For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), you can be referred to as the Data Subject or as the User as you are the individual using the Service.

1. The Basics

A. About Us

ReachYOURneeD is an online knowledge and information sharing platform about the day to day needs, activities and requirements of Human Life. We (“we,” “us,” “our,” and “ReachYOURneeD”) uploads the knowledge on various topics via our posts on our website and share to the “Visitor”, “viewer”, “you”, “member”, “any party” “any entity” “user”, and “your”) on their consent.

Services: We, as a team are available to

• Build the posts with beautiful and valuable information
• Query solving
• Consultation
• Webinars

Send and manage email campaigns across channels for sharing of knowledge and also serve advertisements.

B. Key Terms

In this privacy policy, these terms have the following meanings:

“Affiliate” means an entity that directly or indirectly Controls, is controlled by or is under common Control with an entity.

“Contact” is any party who may contact us through our Service. In other words, a Contact is anyone who has given their information to us or anyone who has interacted with us via the Service. For example, if you are a viewer or a subscriber to our Website, then you would be considered as a Contact.

“Control” means an ownership, voting or similar interest representing fifty percent (50%) or more of the total interests.

“Distribution List” is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).

“Member” means any person or entity that is registered with us to use the Service.

“Mobile App(s)” means any one or all of the ReachYOURneeD applications available for Members to use on their mobile devices.

“Personal Information” means any information that identifies or can be used to identify an individual directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

“Visitor” means, depending on the context, any person who visits any of our website or affiliated websites, offices, or otherwise engages with us at our events or in connection with our marketing or recruitment activities.

2. Privacy for Members

This section applies to the Personal Information we collect and process from a Member including features offered through the Service.

A. Information We Collect

The Personal Information that we collect depends on the context of your interactions with our website or our affiliated websites and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up with us and use the service, consult with our team, send us an email, integrate the Service with another website or service (for example, when you choose to connect your e-commerce account with us), or communicate with us in any other way.

This information may include:

• Business contact information (such as your name, job title, organization, location, phone number, email address, and country);
• Marketing information (such as your contact preferences);
• Account log-in credentials (such as your email address or username and password when you sign up for an account with us);
• Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
• Payment information (including your credit card numbers and associated identifiers and billing address).

Information we collect automatically: When you use the Service, we and our third-party partners may automatically collect or receive certain information (Service Usage Data) about your device and usage of the Service. In some (but not all) countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws. We and our third-party partners use cookies and other tracking technologies to collect some of this information.

Service Usage Data may include:

• Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, viewfinder size, and other information about your system and connection. If you are using our Mobile App, we may also collect information about the cellular network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s name and unique device ID, and information about the features of our Mobile App that you accessed.
• Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
• Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used, session duration, links clicked, non-sensitive text entered, and mouse movements). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service.

Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioural data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

B. Use of Personal Information

We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

• To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency.
• To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service. For example, if you use our Mobile Apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.
• To enforce compliance with our Standard Terms of Use and applicable law, and to protect the rights and safety of our Members in reliance on our legitimate interest to protect against misuse or abuse of our Service and to pursue remedies available. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content our Members send or display to ensure it complies with our Standard Terms of Use. We may or our third-party service provider may also review content that our Members send or display. This benefits all Members who comply with our Standard Terms of Use because it reduces abuse and helps us maintain a reliable platform.
• To meet legal requirements and appropriate legal mechanisms, security requirements in reliance on our legitimate interests.
• To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features. This includes adding features that compare Members’ email campaigns, using data to suggest other publishers your Contacts may be interested in, or using data to recommend products or services that you may be interested in or that may be relevant to you or your Contacts
• To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Members. Our data analytics projects use data from ReachYOURneeD accounts, including Personal Information of Contacts, to provide and improve the Service. We use information like your sending habits and your Contacts’ purchase history, so we can make more informed predictions, decisions, and products for our Members. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.
• To personalize the Service, content, and advertisements we serve to you in reliance on our legitimate interests in supporting our marketing activities and providing certain features within the Service. We and our third-party marketing and advertising partners may use your Personal Information to serve you specifically, such as to deliver gifts and promotional materials, marketing information, product recommendations, non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications), and personalized advertising about us, in accordance with your applicable marketing preferences and this privacy policy.

C. Third-Party Integrations:

We may use the Personal Information we collect or receive through the Service, as a processor.

D. Cookies and Tracking Technologies:

We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service and this may include using cookies and similar tracking technologies, such as pixels, web beacons. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behaviour, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. The web beacons allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data. We use this information to measure the performance of your email campaigns, to provide analytics information, enhance the effectiveness of our Service, and for other purposes described above.

3. Privacy for Contacts:

This section applies to the information we process about our Members’ Contacts as a data controller. Our Service is intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Service, we act as a processor on behalf of our Members. ReachYOURneeD is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, “you” and “your” refer to Contacts.

