PRIVACY POLICY
Reflect Atlanta, LLC offers customized trainings to enhance cultural competency, mitigate bias, and foster a more inclusive workplace. Using Site, people can learn more about the professional development trainings offered by Reflect Atlanta.
This Privacy Policy describes what personal information we collect through the Platform (defined below), how we use this information, how this information may be shared, and what choices and rights you have with respect to this information. Access and use of our Platform is subject to this Privacy Policy. The collection of personal data of job applicants is governed by the Job Applicant Privacy Notice.
Our “Platform” is made up of www.reflectatl.com, and all of the related websites, mobile apps, products, software, services, programs, and networks offered by Site, including our plug-ins and browser extensions.
The terms “we,” “us,” “our,” or “Site” refer to the Reflect Atlanta and their corporate affiliates.
By “you,” we are referring to visitors and users of any part of our Platform.
The term “merchant” includes sellers and vendors of products available on the e-commerce marketplace on the Platform.
- Collection of Information
We collect personal information that you provide us, from third parties, and automatically when you use our Platform. We collect information associated with your device using cookies and similar technologies. We may also receive information about your location.
Information You Provide Us
We collect information that you provide us, including your account and profile information, content you submit or post to our Platform, your purchase information, your communications, and information you provide to us as part of surveys and contests.
Account and Profile Information. When you create an account on our Platform, we collect information you provide us, like your name, e-mail address, interests, gender, age, and profile information. If you are a professional, you may also provide us information related to your business, including a business description and areas served.
Content You Submit. We collect information and content that you submit, share, or create across our Platform and on other websites that link to this Privacy Policy. This includes information and content submitted, shared, or created including but not limited to your company information, profile picture, reviews, messages, comments, searches, photos, style preferences, discussion, project details, project costs, project timelines, change orders, and invoices.
Purchases. If you purchase or sell products or services or make or receive payments within our Platform, we collect certain information in order to complete your purchases, sales, and payments, such as your phone number, address, and payment method (for example, credit card or bank account information). If you participate in our Trade Program or Business Program, you may be asked to provide proof that you are eligible for the program or for a tax exemption.
Communications. When you communicate with us (via e-mail, phone, through our Platform, through our chatbots, or otherwise) and when you use our Platform to communicate with others, we may record, monitor, collect, and use details about you and your communications (including call time and call duration). Certain professionals on our Platform may choose to use our call tracking feature in order to better manage their business. You are using our Platform when you make calls to these professionals using their phone number displayed on our Platform. We will provide you notice or obtain your consent in accordance with applicable law before recording or monitoring any of these calls. Otherwise, to the extent you communicate with professionals, sellers, and other users outside our Platform, those communications are not subject to this Privacy Policy.
Surveys and Contests. If you participate in our surveys, contests, or promotions, we will collect the information you provide to us.
Information from Others
We collect information that others make available to us, including information from other platforms, publicly available information, information from other users of our Platform, information from our partners, service providers, and corporate affiliates, and information from third-party sites.
Other Platforms. We may receive information about you from third-party platforms when you allow the third-party platform to share this information with us or allow Site to obtain this information from the third party. For example, we may receive information such as your name, e-mail address, and profile photo when you sign-up for our Platform through Facebook, Google, or Apple. We may also receive information about you when you upload your contacts from your third-party e-mail service; use our Platform (or a third-party integration on our Platform) to manage your calendar on another platform or to manage and send communications (e.g., e-mail or text messages).
Publicly Available Information. If you are a professional or merchant, we may collect information about you from publicly available sources and where permitted by applicable law or, with your permission, make it available as part of our Platform. For example, we may receive your name and contact information from industry associations and dealer networks in which you participate and display your affiliation with these organizations. We also may collect and display the details of any license you have using publicly available records.
