Privacy Policy

Effective Date: May 25, 2018

OUR COMMITMENT

OpenMinded.com (“OM”), which is operated by Reflex Media, Inc. (“Reflex”), respects your privacy. We are committed to protecting the privacy of our users and we want to provide a safe and secure user experience. We will use our best efforts to ensure that the information you submit to us remains private and is used only for the purposes set forth herein.

This policy details how data about you is collected, used, and shared when you access our websites and services or interact with us (collectively, the “OM Services”).

APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all information we collect through our web and mobile applications from current and former OM users and visitors. When you are no longer our customer, we continue to share your information as described in this policy. This policy only applies to the OM Services and does not apply to the practices of any other Reflex service.

This policy also covers our treatment of any personally identifiable information that our business partners share with us.

REFLEX MEDIA AFFILIATES AND SUBSIDIARIES

Reflex is affiliated with various entities and is the parent company to various subsidiaries. These entities are as follows:

  • Clover8 Investments Pte Ltd.
  • W8 Tech Limited

INFORMATION COLLECTED

When you use the OM Services, you may be asked for certain personal information, including your name, email address, zip code, phone numbers, credit card information, occupation, hobbies and interests. Our website also automatically receives and records information on our server logs from your browser, including your IP address, browser type and OM Cookie (defined below) information.

As previously stated, we are committed to providing you a safe and secure user environment. Therefore, before permitting you to use OM’s Services, we may require additional information from you that we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship. We may also obtain information about you from third parties such as identity verification, fraud prevention, and similar services.

Reflex Media, Inc., collects data to operate effectively and provide better quality experiences. If you do not agree to our collection of the information, you may be limited or restricted in the OM Services available to you.

HOW REFLEX MEDIA, INC., USES PERSONAL DATA:

OpenMinded uses this information to:

  • Provide, maintain, and improve the OM Services;
  • Personalize the content you see;
  • Provide Customer Service;
  • Help protect the safety of OpenMinded and its users, which includes blocking suspected spammers, investigating and addressing abuse, and enforcing the OM Terms;
  • Inform you of updates to our services, security alerts, and other support and administrative messages;
  • Communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you (for information about how to opt out of these communications, see “Choices” below); and
  • Monitor and analyze trends, usage, and activities in connection with the OM Services.

WEBSITE VISITORS

We gather information about all users collectively, such as what areas users visit most frequently and what services users access the most. We only use such data anonymously. This information helps us determine what is the most beneficial for our users and how we can continually create a better overall user experience. We may share information with our partners, and anonymized, so that they may also understand how users and visitors use our services. We may use data stitching, which is the process of combining your datasets from multiple sources, to better track website use. Our Website uses Google Analytics. To learn more about how Google Analytics collects and uses data, or to opt out, click here.

INFORMATION FROM MINORS

We do not knowingly solicit, collect, or share information from any individuals under the age of 18.

COOKIES

When you utilize the OM Services, we—along with certain business partners and vendors—may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies as outlined in the “How Your Information Is Used Section.”

Certain aspects and features of the OM Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the OM Services may be limited or not possible.

DO NOT TRACK

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

SHARING INFORMATION

When you use the OM Services, certain information may be shared with other users and the public. For example:

  • When you submit a post or comment to the OM Services, visitors to and users of the OM Services will be able to see the content of your posts and comments, the username associated with your posts or comments, and the date and time you originally submitted the post or comment. Although some parts of the services may be private or quarantined, they may become public and you should take that into consideration before posting to the OM Services.
  • When you send private messages or messages, the recipients of those messages will be able to see the content of your message, your username, and the date and time the message was sent. Please use caution when sharing information about yourself to third parties, as we have no control over how they will use the information you share with them.
  • When other users view your profile, they will be able to see information about your activities on the OM Services, such as your username, prior posts and comments, etc.

We will not share, sell, or give away any of our users’ personal information to third parties, unless one of the following circumstances applies:

  • We may share information with vendors, consultants, and other service providers who need access to such information to carry out work for us. A complete list of the types of these third parties is at Appendix I at the end of this Policy. These companies may have access to your personal information as necessary to perform their functions, and they are contractually obligated to maintain the confidentiality of any personal information in which they come in contact as part of their services to OM.
  • If you participate in promotions, special offers, or other events or activities in connection with the OM Services, we may share information with entities that partner with us to provide these offerings;
  • We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to meeting national security or law enforcement requirements;
  • We may share information in response to an emergency if we believe it’s necessary to prevent imminent and serious bodily harm to a person;
  • We may share aggregated or anonymized information, which cannot reasonably be used to identify you;
  • We may share information between and among OM, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • We may share information with your consent or at your direction.

SOCIAL SHARING

The OM Services may offer social sharing features or other integrated tools that let you share content or action you take using the OM Services with other media. Your use of these features enables the sharing of certain information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third parties that provide these social sharing features.

