosed or shared that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
    • Sales, identifying the Personal Information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

We are not required to search for Personal Information if all of the following conditions are met:

  • We do not maintain the Personal Information in a searchable or reasonably accessible format.
  • We maintain the Personal Information solely for legal or compliance purposes.
  • We do not sell the Personal Information and do not use it for any commercial purpose.
  • We describe to you the categories of records that may contain Personal Information that we did not search because of the conditions stated above.
  1. Deletion Request Rights. Once we receive and confirm your verifiable consumer request (see Section D(3) below (Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  10. Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at info@reggieapp.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include:

Response Timing and Format

We endeavor to confirm receipt of a request to know or a request to delete within ten (10) business days, and provide information about how we will process the request. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45/90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

  1. Personal Information Sales Opt-Out and Opt-In Rights

We may share your information for monetary consideration or for other valuable consideration such as sharing with a third party that provides us with advertising, data analysis and security services, which may fall under the definition of for “other valuable consideration” which may be considered a ‘sale’ under the CCPA.

You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized agent, after providing written permission signed by you) may submit a request to us by emailing us at info@reggieapp.com  with the title “Do Not Sell My Personal Information.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.