Other Users and Customers. Others may post content on our Platform that includes information about you (for example, as part of photos, stories, and reviews) or provide us your information in connection with using our Platform (e.g., to manage their business, organize photoshoots of their projects, participate in referral programs, and to advertise through our Platform). In order to enhance the quality of our Platform, professionals and sellers on our Platform may provide us information about your engagement with them, including whether you have contacted them or responded to them, whether your project has been completed, and whether you have received a product you have ordered. If you are a professional or merchant, Platform users and visitors may provide us with feedback and public reviews about you.
Our Partners and Service Providers. We may receive information about you from our partners and service providers. For example, our payment processors may update your payment information, advertising partners may help us send communications to your address, and third parties may help us prevent fraud by verifying your contact information. In addition, our banking partner that issues the Site credit card(s) may provide us with information regarding whether you have such a card, related to any card reward or loyalty program, or resulting from prescreening you for card offers.
Third-Party Sites. Certain third-party sites embed a Site plug-in, widget, or content, including through Site-branded buttons, badges, and slideshows and Site co-branded content partnerships. Our plug-ins, widgets, embedded content, and pixels may collect information pursuant to our Cookie Policy. You may also choose to use our browser extensions, which collect the information described in this Privacy Policy like the rest of our Platform.
Website Services. Website Services means any website displaying pro content and other content included by or on behalf of you into standard Site web templates with hosting managed by Site. As with the rest of our Platform, we collect the information described in this Privacy Policy when providing Website Services, including your messages to professionals sent through those sites. Professionals collect usage information for their websites and receive your messages sent through those sites.
Automatically Collected Information
Each time you access the Platform, information is sent to our server by your Internet browser or app and stored in our log files. We collect information about your use of our Platform, including your search activity, the pages you view, the date and time of your visit, and if you use our browser extensions, the content you interact with on third-party sites (for example, if you save an image from a third-party site to your Site account), and how you navigate and interact with a page or screen. We also collect information that your device provides to us in connection with your use of our Platform, such as your browser type, type of device, browser language, IP address, mobile carrier, unique device identifier, and requested and referring URLs.
Cookies and Similar Technologies
We use cookies and similar technologies in connection with your use of our Platform to collect information related to what you see and interact with on our Platform and other Platform access and use. Please see our Cookie Policy for more information on our use of cookies and how to accept or opt-out of cookies, but please note that unless required by law, we do not change system behavior within our Platform in response to browser requests not to be tracked.
Location Information
We will receive your device’s location if you enable this through your browser or mobile device. We may infer your general location from your IP address. You may also choose to provide us your location information by inputting this information in our Platform, including in your Site settings, or when you checkout as a shipping or billing address. - Use of Information
We use the personal information we collect to provide, support, and personalize our Platform and to communicate with you about our Platform (on and off our Platform). The ways we do this include the following:
a. to provide and improve our Platform and its features and functionality, including to display content you post publicly, fulfill your purchases through our Platform, process, store, and deliver your communications; to provide customer service and support; to respond to your inquiries or requests; to back-up our systems; and to improve the security of our Platform;
b. to evaluate use of our Platform for our business purposes and to provide and improve our products and services, including new and co-branded products and services and our Platform’s functionality;
c. to personalize your experience, such as tailoring the content and information made available to you and our support services;
d. to display relevant or targeted advertising (on our Platform and third-party sites) for us and other businesses and to evaluate the success of such advertising;
e. to provide feedback to professionals and merchants on our Platform;
f. to communicate with you as described in our agreements with you (for example, the Site Terms of Use) or this Privacy Policy;
g. to prevent fraud and to maintain a quality experience for our business purposes or legal reasons, including to filter for spam and communications that violate our agreements with you (for example, the Site Terms of Use);
h. to enforce compliance with our agreements with you (for example, the Site Terms of Use) and applicable law; to comply with our legal obligations; to prosecute or defend a lawsuit, arbitration, or similar legal proceeding; to respond to lawful requests by public authorities (including national security or law enforcement requirements);
i. to perform research and analysis for our business purposes and to conduct journalist research; and
j. to award badges and similar designations and if you decide to participate, to administer surveys, contests, and promotions.
