Privacy Policy

1. What Is Personal Data, And What Data Is Collected About Me By Reaction?

“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

1. 1 Non-Personal Data

We collect non-Personal Data regarding Users concerning their use of the Platform, Application and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Platform, Application or Services, and other technical information regarding the device used to access the Services, such as model, operating system, etc.

1. 2 Personal Data​​

1. 2. 1.  Account Registration. If you choose to register to an account as part of the Services, you will be requested to provide certain Personal Data, such as your full name, phone number, e-mail address, company details such as, company name, country, company, etc. If you choose to use the “Contact Us” feature on our Platform or Application, you will be requested to provide certain Personal Data, such as full name, e-mail address, etc.

1. 2.2 Platform. When you interact with our Platform, we may collect additional information, such as purchased products/services, session duration, page impressions, advertisements viewed or clicked on, and Internet protocol (IP) address. Reaction also collects certain data regarding your use of the Platform, such as the frequency and the extent of your use.

1. 2.3 Application:
   

   1.2.3.1  When you use the Application, certain features may provide you the choice of allowing Reaction access to your location, camera, photo gallery or other features as required to provide you with the features or services you have requested. By choosing each such feature you expressly consent to Reaction accessing your mobile device in such manner and allowing us to extract the relevant data for the provision of the Services. If you wish to disable this functionality, you may do so via the menu of the Application.

   1.2.3.2   Without derogating from the foregoing, please note that we need your permission to do things like using your mobile device features, and sharing some of your content, with respect to certain features of the Application if you so choose to use them. Our Services also provide you with features like photo thumbnails, document previews, commenting, editing, sharing, and searching. These and other features may require our Application or systems to access, store, and scan your content. You hereby give us express permission to do those things in accordance with the terms of this Privacy Policy. If you wish to rescind the foregoing consent you may do so via the features of the Application or by contacting us at:​ dpo@reaction-club.com 

   1.2.4 Contractors’ Groups. Please note that our Contractors who perform services via the Platform may open a new group or sub-group and offer Users the opportunity to participate in such groups with respect to the performance of Playbooks by such Contractors. You hereby acknowledge and agree that by joining such new group or sub-group you expressly consent to providing certain Personal Data to such Contractor as required to perform the Playbooks and/or the services provided by Contractors under such group. Such Personal Data, and Contractor’s use of it shall be governed by the terms and conditions of this Privacy Policy and additional agreements entered into between Reaction and Contractor. We encourage Users to use caution with respect to the Personal Data they intend to provide in connection to such new groups or sub-groups, and to provide only the information which is required for the performance of the Playbook, and avoid sharing or disclosing any sensitive information. 

1. 2. 5  Social Networking and Logins. You may enable or log in to the Platform, Application or Services via various online third party services, such as social media and social networking services like Facebook, Google, Instagram or Twitter (“Social Networking Services”). To take advantage of these features and capabilities, we may ask you to authenticate, register for, or log into Social Networking Services on the websites of their respective providers. As part of this integration, you expressly permit us to access certain information from your profile on such Social Networking Services, as such, the Social Networking Services will provide us with access to certain information you have provided to them, and we will use, store, and disclose such information in accordance with this Privacy Policy. Please note that the way third party services (including Social Networking Services) use, store, and disclose your information is governed solely by the policies of those third party services, and we have no liability or responsibility for the privacy practices or other actions of any third-party website or service that may be enabled within the Services. You may be able to control the amount of information that is accessible to us by adjusting your account privacy settings on such Social Networking Services.

1. 2.6  We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Platform or collected by us, please inform us immediately.

2. Persons Under 18

Our Platform and Application is intended for a general audience, which is not directed to persons under 18 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 18 years old. If we become aware that a person under 18 years old has provided us with Personal Data, we will delete such data from our databases.

​3. Links to Third Party Websites/Applications

Please note that our Platform, Application or Services may link to other websites or applications of third-parties that provide useful information/services. Any information User provides on the linked pages is provided directly to this third-party and is subject to that third-party’s provider’s privacy policy. Reaction is not responsible for the content or privacy practices of websites to which it links. Links from Reaction’s platform to third parties or other sites are provided for User’s convenience. You should learn about the privacy practices of each website before providing them with Personal Data.

4. What Will Reaction Do With My Data?

4.1 Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Platform and Services, including among others, in order to measure and understand the level of engagement to our Services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Platform, Application or Services and for developing new services and features.