A. Cookies and Tracking Technologies

This Cookie Policy explains how (“ReachYOURneeD“, “we“, “us“, and “our“) uses cookies and similar technologies to recognize (“Visitor”, “viewer”, “you”, “member”, “any party” “any entity” and “your”) when you visit our website and inside links of website.

We and our third-party partners use cookies and tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising about ReachYOURneeD and its Affiliates. This explains what these technologies are and why we use them, as well as your rights to control our use of them. In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies?

Cookies are small data files that are sited on your computer or mobile or any device via you visit our website.

Generally, Cookies are widely used by website owners in order to make their websites work more efficiently, as well as to provide reporting information. Cookies set by the website owner are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service and this may include using cookies and similar tracking technologies, such as pixels, web beacons. For example, we use web beacons in the emails we send on your behalf, which enable us to track certain behaviour, such as whether the email sent through the Service was delivered and opened and whether links within the email were clicked. The web beacons allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data. We use this information to measure the performance of your email campaigns, to provide analytics information, enhance the effectiveness of our Service, and for other purposes described above.

Why do we use cookies?

We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. Third parties serve cookies through our Websites for advertising, analytics and other purposes. 

How can Visitor control cookies?

Visitor have the right to decide whether to accept or reject cookies. Visitor can exercise the cookie rights by setting the preferences in the Cookie Consent Manager. The Cookie Consent Manager allows the visitor to select which categories of cookies visitor can accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide the visitor with services.

If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s policies for more information.

The specific types of first and third party cookies aided through our Website and how they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit)

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs” etc.). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Website or opened an e-mail including them.

This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to know whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Do you use Flash cookies or Local Shared Objects?

Websites may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs”) to, among other things, collect and store information about your use of our services, fraud prevention and for other site operations.

If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies. Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Do you serve targeted advertising?

Third parties may serve cookies on your computer, mobile device or any other device you use to access our website to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in.

They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

B. Public Information and Third-Party Websites

• Social media platforms and widgets. The ReachYOURneeD Site include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Site and they may set a cookie to make sure the feature functions properly. We also maintain presences on social media platforms. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
• Links to third-party websites. The ReachYOURneeD Site include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
• Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our website or through social media (collectively, “Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our subsidiaries or Affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

If you no longer want to be contacted by one of our Members through our Service, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may either forward your request to the relevant Member or provide you with the identity of the Member to enable you to contact them directly.

4. Privacy for Visitors

This section applies to Personal Information that we collect and process when you visit the ReachYOURneeD sites, and in the usual course of our business activities and services. In this section, “you” and “your” refer to Visitors.

A. Information We Collect

Information you provide to us via the ReachYOURneeD Sites to inquire about us and our services. For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe. You may choose to provide additional information when you communicate or interact with us and we may keep copies of any such communications for our records.

The Personal Information we collect may include:

• Business contact information (such as your name, phone number, email address and country);
• Professional information (such as your job title, institution or company);
• Nature of your communication;
• Marketing information (such as your contact preferences); and
• Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.

Information we collect automatically through the ReachYOURneeD Sites when you visit or interact with our sites, we and our third-party partners use cookies and similar technologies such as pixels or web beacons, alone or in conjunction with cookies, to collect certain information automatically from your browser or device. In some countries, including countries in the EEA, this information may be considered Personal Information under applicable data protection laws.

The information we collect automatically includes:

• Device information: such as your IP address, your browser, operating system, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited, the web browser you used (software used to browse the internet) including its type and language), and viewfinder size and scripts errors.
• Usage data: such as information about how you interact with our emails, ReachYOURneeD Sites, and other websites (such as the pages and files viewed, session duration, links clicked, searches, non-sensitive text entered, mouse movements, operating system and system configuration information and date/time stamps associated with your usage).

B. Use of Personal Information

We may use the information we collect through our Sites and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of reasons in reliance on our legitimate interests, including:

• To provide, operate, optimize, and maintain our Sites.
• To send you marketing information, product recommendations and non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about 3^rd party products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
• To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
• To manage event registrations and attendance, including sending related communications to you.
• To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
• To help us provide, improve and personalize our marketing activities.
• To improve our Sites functioning and services.
• To conduct marketing research, advertise to you, provide personalized information about us on and off our Sites, and to provide other personalized content based on your activities and interests to the extent necessary for our legitimate interests in supporting our marketing activities or advertising our Service or instances where we seek your consent.
• To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
• To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Sites and Services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.