If you provide us information about your contacts (for example, when you sign up for our Platform through Facebook), in order to facilitate a more connected experience, we may inform your contacts who have accounts on our Platform that you also have joined our Platform and follow them on your behalf so that you may view their public activities on our Platform.
We may use your communications generally for quality assurance purposes and training, and to improve our products and services. We may use your communications to understand and help manage the quality of requests received, and responses sent, by professionals and sellers on our Platform and to provide them with feedback. We may use automated technology to review your communications and improve user experience.
We may use your log-in information, cookie information, device information, IP addresses, and other information to identify you and log your use across devices, our Platform, and third-party sites. We may use this information to personalize your experience on our Platform.
For your convenience, we and our payment processors will store information about the payment method you use in connection with the Platform. Note that while our payment processors may store your complete credit card number, Site does not. You may remove or change your payment method on Site through your settings. If you would like to change your payment method on Site and you use a credit card, please go to your settings.
If you make purchases on Site as a visitor and subsequently create an account, for your reference, we will make information available to you about any prior purchases completed using the e-mail address for your account. - Sharing Your Information
We do not rent or sell your personal contact information (such as your e-mail address associated with your account registration) to third parties to use for their direct marketing purposes. We share personal information in the following ways:
Platform Visitors and Users
Professionals, Merchants, and Other Businesses on our Platform
If you request us to find professionals for you, your project information (including the contact information) that you provide will be made available to a limited number of professionals that we believe may be suitable for your project. Such professionals are independent from Site and their use of your data is not covered by this Privacy Policy. Professionals and merchants that participate on the Site Platform may view your public activities on our Platform and receive feedback you provide to us about your engagement with them. For example, if you requested us to find professionals for you and provide us feedback about your level of interest in these professionals, we may convey such feedback to them. In addition, a professional or merchant can view your public activities on our Platform that are interactions with their content (for example, that you added one of their photos to your non-private account on a particular date, as identified by the username for your profile and any photo or public identifiers you provide for your profile). When you receive messages from professionals through the Platform, Site and the professionals can track your interaction with these messages, including whether you opened the messages or documents shared with these messages. A professional or merchant cannot see your non-public account information or see private activity (for example, if your account is private).
Service Providers and Partners
We may share your information with service providers and partners as reasonably needed for our uses described in this Privacy Policy, including entities that help us sell and deliver products to you, such as merchants, payment service providers, logistics professionals, delivery and freight companies, and entities that host data for us or help us understand user behavior on our Platform. You can find more information here about our service providers and partners with which we may share your information. Only if you specifically agree to share your contact information with a third-party partner, for example, as part of a contest or promotion we sponsor with such a third party, will we share your contact information with that third-party partner for their direct marketing purposes.
In addition, we may share information about you with third-party platforms when you allow the third-party platform to receive this information from us or allow Site to share this information with the third party. Our Platform may include third-party social media features and other third-party plug-ins and widgets. When these features are displayed on our Platform, they are operated or hosted by third parties. We are not responsible for these third parties and third-party platforms, so please carefully review their privacy policies and your permissions granted to these third parties and platforms. For example, you may sign-up for our Platform through Facebook, Google, or Apple.
Advertisers and Ad Networks
We use advertising networks and partners to serve advertisements for us and other businesses, including interest-based advertising, on third-party sites and to assist us in evaluating the effectiveness of our advertising. We may also work with advertising networks and partners to serve ads on our Platform and to communicate with you at the addresses they have for you. We may provide advertising networks, advertising partners, and businesses advertising on our Platform with aggregate information but other than hashed information or device identifiers, we do not disclose your name, contact information, or other personal information. For example, we may provide a hashed version of your e-mail address or other information to advertising networks (e.g., Facebook and Google) to serve advertisements to you or others. To opt-out of the use of your information for this purpose, please send a request as provided under the Contact Us section.
We and the businesses advertising on our Platform, advertising networks, and advertising partners may also use cookies or similar technologies to track your activities on our Platform and other online properties in order to provide you with tailored ads across websites, apps, and devices and to understand how those ads perform. To learn how to opt-out of receiving this type of advertising, please see our Cookie Policy.
