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1. PLEASE READ CAREFULLY
2. WHAT 'PERSONAL INFORMATION' DO WE COLLECT?
2.1. User information:
To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:
1. Information you provide us. When you register for our Services use any of our Services; and/or when you contact us directly by any communication channel (e.g., Reed Advisory Solutions LLC’s support tickets, emails), you may provide us Personal Information, such as name, email address, phone number, payment information (for Users with Paid Services), information you include in your communications with us and with other users on our platform, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
2. Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
3. Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.
2.2. Users of users ‘Personal Information’
We may also collect Personal Information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. WHY DO WE COLLECT SUCH 'PERSONAL INFORMATION'
We use your Personal Information for the following purposes:
1. To provide and operate the Services.
2. To further develop, customize, expand, and improve our Services, based on Users’ common or personal preferences, experiences and difficulties.
3. To provide our Users with ongoing customer assistance and technical support.
4. To be able to contact our Users with general or personalized service-related notices and promotional messages (as further detailed in Section 8 below).
5. To help us to update, expand and analyze our records to identify new customers.
6. To facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits.
7. To analyze our performance and marketing activities.
8. To create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services.
9. To provide you with professional assistance, only upon your request.
10. To enhance our data security and fraud prevention capabilities; and
11. To comply with any applicable laws and regulations.
We use your Personal Information for the purposes set out in Section 3 where:
1. Our use of your Personal Information is necessary to perform a contract or to take steps to enter a contract with you (e.g., to provide you with a website builder, to provide you with our customer assistance and technical support).
2. Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have; or
3. Our use of your Personal Information is necessary to support legitimate interests and business purposes (for example, to maintain and improve our Services and the effectiveness of Reed Advisory Solutions LLC by identifying technical issues), provided it is conducted in a way that is proportionate and that respects your privacy rights.
4. HOW WE SHARE YOUR 'PERSONAL INFORMATION'
We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:
Third Party Service Providers: Reed Advisory Solutions LLC has partnered with several selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).
Reed Advisory Solutions LLC may share the following categories of Personal Information with Third Party Service Providers for a business purpose:
* identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers
* commercial information, for example information regarding products or services purchased, obtained, or considered
Law Enforcement, Legal Requests and Duties: Reed Advisory Solutions LLC may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
Protecting Rights and Safety: Reed Advisory Solutions LLC may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of Reed Advisory Solutions LLC, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.
App Market Developers: As part of our App Market program, we allow third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the Reed Advisory Solutions LLC App Market (“Third Party App(s)”), in conjunction with Reed Advisory Solutions LLC.
You are solely responsible for notifying your Users-of-Users of the collection, processing and use of their Information and informing them that their Information will be transferred to and processed by Reed Advisory Solutions LLC on your behalf.
Sharing Personal Information from Reed Advisory Solutions LLC subsidiaries and affiliated companies in the European Union and Switzerland to Reed Advisory Solutions LLC’s United States subsidiary will be only when the relevant Model Standard Contractual Clauses are in place.
Connection with a Change in Corporate Control: In addition, should Reed Advisory Solutions LLC or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all its assets, your Personal Information may be shared with the parties involved in such event.
Upon Your Further Direction: Reed Advisory Solutions LLC may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.
5. WHERE DO WE STORE YOUR 'PERSONAL INFORMATION'?
Users’ and Users-of-Users’ Personal Information may be stored in data centers located in the United States of America, Ireland, Japan and Israel. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.
Reed Advisory Solutions LLC affiliates and Third-Party Service Providers that store or process your Personal Information on Reed Advisory Solutions LLC’s behalf are contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
6. USERS-OF-USERS 'PERSONAL INFORMATION'
Reed Advisory Solutions LLC may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users can import their e-mail contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Reed Advisory Solutions LLC, on the User’s behalf.
The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.
Reed Advisory Solutions LLC cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.
For more information on how Users-of-Users Personal Information may be handled by Reed Advisory Solutions LLC (which may be relevant for any specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 4, 12 and 13.
If you are a visitor, user or customer of any of our Users, please read the following: Reed Advisory Solutions LLC has no direct relationship with Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to request to access, correct, amend, or delete inaccurate Personal Information processed by Reed Advisory Solutions LLC on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If Reed Advisory Solutions LLC is requested by our Users to remove any Users-of-Users’ Personal Information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law (for example, thirty (30) days under the GDPR). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
8. COMMUNICATIONS FROM REED ADVISORY SOLUTIONS LLC
We may use your Personal Information to send you promotional content and messages by e-mail, text messages, notifications within our platform, marketing calls and similar forms of communication from Reed Advisory Solutions LLC or our partners (acting on Reed Advisory Solutions LLC’s behalf) through such means.
If you do not wish to receive such promotional messages or calls, you may notify Reed Advisory Solutions LLC at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
9. YOUR RIGHTS IN RELATION TO YOUR 'PERSONAL INFORMATION'
Reed Advisory Solutions LLC agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, Reed Advisory Solutions LLC is taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.
Before fulfilling your request, we may ask you for additional information to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g., if your request is unfounded or excessive).
You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).
If you are a Reed Advisory Solutions LLC User, and you wish to receive a copy, access and/or request us to make corrections to the Personal Information that you have stored with us (either yours or your Users-of-Users’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please contact us directly.
10. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident using the Services, the California Consumer Privacy Act (“CCPA”) may provide you the right to request access to and deletion of your Personal Information.
To exercise the right to request access to and deletion of your Personal Information, please see the information on the section 9, above. We do not discriminate based on the exercise of any privacy rights that you might have under this Section.
Reed Advisory Solutions LLC does not sell user Personal Information to third parties for the intents and purposes of the CCPA.
As informed in section 6 above, Reed Advisory Solutions LLC may collect, store and process certain Personal Information of Users-of-Users, solely on our Users’ behalf and at their direction. For such purposes, Reed Advisory Solutions LLC serves and shall be considered as a “Service Provider” and not as the “Business” (as both such capitalized terms are defined in the CCPA. Reed Advisory Solutions LLC does not and will not sell your customers’ (User-of-User) Personal Information.
Users of the Services who are California residents and under 18 years of age may request and obtain removal of content they posted by emailing us. All requests must be labeled “California Removal Request” on the email subject line. All requests must provide a description of the content you want removed and information reasonably sufficient to permit us to locate that content. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party.
11. QUESTIONS AND COMPLAINTS
12. DATA RENTENTION
We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
We maintain a data retention policy which we apply to Personal Information in our care.
Reed Advisory Solutions LLC has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic, and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
Regardless of the measures and efforts taken by Reed Advisory Solutions LLC, we cannot and do not guarantee the absolute protection and security of your Personal Information, your Users-of-Users’ Personal Information or any other information you upload, publish or otherwise share with Reed Advisory Solutions LLC or anyone else. We encourage you to set strong passwords for your User Account and User Website and avoid providing us or anyone with any sensitive Personal Information of which you believe its disclosure could cause you substantial or irreparable harm.
Furthermore, because certain areas on our Services are less secure than others (for example, if you set your Support forum ticket to be “Public” instead of “Private”, or if you browse to a non-SSL page), and since e-mail and instant messaging are not recognized as secure forms of communications, we request and encourage you not to share any Personal Information on any of these areas or via any of these methods.
If you have any questions regarding the security of our Services, you are welcome to contact us at INFO@reedadvisorysolutionsllc.com.
14. THIRD-PARTY WEBSITES
15. UPDATES AND INTERPRETATION
16. CONTACTING US
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