C. Public Information and Third-Party Websites

• Blog: We have public blogs on the ReachYOURneeD sites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.
• Social media platforms and widgets: The ReachYOURneeD Sites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our ReachYOURneeD Site, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our ReachYOURneeD Site. We also maintain presences on social media platforms, including Facebook, Twitter, and Instagram etc. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
• Links to third-party websites: The ReachYOURneeD Sites include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
• Contests and sweepstakes: We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on the ReachYOURneeD Sites or through social media (collectively, “Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service. We may share this information with our subsidiaries or Affiliates and other organizations or service providers in line with this privacy policy and the rules posted for our Promotions.

D. Cookies and Tracking Technologies

We and our third-party partners use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising about ReachYOURneeD and its Affiliates.

E. Other Data Protection Rights

Depending on the country in which you reside, you may have the following data protection rights:

• To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can contact us.
• You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your preferences.

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 efficiently to your request.

5. General Information

A. How We Share Information

We may share and disclose your Personal Information with our subsidiaries or Affiliates and to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, “you” and “your” refer to Members, Contacts, and Visitors unless otherwise indicated).

Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions.

Other examples include analysing data, hosting data, and engaging technical support for our Service, processing payments, and delivering content.

We use YouTube’s API services in connection with our Service to provide certain features. As such, you acknowledge and agree that by signing up for an account and using the Service, you are also bound by Google’s Privacy Policy.

Advertising partners: We may partner with third-party advertising networks, exchanges, and social media platforms to display advertising on the ReachYOURneeD Sites or to manage and serve our advertising on other sites. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to gather information about your activities on the ReachYOURneeD Sites and other sites in order to provide you with targeted advertising based on your browsing activities and interests.

In certain situations: we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

A potential buyer: (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our ReachYOURneeD Site.

Any other person with your consent: We may also share information with selected third parties for statistical or research purposes that has been aggregated and made unidentifiable to the third party.

B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)

If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled “Use of Personal Information”, but they typically include improving, maintaining, providing, and enhancing our technology, products, and services.

If you are a Member, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

C. Your Choices and Opt-Outs

Marketing: Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the “unsubscribe” link at the bottom of our marketing messages.

Data Analytics: Our data analytics projects use data from ReachYOURneeD accounts, including Personal Information of Members and Contacts, to provide and improve the Service.

Personalized Advertising: We may share limited Personal Information of our Members with third-party advertising networks, exchanges, and social media platforms to display advertising on the ReachYOURneeD Sites or to manage and serve our advertising on other sites

D. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect 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.

ReachYOURneeD accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Member’s ReachYOURneeD account is private, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.

E. International Transfers

Data transfers from Switzerland, United Kingdom, or the EEA to the United States

In addition, ReachYOURneeD continues to certify its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield website available here. We adhere to the Privacy Shield Principles for all onward transfers of Personal Information from the EEA, the United Kingdom, and Switzerland.

Members, Contacts and Visitors located in Australia

If you are a Member, Contact or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 (“Australian Privacy Act”). Here are the specific points you should be aware of:

• Sensitive personal information is not permitted on ReachYOURneeD platform and Members are prohibited from importing or incorporating any sensitive personal information into their ReachYOURneeD accounts or uploading any sensitive personal information to ReachYOURneeD servers.
• Please note that if you do not provide us with your Personal Information or if you withdraw your consent for us to collect, use and disclose your Personal Information, we may be unable to provide the Service to you.
• Where we collect Personal Information of our Visitors, the Personal Information we ask you to provide will be information that is reasonably necessary for, or directly related to, one or more of our functions or activities.
• Where we say we assume an obligation about Personal Information, we will also require our contractors and subcontractors to undertake a similar obligation.
• We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
  • you have consented to receive direct marketing;
  • you would reasonably expect us to use your personal details for marketing; or
  • we believe you may be interested in the material but it is impractical for us to obtain your consent.

You may opt out of any marketing materials we send to you through an unsubscribe mechanism. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as “direct marketing” under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account as permitted under the Australian Privacy Act and the Spam Act 2003.

• We may also share your Personal Information outside of Australia to our business operations in other countries. While it is not practicable for us to specify in advance each country where your Personal Information may be disclosed, typically we may disclose your Personal Information to the United States, Canada and the European Union.
• You may access the Personal Information we hold about you.

If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request. If you find that the information we have is not up to date or is inaccurate or incomplete, please contact us in writing. So we can update our records. We will respond to all requests for correction within a reasonable time.

• If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.

F. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Service.
• Whether our Members have the ability to access and delete the data within their ReachYOURneeD accounts.
• Whether our Members would reasonably expect that we would retain the data until they remove it or until their ReachYOURneeD accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or de-identify it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

G. California Privacy

The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Members with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

When offering services to its Members, ReachYOURneeD acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Members in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Member with whom you have a direct relationship.

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

H. Do not Track

Certain state laws require us to indicate whether we honour “Do Not Track” settings in your browser. ReachYOURneeD adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

I. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the ReachYOURneeD Sites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the ReachYOURneeD Site.