Corporate Affiliates and Business Transfers
We may share information from or about you with (a) joint ventures or other companies in the Site, or (b) a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in bankruptcy or similar proceedings). In these cases, their use will be subject to this Privacy Policy.
Legal Obligations
We may disclose information from or about you, as required or permitted by applicable law, if we believe that such disclosure is reasonably necessary to (a) comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us, a service provider, or a partner (which may include disclosure to law enforcement, courts, or governmental authorities); (b) prevent, investigate, or identify possible wrongdoing in connection with our Platform; (c) protect our rights, reputation, property, or that of our visitors, users, corporate affiliates, or the public; or (d) enforce compliance with our agreements with you (for example, the Site Terms of Use). - Communications
An essential part of our services that you sign up for when you create an account on our Platform is to receive communications from us or our professional partners through e-mail, phone call, and text message, or through our Platform. If you use our mobile app, these communications also include push notifications. We communicate with you about your account, privacy, use of the Platform, including interactions with your content, news relating to the Platform, its features and industry developments, and communications concerning promotions run by us or third parties. We also ask for your feedback about your experience in connection with our Platform. In accordance with applicable law, we or our professional partners may send you marketing communications (e.g., with tips, offers, and similar services). These communications may feature us, our Platform, co-branded products and services, professionals, merchants, and other businesses on our Platform.
If you provide us your phone number, we and our professional partners may call you or send you text messages to help you with using the Platform. If you are a professional or other business, we may use your contact information (whether publicly available or provided to Site) to call and otherwise contact you about our Platform, including to market and sell our products or services or those available on our Platform.
You may change your communication preferences at any time through your Site settings if you have a Site account, and you may also opt-out of similar types of marketing e-mails from us directly through the e-mail. To opt-out of our text messages at any time, you can follow the instructions provided in the text message, which typically is to reply “STOP.” You may opt-out of sales and marketing phone calls from us by letting us know during the call or by contacting us as described in the “Contact Us” section. Please be aware that you cannot opt-out of receiving necessary account- and privacy-related messages from us. If you wish to stop receiving push notifications from us, you can turn off push notifications for the mobile application in the settings of your mobile device.
Our Platform also allows you and others to send messages and make calls in our Platform, share content with others outside our Platform, and if you make your contact information available, for others to contact you outside of our Platform. - Your Choices and Rights
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond to your request securely and efficiently.
Even where not legally required, we will use reasonable efforts to complete requests to access or delete your personal information. You may request to receive a copy of your Site information through your Site settings and clicking on Download a Copy of your Data. You may also access your Site information by contacting us as provided in the Contact Us section. To request permanent deletion of your personal information, please contact us as described in the Contact Us section or go to your Site settings and click on Delete my Site Account as further outlined here.
To edit your personal information, you can manage your profile in your Site settings. You may also contact us about correcting or updating your personal information (including your marketing preferences) using the methods provided in the Contact Us section. We will consider your request in accordance with applicable laws. - Account Termination and Data Retention
You can request to deactivate your Site account at any time by going to your Site settings or contacting us as described in the Contact Us section of this Privacy Policy. When you deactivate your account, you will cease to provide ongoing or future data to us that is associated with your account. Your Site profile will no longer be accessible on the Platform but in accordance with applicable law and the Site Terms of Use, your photos, reviews, and other content may still be available through our Platform. In order to request permanent deletion of the personal information associated with your account, please contact us as described in the Contact Us section.
