Last Updated: July 3, 2023
1. Collection of Data
RFLXT collects several different types of information for various purposes in order to provide and improve the Product for your use.
Types of Data Collected
1. Personal Data
While using the Product, RFLXT may ask you to provide certain personally identifiable information that can be used to contact or identify you (“Personal Data”), which may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
Your Personal Data may be used to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email sent to you by RFLXT.
2. Usage Information
Usage Information refers to all information collected from the Product such as what action has been applied to the Product such as clicking logs; your registration details or how you may be using the Product.
3. IP Address
When you use the Product, we may automatically log your IP address (the unique address which identifies your computer on the internet) which is automatically recognized by our server.
2. Use of Data
Specifically RFLXT uses your information for the purpose for which you provided it to us such as:
- To notify you about changes to this Product
- To allow you to participate in interactive features of this Product when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve the website
- To monitor the usage of this Product
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which RFLXT offers that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Where and as permitted under applicable law, RFLXT may process your contact information for direct marketing purposes (e.g. show invitations, newsletters) and to carry out customer satisfaction surveys, in each case also by email. You may object to the processing of your contact data for these purposes at any time by writing to email@example.com or by using the opt-out mechanism provided in the respective communication you received.
3. Legal Basis under General Data Protection Regulation (GDPR)
RFLXT may process your Personal Data because:
- RFLXT needs to perform a contract with you
- You have given us permission to do so
- The processing derives from RFLXT’s legitimate interests
- RFLXT has to comply with applicable law
The legal basis for RFLXT processing data about you is that such processing is necessary for the purposes of:
- RFLXT exercising its rights and performing its obligations in connection with any contract we make with you (Article 6 (1) (b) General Data Protection Regulation),
- Compliance with RFLXT’s legal obligations (Article 6 (1) (c) General Data Protection Regulation), and/or
- Legitimate interests pursued by RFLXT (Article 6 (1) (f) General Data Protection Regulation).
Generally the legitimate interest pursued by RFLXT in relation to our use of your personal data is the efficient performance or management of our business relationship with you.
In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for RFLXT processing that data about you may (in addition or instead) be that you have consented (Article 6 (1) (a) General Data Protection Regulation).
4. Retention of Data
RFLXT will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Product, or RFLXT is legally obligated to retain such data for longer time periods.
5. Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
6. Disclosure Of Data
1. Legal Requirements
RFLXT may disclose your Personal Data in good faith belief that such disclosure is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of RFLXT
- To prevent or investigate possible wrongdoing in connection with the Product
- To protect the personal safety of users of the Product or the public
- To protect against legal liability
Disclosure of Personal Information Within The EU
Insofar as we employ the services of service providers to implement or fulfill any tasks on our behalf the contractual relations will be regulated in writing according to the provisions of the European General Data Protection Regulation (EU-GDPR) and the Federal Data Protection Act (new BDSG).”
Disclosure of Personal Information Outside of The EU
Insofar as you have selected and consented to this in the form, your data will be disclosed to our offices within the network of affiliated companies outside of the European economic area for the processing of your enquiry. These offices are legally obligated to abide by the EU-GDPR. Furthermore, between the legally autonomous companies in the network of affiliated companies written agreements exist for the processing of data on commission, based on standard EU contract stipulations.
7. Security Of Data
We use reasonable technical and organizational methods to safeguard your information, for example, by password protecting (via usernames and passwords unique to you) certain parts of the Product and by using SSL encryption and firewalls to protect against unauthorized access, disclosure, alteration or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.
Whilst we will use all reasonable efforts to safeguard your information, you acknowledge that data transmissions over the internet cannot be guaranteed to be 100% secure and for this reason we cannot guarantee the security or integrity of any Personal Information that is transferred from you or to you via the internet and as such, any information you transfer to RFLXT is done at your own risk.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using this Product or providing Personal Information to us you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of this Product. We may post a notice on our Product if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
8. Rights Under General Data Protection Regulation (GDPR)
If you are a citizen or resident of a member country of the European Union (EU) or the European Economic Area (EEA), you have certain data protection rights. RFLXT aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data RFLXT holds about you and if you want it to be removed from our systems, please contact us firstname.lastname@example.org
In certain circumstances, you have the following data protection rights:
- The right to access.
You have the right to request information concerning the personal information we hold that relates to you.
- The right of rectification.
You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object.
You have the right to object to your personal information being used for a particular purpose and you can exercise these rights, for example, via an unsubscribe link at the bottom of any email.
- The right of restriction.
You have the right to request that RFLXT restricts the processing of your personal information
The right to data portability.
You have the right to be provided with a copy of the information RFLXT has on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent.
You also have the right to withdraw your consent at any time where RFLXT relied on your consent to process your personal information.
9. California Residents
If you are a California resident, you have certain rights with respect to your personal information pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). This section applies to you.
We are required to inform you of: (i) what categories of information we collect about you, including during the preceding 12 months, (ii) the purposes for which we use your personal data, including during the preceding 12 months, and (iii) the purposes for which we share your personal data, including during the preceding 12 months.