4.2 Personal Data. Personal Data is used only for the following limited purposes:

4.2.1 Operate, maintain and provide you with the Platform, Application or Services.

4.2.2 For the purposes of our legitimate interests, such as, use of anti-fraud protection or any other purpose disclosed to you at the time you provide Personal Data to us or with your consent, provided that such legitime interest is not restricted or prohibited under applicable law.

4.2.3 Enhance, upgrade or modify the Platform, Application or Services, and create new features, products and services, including customization of the Application or Services based on your preferences.

4.2.4 Protect Reaction’s or third parties’ rights, property or safety, including among others, protecting our databases, Platform, Application or Services from potential harmful, illegal activities, fraud, infringements of third parties’ rights or any other use of the Platform, Application or Services which is not permitted hereunder or under our Terms of Use.

4.2.5 Assist us in resolving any service and support issues, including responding to Users queries or other communications requests.

4.2.6 Communicate information to you, including with respect to the Platform, Application or Services or new features or products, or to provide you with updates relating to amendments to the Privacy Policy.

5. Cookies and Pixel Tags/Web Beacons?

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We, as well as third parties that provide content, advertising, or other functionality on our Platform, Application or Services, as applicable, may use cookies, pixel tags, local storage, and other technologies (“Cookies”) to automatically collect information through the Platform, Application or Services. We use Cookies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our Platform, Application or Services, and to recognize you across devices, customize our Platform, Application and Services, content, and advertising; measure promotional effectiveness; mitigate risk and prevent fraud; and to promote trust and safety across our Platforms, Application and Services.

Cookies can be placed on your device by the Platform operator such as Reaction, when you visit our Platform, or when using the Application, such Cookies constitute – “first party” Cookies, or by a party other than Reaction, in which case the Cookies will constitute – “third party” Cookies.

Cookies can be differentiated by their time of use:

“Session Cookies” are Cookies that exists between the time you visit a Platform or use the Application and the time you ended the particular browsing session. Session Cookies expire and are automatically deleted when you close your internet browser.

“Persistent Cookies” are Cookies that stay on your device – they do not expire and are not automatically deleted when you close your browser. The length of time Persistent Cookies stay on your device varies from Cookie to Cookie.

“Pixel Tags/Web beacons”, A pixel tag (also known as a web beacon) is a piece of code embedded on the Platform that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement, if applicable.

If you wish to disable or block the Cookies available on the Platform, Application or Services, you will have to change the settings in your browser and follow the necessary instructions to disable receipt of Cookies, however, please be aware that such blocking may prevent us from providing you parts or all of the features or Services to you. For additional information about Cookies you may refer to this site:https://www.allaboutcookies.org

If you wish not to receive Cookies from us, with the exception of technical Cookies, you may notify us by following the instructions for opting out of such Cookies on our Platforms or sending us an email to: DPO@reaction-club.com. If you are accessing our Platform from the EEA, we will not use third party Cookies and persistent Cookies without your prior consent. If you have any questions about how we use Cookies not answered in this Privacy Policy, you may contact us by sending us an email to: DPO@reaction-club.com.

6. Users’ Rights With Respect to Personal Data?

You should be aware that certain privacy laws provide users with the ability to exercise some rights regarding their Personal Data. These rights (which may differ in various jurisdictions) include such rights as:

6.1  Erasure and Restriction. In accordance with applicable law, you might have the right to request the restriction or erasure of your Personal Data, in such case we will comply with such requests, in accordance with such applicable law.  

6.2 Access, Review and Amendment. If you wish to access or review your Personal Data that is held by us you may do so by sending us a notice asking for such review to: DPO@reaction-club.com. If you find out an error or wish to amend your Personal Data, you can amend or update the data by using the relevant features in the Platform or Application of by contacting us directly.

6.3 Data Retention. Reaction shall retain Personal Data for as long as reasonably necessary: (a) to comply with applicable laws and regulations; (b) for handling complaints, legal claims or any other liability; (c) for the performance of the purposes as set forth under this Privacy Policy; (d) for research and development of the Platform, Application or Services. You should be aware that with respect to Non-Personal Data, including any anonymized data we may retain such data for as long as we require in our sole discretion.

6.4 Data Portability. In some cases, and if relevant to you and to the Services, your Personal Data will be eligible to be portable, which means you may request us to port your Personal Data, and we will comply with such request in accordance with applicable law.

Without derogating from the foregoing, if you wish to exercise any or all of the above rights, please contact our Data Protection Officer at: DPO@reaction-club.com and let us know that you wish to exercise your rights. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information in accordance with applicable law. Furthermore, you should be aware that the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

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7. With Whom Does Reaction Share My Personal Data?