We will keep your personal information only for as long as necessary to fulfill the purposes for which we are processing your personal information unless the law permits or requires us to retain your personal information for a longer period. For example, we may need to keep your personal data to provide services on our Platform or to defend future legal claims. We also will retain de-identified information after your account has been deleted. Information you have shared with others will remain visible after your account has been deactivated or deleted and after the information has been deleted from your own profile or account. We do not control information or content that others have copied out of our Platform. Please note that copies of information that you have updated, modified, or deleted may continue to reside in our systems for a period of time, and we may maintain copies of this information as part of our business records. - Children
Our Platform is intended for general audiences and is not directed to children under 18. We do not knowingly collect personal information from children under 18. In the event that we learn that we have collected personal information from a child under age 18, we will take reasonable steps to delete that information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in the Contact Us section. - Data Security
We use reasonable measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. - Updates to this Privacy Policy
We may revise this Privacy Policy from time to time. The most current version of our Privacy Policy will govern our use of information about you. If we make material changes to our Privacy Policy, we will notify you by e-mail or by posting a notice on our Platform or by other means, to offer you an opportunity to review the changes before they become effective. By continuing to access or use our Platform after those changes become effective, you are subject to the revised Privacy Policy. - Contact Us
If you have questions or comments about this Privacy Policy (including about the manner in which we or our service providers treat your personal information), you may contact us in the following ways:
shadi@reflectatlanta.com. - International Transfers of Personal Information
Site may process your personal data among affiliates of the Site outside your local jurisdiction. Many of Site’s third-party processors also are based in different jurisdictions.
Historically, Site has complied with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information (as defined in these Frameworks) transferred from countries in the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland, as applicable, to the United States. On July 16, 2020, however, the Court of Justice of the European Union issued a judgment declaring as “invalid” the European Commission’s Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield. As a result of that decision, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism to comply with EU data protection requirements when transferring personal data from the European Union to the United States. That decision does not relieve participants in the EU-U.S. Privacy Shield of their obligations under the EU-U.S. Privacy Shield Framework.
We may receive from the EEA, UK, and Switzerland some or all of the information listed in the Collection of Information section of this Privacy Policy. Some of that information may qualify as personal information. We may use the personal information we receive from the EEA, UK, and Switzerland for the purposes set forth in this Privacy Policy or as you may otherwise be notified. In case we transfer personal data outside of the EEA, the UK, or Switzerland, we will make sure that (a) the recipient is based in a jurisdiction that the European Commission has decided maintains an adequate level of protection for personal data, or (b) the recipient has enacted appropriate safeguards under Article 46 of the GDPR (such as for example Binding Corporate Rules or EU Standard Contractual Clauses).
Onward Transfer
In the Sharing Your Information section of this Privacy Policy we describe our data sharing practices. We may also be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We may use third parties to process data on our behalf as described in this Privacy Policy.
Access and Choice
EEA, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to them. As an individual from the EEA, UK, or Switzerland, you may also request to correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate personal information, should direct their query as provided in the Contact Us section.
You can manage your profile and settings within our Platform.
Dispute Resolution
European Union, UK, and Swiss individuals with privacy inquiries or complaints should please contact us first as described in the Contact Us section. - Additional Information for Individuals in California, Virginia, Colorado, and Connecticut
This section provides notice and specific information to consumers in California, Virginia, Colorado, and Connecticut, including information required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively “CCPA”), the Virginia Consumer Data Protection Act, the Colorado Consumer Privacy Act (effective July 1, 2023), and the Connecticut Data Privacy Act (effective July 1, 2023). Please note that the notice, information, and rights for residents in Colorado and Connecticut are only effective July 1, 2023.
We do not disclose your data in exchange for money except at your request or direction. However, we disclose certain of your contact information and identifiers, commercial information, and Internet activity information to professionals, vendors, and sellers on our Platform, advertising providers, and other service providers in exchange for services, including behavioral and targeted advertising services, which may constitute a data “sale” and “sharing” under some privacy laws, including the CCPA. You may opt-out of these disclosures of your data and opt out of our processing of your information for targeted advertising here if you are a resident of California, Virginia, Colorado, and Connecticut. As provided in our Terms of Use, use of the Site Platform by anyone under 18 years of age is strictly prohibited.
Consequently, we do not knowingly disclose information regarding individuals under 18 years of age to third parties in exchange for consideration. We do not use or disclose sensitive personal information for purposes other than those set forth in the CCPA.