You have the right to: (i) request a copy of the personal information that we have about you; (ii) request that we delete your personal information; and (iii) opt-out of the sale of your personal information. You can limit the use of tracking technologies, such as cookies, by following instructions in the “Your choices” section. These rights are subject to limitations as described in the CCPA.
We will not discriminate against any consumer for exercising their CCPA rights.
If you would like to exercise any of these rights, please contact us at email@example.com.
10. Service Providers, Plugins and Tools
RFLXT may use social media plugins to enable a better user experience with the use of the Product
RFLXT uses the YouTube video platform operated by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA. YouTube is a platform that enables playback of audio and video files. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. For information about the scope and purpose of data collection, the further processing and use of the data by YouTube and your rights and the settings you can configure to protect your privacy, please refer to the YouTube Privacy Guidelines.
RFLXT may use Service Providers to monitor and analyze the use of the Product.
RFLXT uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising. If you would like to opt-out of Google Analytics monitoring your behavior on the Product, please use this link: https://tools.google.com/dlpage/gaoptout/.
You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: tools.google.com/dlpage/gaoptout.
Object to the Collection of Data
Outsourced Data Processing
We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Demographic Data Collection by Google Analytics
This website uses Google Analytics' demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section "Refusal of data collection".
Google Tag Manager
This website uses Google Tag Manager. This service allows website tags to be managed via an interface. Google Tag Manager only implements tags. This means that no cookies are set and no personal data is recorded. Google Tag Manager triggers other tags which, in turn, may record data. However, Google Tag Manager does not access this data. If tags have been disabled at the domain or cookie level, this remains in place for all tracking tags if these are implemented with Google Tag Manager. You can find out more about Google Tag Manager by clicking the following link: http://www.google.de/tagmanager/use-policy.html.
RFLXT may use an online marketing tool to display adverts on the Product.
DoubleClick by Google
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no control over the extent and further use of the data collected by the use of this tool by Google and therefore inform you to the best of our knowledge: By including DoubleClick, Google receives the information that you access the corresponding part of our website or clicked an ad from us. If you are registered with a service provided by Google, Google may associate the visit with your account. Even if you are not registered with Google or have not logged in, there is a chance that the provider will find and store your IP address.
You can prevent participation in this tracking process in several ways: a) by adjusting your browser software accordingly, in particular, the suppression of third-party cookies will prevent you from receiving any third party advertisements; b) by disabling the cookies for conversion tracking by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.com/settings/ads, this setting is deleted when you delete your cookies; c) by deactivating the interest-based advertisements of the providers that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies; d) by permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link http://www.google.com/settings/ads/plugin. We point out that in this case you may not be able to use all the features of this offer in full.
This website uses Google Maps API in order to present geographical information visually. When using Google Maps, data on the use of Maps features by visitors of the website is also gathered, processed and used by Google. More detailed information on Google's data processing can be found in Google's data protection policy. You can change your settings in the data protection center so that you can manage and safeguard your data.
RFLXT may use online web fonts to display texts and fonts on the Product.
Google Web Fonts
For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO.
If your browser does not support web fonts, a standard font is used by your computer.
If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.
We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed. The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.
Newsletter tracking (also referred to as Web beacons or tracking pixels) is used if users have given their explicit prior consent. When the newsletter is dispatched, the external server can then record certain data related to the recipient, such as the time and date the newsletter is retrieved, the IP address or details regarding the email program (client) used. The name of the image file is personalized for every email recipient by a unique ID being appended to it. The sender of the email notes which ID belongs to which email address and is thus able to determine which newsletter recipient has just opened the email when the image is called.
You may revoke your consent at any time by unsubscribing to the newsletter. This can be done by sending an email to this effect to firstname.lastname@example.org. They can also remove themselves from the mailing list using the unsubscribe link in the newsletter.
Cookie Compliance Solution
By selecting the ‘Privacy Settings’ button available on each Product page, you can learn more about the cookies we use to enhance your Product experience, and you can choose not to allow some types of cookies to be set. However, please note that opting out of certain cookies may impact your Product experience, and certain services provided on our Product may no longer be available.
11. Links To Other Products
13. Data Privacy Contact
You can reach our data protection officer at email@example.com
14. Contact by E-mail or Contact Form
When you contact us by e-mail or through a contact form, we will store the data you provide (your email address, possibly your name and telephone number) so we can answer your questions. Insofar as we use our contact form to request entries that are not required for contacting you, we have always marked these as optional. This information serves to substantiate your inquiry and improve the handling of your request. Your message may be linked to various actions taken by you on the RFLXT website. Information collected will be solely used to provide you with support relating to your inquiry and better understand your feedback. A statement of this information is expressly provided on a voluntary basis and with your consent, art. 6 par. 1a GDPR. As far as this concerns information about communication channels (such as your e-mail address or telephone number), you also agree that we may also, where appropriate, contact you via this communication channel to answer your request. You may of course revoke this consent for the future at any time.
We delete the data that arises in this context after saving is no longer required, or limit processing if there are statutory retention requirements.