We share information we have about you for the purposes described in this Privacy Policy, including to provide you with the Services you have requested. We do not rent, license, sell or provide any Personal Data about you to other people, organizations or non-affiliated companies. We may share your Personal Data only as follows:

7.1  Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.

7.2 We share Personal Data only under the following limited circumstances:

7.2.1 As required to trace, track and prevent unlawful, harmful or illegal acts, and in order to provide necessary information required for our decision-making processes with respect to our services, products and features.

7.2.2 For the purpose of legal compliance with applicable laws and regulations, including taking necessary precautions against legal liability, protecting our material interests or the material interests of Users or third parties or in case of a sale of all or subnational part of our assets or shares, including, among others, as part of a reorganization, purchase, merger or any other similar event.

7.2.3 Sharing it with Reaction’s trusted partners and third parties in connection with the provision of the Platform, Application or Services, including with respect to conducting our business and expanding our business, such as obtaining new technological products and services, security and safety, or marketing services.

7.2.4 Sharing based on your express consent or instructions to do so.

7.2.5 Customizing Users experience within the Platform, Application or Services.

7.2.6 Sharing as necessary with our subsidiaries, affiliates, or other connected companies that are part of Reaction.

7.3  Please note that we collaborate or use the services of the following third-party service providers and data processors in connection with our Platform, Application or Services. As a result, Reaction may share data regarding your use of our Platform, Application or Services with these providers. We encourage you to review the privacy policies of these third parties specified below:

• Amazon Web Services (AWS) – https://aws.amazon.com/privacy/?nc1=f_pr

• Google Analytics – https://policies.google.com/privacy

• BugSnag – https://docs.bugsnag.com/legal/privacy-policy/

• Mixpanel – https://mixpanel.com/legal/privacy-policy/

8. The Lawful Basis For The Processing of Your Personal Data?

8.1 When our customers use our Services, we may process the customer’s Personal Data in order to perform our contract with the customer;

8.2 Based on our legitimate interests for the purpose of operating, maintaining and developing the Platform, Application or Services or in case the legitimate interests of a third party require it, except where such legitimate interests are prohibited by applicable law or conflict with the legitimate interests or fundamental rights of Users.

8.3 In order to provide you with the Platform, Application or Services it might be necessary to process your Personal Data, including with respect the contract between us and our Users and customers.

8.4 Some processing activities may be based on your direct consent. In connection with such activities, you may revoke or rescind your consent, by sending us an email to: DPO@reaction-club.com. Please be aware that in the case you revoke or rescind your consent to such processing of Personal Data, we may not be able to provide you with some or all of the Services.

9. Will Reaction Transfer My Personal Data Internationally?

Our databases are currently located in the U.S and France. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

10. How we Protect Your Data?

Reaction uses security techniques to prevent your information from being unlawfully destructed or accidental loss, or accessed without authorization or improperly used or disclosed, as are customary in the industry with similar platforms and/or services, both during transmission and once Reaction receives it.  For example, we use InstantSSL Certificates, see here for more details: https://www.instantssl.com/ssl-certificate-products/https.html. These measures will be continuously adjusted and updated in accordance with current industry standards. However, although Reaction uses its best efforts in this regard and adopt what we consider to be appropriate data collection and security measures, still we cannot provide a 100% security guarantee and we cannot be held responsible for unauthorized or unintended access that is beyond our control.

11. Will I Receive Promotional Materials From Reaction?

We do not send Users any commercial or promotion information via direct mailing such as emails or SMS messaging without obtaining the User’s explicit prior consent. You may unsubscribe from receiving such communications at any time, by sending us a notification to: DPO@reaction-club.com, or following the instructions for unsubscribing included in such communications. 

​12. Applicable Laws

To the extent some of the provisions included in this Privacy Policy relate to matters regulated under the GDPR, then such provisions shall only apply to the processing of Personal Data which is subject to the GDPR. In case the GDPR shall not apply to the processing of your Personal Data, some of the provisions in this Privacy Policy may not apply to you.

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For the purpose of this Privacy Policy “GDPR” means Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

13. Comments Or Questions

If you have any comments or questions about our Privacy Policy, please contact us at DPO@reaction-club.com, and we will make every effort to resolve your concerns without delay.

Please be aware that you are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.

Reaction may, at any time and from time to time, modify this Privacy Policy. Modifications to this Privacy Policy will be posted on the Platform, Application or Services and shall be effective as of the date in which they are posted on the Platform, Application or Services.

14. Data Protection Officer

If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to amend, remove, delete, modify or transfer the data, please contact our Data Protection Officer at: DPO@reaction-club.com.

Please be sure to include your information in any correspondence to us so that we can respond to your inquiry in a timely manner.