ONLINE TRANSACTIONS

When you place an order online, your personal details and credit card information are encrypted using SSL encryption technology before being sent over the Internet. Although we cannot guarantee encryption or the privacy of your personal details, SSL makes it very difficult for your information to be stolen or intercepted while being transferred. Our credit card transactions are processed by MultiCards. All information sent to MultiCards is in the secure SSL environment, which will protect it against disclosure to third-parties. When we receive your order, it is on an SSL server. For MultiCards’ privacy statement, please click HERE. At the point when an end-user wishes to make a payment, his registration details may be passed to Paymentwall, a company that provides payment processing services, in order for Paymentwall to better protect service and end-users from unauthorized payments.

ACCOUNTS PAYABLE OR COLLECTIONS

It is your duty to make sure that you keep your account(s) in good standing with us. If you have an outstanding balance, or if you dispute your payment to us with your credit card or financial institution for any reason, please note that all information collected from your activity on our website may be disclosed to the bank and/or collections agency we work with for the purposes of establishing proof of users’ identity, proof of use, proof that service was provided, and/or collecting any outstanding debt owed to us.

INTERNATIONAL DATA

OM is a worldwide service. We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the OM Services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.

Pending Privacy Shield Approval: [In connection with OM’s processing of personal data received from the European Union and Switzerland, we adhere to the E.U.-U.S. and Swiss-U.S. Privacy Shield Program (“Privacy Shield”) and comply with its framework and principles.

For more information about Privacy Shield principles and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website.

Please direct any inquiries or complaints regarding our compliance with the Privacy Shield principles to the email listed in the “Data Protection Officer” section below. If we do not resolve your complaint, you may submit your complaint free of charge to Datavault, based in the United States. Under certain conditions specified by the Privacy Shield Principles, you may also be able to invoke binding arbitration to resolve your complaint.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share E.U. or Swiss data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of E.U. or Swiss data in violation of the Privacy Shield principles, unless we can prove that we are not responsible for the event giving rise to the damage.

PROTECTION & STORAGE OF PERSONAL INFORMATION

Your personal information is protected by physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption. For example, we use SSL encryption to safeguard your credit card data when used in e-commerce transactions. In addition, we enforce physical access controls to our offices and files, and we authorize access to users’ personal information only for personnel who require it to fulfill their job responsibilities.

We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing the username and password used in connection with your participation in the OM Services.

If OM learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the OM Services, you agree that OM may communicate with you electronically. OM may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us of your request here.

UPDATING ACCOUNT INFORMATION

OM allows you to change your personal information at any time. To do so, simply log on to OM with your username and password, and you will be able to update the information you have submitted.

CHOICES

We also provide you with the opportunity to opt-in to receive these types of communications at the time of registration, but later decide to opt out of several types of communications at the time of registration. If you no longer want to receive them, simply change your preferences on your account settings or communicate your preferences to us via email.

You may opt out of receiving promotional communications from us by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as information about your account or your use of the OM Services.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

As a Data Subject in the European Economic Area, you have the right to request, access, rectify, withdraw, delete, and restrict how we process your Personal Data. These rights include the ability to review the Personal Data we have in our Information and Communications systems concerning you, the ability to make any corrections to that Personal Data, the ability to be informed of who that data may have been shared with, the ability to withdraw your consent for Reflex to process your Personal Data, the ability to request that we delete all of your Personal Data, and the ability to restrict how we process your Personal Data.

CHANGES TO OUR PRIVACY Policy

We may update this Privacy Policy from time to time. We will place any updates to this policy on our website. You may also request a paper copy of the Privacy Policy by contacting us at the email or address noted below. You are bound by any changes to the Privacy Policy by using the OM Services after such changes have been posted to the website.

DATA PROTECTION OFFICER

To communicate with our Data Protection Officer, please email [email protected] .com

CONTACT US

Whether you live in the United States or outside the United States, Reflex Media, Inc. is responsible for your information. If you have any questions, you can contact Reflex Media, Inc. via the following email [email protected] .com or at the following address Reflex Media, 3250 Pepper Ln, Las Vegas NV 89120.

You can also contact our Data Protection Officer at the e-mail noted above.

APPENDIX I

Types of Reflex Vendor Third Parties

  • Web server hosting
  • Data analysis
  • Marketing services
  • Security services
  • Card and payment processors

To receive a copy of the complete list of third parties, please send an email to [email protected] .com with the Subject Line: Request for Third Party Information.  Use of the list is limited to compliance with Privacy Shield requirements. The list is proprietary and confidential and may not be used for any other purpose or distributed in any form; violation of this requirement is a violation of the Terms of Use governing this site, and its use and is subject to the Commercial Use provisions in the Terms of Use.

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