Effective Date: October 1, 2021
WhatsYourPrice.com (“WYP”), which is operated by Reflex Media, Inc. (“Reflex”) and W8 Tech Cyprus (“W8 Cyprus”), respects your privacy. W8 Cyprus operates the Website in the European Union, the European Economic Area and the United Kingdom. Reflex operates the Website in all other applicable areas. 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 “WYP Services”).
REFLEX MEDIA and W8 CYPRUS AFFILIATES
Reflex and W8 Cyprus are affiliated with various entities. These entities are as follows:
- Clover8 Investments Pte Ltd.
- W8 Tech Limited (Hong Kong)
- W8 Tech Limited, Inc. (USA)
When you use the WYP 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 WYP 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 WYP’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 and/or W8 Cyprus, collect 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 WYP Services available to you.
HOW REFLEX and W8 CYPRUS, USE PERSONAL DATA:
WYP uses this information to:
- Provide, maintain, and improve the WYP Services;
- Personalize the content you see;
- Provide Customer Service;
- 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 WYP Services.
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 anonymized information with our partners 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.
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.
When you use the WYP Services, certain information may be shared with other users and the public. For example:
- When you submit a post or comment to the WYP Services, visitors to and users of the WYP 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 WYP 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 WYP 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 WYP.
- If you participate in promotions, special offers, or other events or activities in connection with the WYP 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 is 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 WYP, 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.
The WYP Services may offer social sharing features or other integrated tools that let you share content or action you take using the WYP 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.
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 InovioPay and RocketGate. All information sent to InovioPay and RocketGate 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 InovioPay’s privacy statement, please click HERE. For RocketGate’s 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.
Pursuant to the California Consumer Privacy Act (the “CCPA”), we are required to disclose the categories of Personal Data we collect from You and how we use it, as well as the third parties with whom we share it, which we have explained above and in Appendix I.
The CCPA provides California consumers, defined as “natural persons who are California residents,” with certain rights under the CCPA. These rights are as follows:
- You have the right to know and request information regarding the categories of Personal Data:
- We collect, use, or share;
- The purposes for which these categories are collected or used by us;
- The sources from which we collect Personal Data; and
- The specific Personal Data we have collected about you.
- You have the right to equal service. Reflex and will not discriminate against You for exercising your privacy rights under California law.
- You have to right to request deletion of your Personal Data.
To request access to or deletion of your Personal Data, please contact Reflex at the following email: [email protected] or via our toll-free telephone number: 1-888-928-3887. Any requests are subject to identity verification.
Reflex does not sell the Personal Data of our users.
WYP 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 WYP 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.
European Union; European Economic Area; Switzerland
In connection with WYP’s processing of personal data received from the European Union and Switzerland, we adhere to the E.U.General Data Protection Regulation (the “GDPR”) and the Swiss Federal Act on Data Protection (the “SFADP”) and comply with their frameworks and principles. Please direct any inquiries or complaints regarding our compliance with GDPR or SFADP 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 the International Centre For Dispute Resolution-American Arbitration Association (ICDR-AAA) based in the United States. Under certain conditions, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the E.U. and Switzerland. 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 GDPR or SFADP, unless we can prove that we are not responsible for the event giving rise to the damage.
In connection with WYP’s processing of personal data received from the United Kingdom (the “U.K.”), we adhere to the U.K. GDPR/2018 Data Protection Act (the “U.K. GDPR”) and comply with its frameworks and principles. Please direct any inquiries or complaints regarding our compliance with U.K. GDPR 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 the International Centre For Dispute Resolution-American Arbitration Association (ICDR-AAA) based in the United States. Under certain conditions, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.K. If we share U.K. 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 U.K. data in violation of the U.K. GDPR, unless we can prove that we are not responsible for the event giving rise to the damage.
In connection with WYP’s processing of personal data received from Brazil, we adhere to the Brazilian General Data Protection Law (Lei Geral de Protecao de Dados Pessoais) (the “LGDP”) and comply with its frameworks and principles. Please direct any inquiries or complaints regarding our compliance with LGPD to the email listed in the “Data Protection Officer” section below.
In connection with WYP’s processing of personal data, we adhere to the New Zealand Privacy Act. Please note that while WYP strives to ensure the privacy of your personal data, by using the WYP Services your personal data may not be given the same protection as provided by the New Zealand Privacy Act.
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 WYP Services. If WYP learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the WYP Services, you agree that WYP may communicate with you electronically. WYP 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
WYP allows you to change your personal information at any time. To do so, simply log on to WYP with your username and password, and you will be able to update the information you have submitted.
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 WYP 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 and/or W8 Cyprus 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.
DATA PROTECTION OFFICER
To communicate with our Data Protection Officer, please email [email protected].
Depending on where you live, Reflex and/or W8 Cyprus are responsible for your information. If you have any questions, You can contact Reflex or W8 Cyprus via the following email [email protected] or at the following addresses Reflex Media, 3250 Pepper Ln, Las Vegas, NV 89120; W8 Tech Ltd. Cyprus, Paster 6, Flat/Office 101, 1055 Nicosia, Cyprus.
You can also contact our Data Protection Officer at the e-mail noted above, or our Data Protection Representative located in the EEA at www.datarep.com/reflex or, or our Data Protection Representative located in the U.K. at www.datarep.uk/reflex.
Types of Reflex/W8 Cyprus Vendor Third Parties
- Web server hosting
- Data analysis
- Marketing services
- Security services
- Card and payment processors