Privacy Policy

We at Reaction Wellness Ltd. ("Reaction" or "us") respect your privacy and are committed to maintain your right to privacy.

This Privacy Policy ("Privacy Policy") governs the processing and transfer of Personal Data collected in connection with our Platform, available at: http://www.reaction-club.com ("Platform") or via our application ("Application") and other services provided by Reaction, whether via the Platform or Application (the "Services"), to each person ("User" or "You") accessing or using the Platform, Application or the Services.

Please be aware that you are not obligated to provide us with any data, however, if you choose to use, interact with the Platform, Application or register for the Services, or otherwise provide data to us, you expressly agree to the use of such data in accordance with this Privacy Policy. You may not use the Services, Application or the Platform or submit any data through them if you do not agree to any of the terms of this Privacy Policy.

1. What Is Personal Data, And What Data Is Collected?

"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.

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.

Personal Data

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.

Health and Fitness Data: If you connect third-party health services such as Google Fit, Apple Health, or Android Connect, we may collect health and fitness data (e.g., step counts, activity levels) to deliver personalized features and enhance your user experience. The specific data collected depends on the permissions you grant during the integration process.

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.

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.

4. What Will Reaction Do With My Data?

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.

Personal Data

Personal Data is used only for the following limited purposes:

• Operate, maintain and provide you with the Platform, Application or Services.
• For the purposes of our legitimate interests, such as, use of anti-fraud protection.
• Enhance, upgrade or modify the Platform, Application or Services, and create new features, products and services.
• Protect Reaction's or third parties' rights, property or safety.
• Assist us in resolving any service and support issues.
• Communicate information to you, including with respect to the Platform, Application or Services.
• Process health and fitness data to provide personalized wellness programs, track user progress, and optimize features.

5. Cookies and Pixel Tags/Web Beacons

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.

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.

6. Users' Rights With Respect to Personal Data

Erasure and Restriction: In accordance with applicable law, you might have the right to request the restriction or erasure of your Personal Data. If you revoke your permission to share health and fitness data through third-party services, we will cease collecting this information.

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 to: DPO@reaction-club.com

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.

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.

7. With Whom Does Reaction Share My Personal Data?

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 under limited circumstances such as:

• As required to trace, track and prevent unlawful, harmful or illegal acts
• For the purpose of legal compliance with applicable laws and regulations
• Sharing it with Reaction's trusted partners and third parties in connection with the provision of the Platform, Application or Services
• Sharing based on your express consent or instructions to do so

Third-Party Service Providers

We collaborate or use the services of the following third-party service providers:

• Amazon Web Services (AWS) – Privacy Policy
• Google Analytics – Privacy Policy
• BugSnag – Privacy Policy
• Mixpanel – Privacy Policy

8. International Data Transfer

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.

9. 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. Health and fitness data collected from third-party platforms is encrypted during transmission and stored securely.

10. Promotional Materials

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

11. GDPR Compliance

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.

"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.

12. 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.

13. 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