“Personal Data” means individually identified and/or identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or could reasonably be linked, directly or indirectly, with a particular individual, collected on the Website through the Tool, or as otherwise defined in the GDPR.
“Visitor” or “User” or “you” means visitors of the Website.
“GDPR” means the General Data Protection Regulation (EU) 2016/679, as amended from time to time.
“CCPA” means the California Consumer Privacy Act of 2018.
“Services” means any services provided by ReigNN in connection with the Website and/or the Tool.
“Tool” means a code operated by ReigNN which is installed on the Website operated by ReigNN and is used for the collection and process of your behavior within the Website in order to track the analytics of the User’s behavior within the Website and for best suit the format of advertisements while visiting the Website using ReigNN’s technology.
“Website” the public website which is operated by ReigNN, in which the Tool is installed and used, and from which you were referred to this Policy.
This Policy was originally written in English. If you are reading a translation and it conflicts with the English version, please note that the English version prevails.
- COLLECTION OF PERSONAL DATA – GENERAL PROVISIONS
We collect Personal Data by automated means through our Tool.
We hereby inform you, and you hereby acknowledge that you have no legal obligation to provide us with any Personal Data (or any other Information) when you use our Services, and the provision of it is solely based on your free will. However, without the provision of your Personal Data, we will not be able to enable you to access and/or use our Services.
- THE TYPES OF PERSONAL DATA COLLECTED THROUGH THE TOOL
THE PERSONAL DATA THAT WE COLLECT OR GENERATE
While your use of the Website, through our Tool, we will collect and/or process Personal Data regarding your use of the Website which may include behavioral data.
In addition, if you browse the Website, we may collect Personal Data through the Tool, which may include (by way of a non-exhaustive list): your device ID, computer’s Internet Protocol address and your Geo location- including region and country, through the use of “cookies” as detailed below. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes.
We use automated devices and applications to evaluate usage of our Services. We use these tools to help us improve the performance and user experience of the Website and the Tool. We may also engage third parties to track and analyze data or provide other services on our behalf. Please note, This Policy does not cover such third parties’ use of the data and such use is governed by such third parties’ privacy policies. Other websites and applications may also place or read cookies on your computer’s browser. Please see below “SHARING INFORMATION WITH OTHERS”.
- HOW WE USE PERSONAL DATA COLLECTED THROUGH THE TOOL
Personal Data is used for the following primary purposes (as may be updated from time to time): to (i) adjusting advertising content; (ii) monitor and analyze use of the Website and study and analyze the functionality of the Website and the Tool; (iii) disclose to third party vendors, service providers, contractors or agents who perform functions on our behalf with respect to the Tool; (iv) to create aggregated statistical data and other aggregated and/or inferred non personal data, which we or our business partners may use to provide and improve the Website and the Tool; and (v) For any other legitimate purpose.
We may also use information about you in order to: (i) compile anonymous or aggregate non personal data, (ii) disclose to third party vendors, service providers, contractors or agents who perform tasks on our behalf in connection with our Services or the Tool and (iii) provide us with statistical data.
- THE LEGAL BASIS FOR USE OF PERSONAL DATA
We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your Personal Data.
When collecting Personal Data through the Tool, the legal basis will be: (i) you consented to the processing of Personal Data by ReigNN; (ii) processing is necessary for the purposes of the legitimate interests pursued by ReigNN.
It is hereby clarified that the legal bases detailed above are the legal bases for actions to process Personal Data, carried out by us in accordance with the GDPR. If processing of Personal Data is subject to other applicable laws, then the legal basis for processing Personal Data may differ according to those applicable laws.
For more information, see Section “YOUR RIGHTS” below.
Cookies are a commonly-used web technology that allow websites and apps to store and retrieve certain information on a user’s system, and track users’ online activities. We and our service providers may collect information about your use of our Services by such automated means. List of the cookies and similar technologies (eg. pixels) that are placed by in the Website in order to collect this information is set forth in our cookies policy, available at: https://freshedits.com/cookie-policy/.
- SHARING INFORMATION WITH OTHERS
Service Providers and Business Partners: We engage service providers to facilitate the collection of information through the Website and the Tool and the functioning of the Website and the Tool (such as cloud vendors, hosting services, data analytics services, legal, financial and compliance advisors). In the past twelve (12) months, we have shared your internet and other electronic network activity information and geolocation with these service providers to facilitate the operation of the Website and the Tool.
IT: In the preceding twelve (12) months, we have shared your internet and other electronic network activity information with IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair errors, and maintain and improve the operation of the Website and the Tool.
For A Sale: Reignn does not sell Personal Data collected through the Website.
Affiliates: Your Information may be shared with any of our affiliates where we consider that it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of Services to our Users, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance.)
Compliance with Applicable Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws. Such disclosure or access may occur if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Enforce Our Rights: We may disclose Personal Data collected through the Website or the Tool in order to establish, protect, or exercise our legal rights, as required to enforce our policies or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights; or take any action in case of dispute involving you with respect to our Services.