In addition to the rights described above and in the Your Choices and Rights section, California residents may also, subject to certain exceptions, request us to provide information about how we have used and shared your personal information. Residents of California, Virginia, Colorado, and Connecticut also have the right to request correction of inaccurate personal information. Residents of Virginia, Colorado, and Connecticut have the right to confirm whether Site is processing their personal information. Please submit these requests for information, as well as requests to access, correct, or delete your information, through this online support form, through your privacy settings, or by e-mailing us at shadi@reflectatl.com. Residents of Virginia, Colorado, and Connecticut may appeal Site’s decision regarding their request by contacting us at shadi@reflectatl.com. Consistent with applicable privacy laws, except to the extent reasonably related to the value of your personal information, we will not treat you differently for exercising your rights under these laws.
Your authorized agent may exercise your data protection rights on your behalf via this online support form or by e-mailing us at shadi@reflectatl.com. We may still require you to directly verify your identity and confirm that you have provided the authorized agent permission to submit the request. Whether you submit your request directly or through an authorized agent, generally, the only means Site has to verify your identity is for you to respond to a specific Site e-mail from the Site support team from the e-mail address associated with your Site account or to click a confirmation or similar button in a specific Site e-mail from the e-mail address associated with your Site account.
We collect, use, and disclose personal information for the following purposes:
a. to provide and improve our Platform and its features and functionality;
b. to evaluate use of our Platform for our business purposes and to provide and improve our products and services;
c. to personalize your experience;
d. to display relevant or targeted advertising (on our Platform and third-party sites) for us and other businesses and to evaluate the success of such advertising;
e. to provide feedback to professionals and merchants on our Platform;
f. to communicate with you as described in our agreements with you (for example, the Site Terms of Use) or this Privacy Policy;
g. to prevent fraud and to maintain a quality experience for our business purposes or legal reasons (for example, the Site Terms of Use);
h. to enforce compliance with our agreements with you (for example, the Site Terms of Use) and applicable law; to comply with our legal obligations; to prosecute or defend a lawsuit, arbitration, or similar legal proceeding; to respond to lawful requests by public authorities (including national security or law enforcement requirements);
i. to perform research and analysis for our business purposes and to conduct journalist research;
j. to award badges and similar designations and if you decide to participate, to administer surveys, contests, and promotions;
k. to inform your contacts who have accounts on our Platform that you also have joined our Platform and follow them on your behalf so that you may view their public activities on our Platform;
l. to provide quality assurance purposes and training;
m. to understand and help manage the quality of requests received, and responses sent, by professionals and sellers on our Platform and to provide them with feedback;
n. to review your communications and improve user experience, including using automated technology, contact: shadi@reflectatl.com;
o. to identify you and log your use across devices, our Platform, and third-party sites;
p. to store information about the payment method you use in connection with the Platform;
q. to make information available to you about any prior purchases completed using the e-mail address for your account if you make purchases on Site as a visitor and subsequently create an account; and
r. to show you all of your payments, as well as invoices, proposals, retainers, and similar documents on a per-project basis.
You can learn more about the types of personal information that we collect, disclose for a business purpose, share for behavioral targeted advertising, disclose for valuable services, and disclose for money, about the intended data retention period for such data, and about the third parties to which we disclose such data by contacting: shadi@reflectatl.com. When you close your account, we take steps to delete your data. The Collection of Information section of this Privacy Policy describes the sources from which we collect your personal information. The Sharing Your Information section of this Privacy Policy describes the types of third parties with which we share your personal information.
Notes
General:
In the case of a business, a privacy policy is often a statement that declares a party’s policy on how it collects, stores, and releases the personal information it collects. It informs the user what specific information is collected and whether it is kept confidential, shared with partners, or sold to other firms or enterprises. Privacy policies typically represent a broader, more generalized treatment, as opposed to data use statements that tend to be more detailed and specific.
A privacy policy for an e-commerce site is similar to traditional privacy policies for other sites, although because of the nature of their use and the information that collect, e.g., information relating to payments, credit and debit cards, commercial information, geographical information, transactions, etc., such policies tend to be more specific to commercial transactions than the policies for social media sites.