Business Transfers: We may share Personal Data collected through the Website or the Tool in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- TRANSFER OF DATA OUTSIDE YOUR TERRITORY
We store process or maintain Personal Data collected through the Website or the Tool in Israel and the US. We use appropriate safeguards for such processing and for the transfer of Personal Data to our service providers and/or data processors including, where required, entering into data processing agreements and executing standard contractual clauses as required by applicable data protection laws.
- YOUR RIGHTS
You may have the right to review your Personal Data that is stored in our database(s) and provide a request for update, amendment and/or deletion of your Personal Data, by contacting us at email@example.com.
If you are a resident of the EEA, you have the following rights:
Access, Correction and Erasure Requests: You have the right to (i) ask us to confirm whether we are processing your Personal Data; (ii) receive information on how your Personal Data is processed; (iii) obtain a copy of your Personal Data; (iv) request that we update or correct your Personal Data; (v) request that we delete Personal Data in certain circumstances.
Right to Object to Processing: In certain circumstance, you have the right to request that we cease processing of your Personal Data.
Right to Restrict Processing: In certain circumstance, you have the right to request that we limit the processing of your Personal Data.
Data Portability: You have the right to request that we provide you or a third party that you designate with certain elements of your Personal Data in a commonly used, machine readable format. Please note, however, that data portability rights apply only to Personal Data that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
Right to access: You have the right to request what Personal Data we have collected, used, disclosed, and sold about you within the preceding twelve months. You may only make a request for access twice within a twelve-month period.
Right to deletion: You have the right to request the deletion of your Personal Data that we collect or maintain, subject to certain exceptions.
Right to opt-out: You have the right to opt-out of the sale of your Personal Data to third parties. ReigNN does not have actual knowledge that it sells Personal Data of minors under the age of sixteen years.
Right to non-discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your Personal Data. We do not currently sell any of your Personal Data under Nevada law. To exercise your right to opt-out of the current or future sale of your Personal Data, you may submit a request by contacting us at firstname.lastname@example.org.
When you ask us to exercise any of your rights under this Policy and the applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data related to others and to ask you questions to better understand the nature and scope of Personal Data that you request to access.
We may redact from the Personal Data which we will make available to you, any Personal Data related to others.
We will act in accordance with applicable laws in order to comply with your request. Your rights may differ depending on your jurisdiction and applicable law.
However, we may retain certain information about you as deemed required by us in accordance with applicable laws, or for legitimate business reasons, for the duration as required under applicable laws.
- DATA SECURITY
We take the safeguarding of your information very seriously, and use a variety of systems, applications and procedures to protect your information from loss, theft, damage or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict access to the information. We also regularly monitor our systems for possible vulnerabilities and attacks. These measures provide sound industry standard security. However, although we make efforts to protect your information, we cannot guarantee that the Website operated by ReigNN and/or the Tool will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
We will make any legally required disclosures in the event of any compromise of Personal Data. To the extent the law allows us to provide such notification via e-mail or conspicuous posting on the Website, you agree to accept notice in that form.
- DATA RETENTION
We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable laws. We may retain Personal Data for as long as necessary to support the collection and the use purposes under this Policy and for other legitimate business purposes, for example, for storing data, for documentation, for cyber-security management purposes, legal proceedings and tax issues. We may store aggregated non personal data without time limit. In any case, as long as you use the Tool, we will keep information about you, unless we are legally required to delete it, or if you exercise your rights to delete the information in accordance with applicable laws.
Please note that except as required by applicable laws, we will not be obligated to retain your information for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.
- OUR POLICY TOWARD CHILDREN
The Website and/or the Tool are not meant to be used by or for persons under the age of 18, as such, we do not knowingly collect Personal Data from minors younger than 18. If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will endeavor to delete such information from our systems. Insofar as Personal Data may be collected based on your consent, the data subject must be above the age of 16 (or above the age of 13 if this is the legal requirement in your country). If these age requirements are not met, you are required to obtain the consent of the parent or guardian to provide and process Information in accordance with this Policy; lacking such consent, please do not use the Website and the Tool.
If we need to adapt the Policy to legal requirements, the amended Policy will become effective immediately or as required.
Where such changes will require your specific consent under applicable laws, we shall obtain it before applying the changes to the processing of your Personal Data, Otherwise, your continued use of the Website with the Tool, following such notice, shall constitute your consent to any changes made and a waiver of any claim or demand in relation to such changes. If you do not agree to the new or different terms, you should not use our Services.
- CONTACT US
For further information about this Policy, please contact us at email@example.com.
If you have concerns about our data practices or the exercise of your rights, please contact us and we will make good-faith efforts to address your concerns or the supervisory authority in the Member State of your residence.
Copyright © 2021, Reignn All rights reserved.
Last Updated: December 2nd, 2021