Last updated March 12, 2020
This privacy notice (“Privacy Notice”) is a binding agreement between you and Reel2Media, LLC and its affiliates, corporate parent(s), and subsidiaries (collectively, “Reel2Media,” “us,” “our,” or “we”) and is part of our Terms and Conditions. This Privacy Notice explains the categories of information that we collect and how we use that information. Any terms defined in the Terms and Conditions have the same meaning when used in this Privacy Notice. We encourage you to read this Privacy Notice carefully to understand how we collect and use your information.
Scope. This Privacy Notice applies to information we collect when you visit www.reel2media.com and other websites we own or operate (collectively, the “Site”), and when you download or use our Amazon Alexa Skills, including but not limited to YakTalk Back!, MisaYoga, Beat the Bonus, or our other Amazon Alexa Skills on Amazon’s Alexa service on any Alexa-enabled device (“Alexa Device”), as well as mobile applications and other software, products, services, and devices we develop, publish, or otherwise offer (each, a “Skill”; collectively, our “Skills”) through third parties and by other means over the course of your use of our Site or Skills.
This Privacy Notice also contains information about privacy rights specific to California residents and residents of the European Economic Area.
Your use of our Skills is primarily subject to the Alexa Privacy Notice and other applicable Amazon Legal Policies. Please read these documents carefully to understand Amazon’s policies and practices.
Consent. By visiting the Site or downloading or using the Skill, you consent to this Privacy Notice and the collection and use of information as described herein. We will take steps to notify you and confirm that you agree at different stages of collecting your information. Your use of our Site or Skill is subject to this Privacy Notice and our Terms and Conditions, including its applicable limitations on damages and the provisions regarding resolution of disputes.
What Is Personal Information?
As used in this Privacy Notice, “Personal Information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or device, such as:
- Identifiers (e.g., name, address, telephone number, email address, username)
- Sensitive Personal Information (e.g., state identification number, financial information)
- Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status)
- Biometric information (e.g., keystrokes, behavioral or biological characteristics)
- Internet or other similar activity (e.g., browsing history)
- Employment-related information (e.g., current or past employment)
- Nonpublic educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
Personal Information does not include (a) publicly available information; (b) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (c) deidentified information that cannot be easily linked back to the individual.
Lawful Basis. We will only collect your Personal Information (a) with your consent, either obtained directly from you or obtained from Amazon via an Alexa Device or your Amazon account; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We will limit the collection of Personal Information to that which is reasonable and necessary. If we collect or use your Personal Information based on your consent, we will also notify you of any changes and will request your further consent as needed.
How We Collect and Use Your Personal Information. The types of Personal Information we collect about you and how we use the Personal Information we collect depends on the context of your interactions with us, the Skill, and the Site.
Personal Information we collect when you download or use the Skill:
- Alexa Account Information. We automatically collect your Alexa user ID and other account information from Amazon in accordance with Amazon’s privacy practices. We use this information to connect your Alexa account to your Skill profile to allow you to resume your session later or use the Skill on multiple devices, and to link your profile to your In-Skill Purchases. We may receive additional Personal Information about you from Amazon pursuant to Amazon’s privacy practices.
- Technical and Device Information. We automatically collect technical information about your use of the Skill, including access dates and times, the number of times you have accessed the Skill, and Skill features you have used. We also collect information about the capabilities of the devices that you use to interact with the Skill. We use this information to learn more about your interactions with the Skill, as well as to monitor the availability of all of the Skill’s functionality and security features.
Personal Information we collect when you visit the Site:
- Registration and Contact Information. We collect Personal Information (such as your name, email address, and phone number) with your consent when you fill out forms on the Site or correspond with us. We do not process or store any payment information. You may provide this information when you register to use the Skill; participate in discussion boards or other social media functions; enter a competition, promotion or survey; and report a problem with the Skill. We use this information to register you to use the Skill, to provide you with services and information you request from us, and to communicate with you about our company, the Skill, and our services. We also use this information for our direct marketing purposes. You can opt out of Reel2Media’s marketing communications at any time.
- Your Communications and Content. We collect Personal Information that you submit to us through your account with your consent, including information related to your account, communications you submit related to the Skill, or any comments or other content you post to interactive features of the Site or the Skill. We use this Personal Information to provide you with the Skill, to improve the Skill, and to provide customer support.
- Text Messages. If you provide us with your wireless phone number, you consent to Reel2Media sending you informational text messages related to your use of the Skill or the Site. You can unsubscribe from our text messages by replying STOP or UNSUBSCRIBE to any of these text messages. You may use the Skill or the Site without consenting to receive text messages. Messaging and data charges may apply to any text message you receive or send. Please contact your wireless carrier if you have questions about messaging or data charges.
- Technical and Device Information. We automatically collect technical information from your use of the Site, including your IP address, browser and device characteristics, mobile device ID, operating system, language preferences, referring URLs, and device name. We also track pages visited and emails opened by Site visitors. This information allows us to maintain security of the Site, to ensure that the Site will appear and function properly on your device, and to conduct our own analyses and research to improve the Site and our services.
- Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. We use this information to tailor our services to you based on your location, and to conduct our own internal analyses. If you wish to change our access or permissions, you may do so in your device’s settings.
In addition to the above uses, Reel2Media uses Personal Information collected from you to perform data analysis, identify Site and Skill usage trends, troubleshoot, develop and display content and advertising tailored to your interests or location, and measure the effectiveness of our marketing efforts. We may use and store this information and the reports we generate using this information in an anonymized form or in the aggregate, so that it is not associated with individual end users and does not include personal information.
Sources of Personal Information We Collect. We collect the Personal Information described above from the following sources:
- Directly from you (depending on the context of your interactions with the Site or the Skill), such as when you register with us, use the Skill. or interact with us via the Site.
- Amazon, including your Alexa account ID and other information that Amazon provides to us in accordance with Amazon’s privacy practices.
- Indirectly from you, meaning the Personal Information we collect automatically from your use of the Site or the Skill.
- Third parties, including companies that host and maintain the cookies we deploy on the Site.
Automated Decision-Making. Automated decision-making, including profiling (together, “ADM”), refers to a decision that is taken solely on the basis of automated processing of your Personal Information. This means processing using, for example, software code or an algorithm that does not require human intervention. Reel2Media may use automated decision-making technology in certain features of the Skill in order to enable the Skill to respond to your interactions with the Skill. We will never use ADM to process your sensitive Personal Information or to determine whether you have access to our features or services. You may object to our use of ADM by emailing us at email@example.com. Please note that ADM technology is central to the function of certain Skill features and, as such, if you object to our use of ADM, we may not be able to provide you with those features.
Children Under Age 16. Amazon provides children and their families with privacy settings designed to protect children online and while using Skills on an Alexa Device. These settings include options for parents and guardians to provide or withhold consent for the collection and processing of their child’s Personal Information. Any use of the Skill by a child under age 16 is subject to Amazon’s privacy practices. Reel2Media does not knowingly collect personal information from children under the age of 16 via the Site or the Skill without the consent of the child’s parent or guardian. If we learn we have collected or received Personal Information from a child under 16 without parent or guardian consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
Disclosure of Personal Information. Reel2Media may disclose Personal Information for a business purpose to:
- Amazon, its affiliates or subsidiaries.
- Service providers that assist with marketing, web hosting, and other technical functions. We prohibit our Service Providers from selling or disclosing the Personal Information we provide, and we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
- Parent entities, affiliates and subsidiaries. If we do disclose your Personal Information to our affiliates or subsidiaries, their use and disclosure of your Personal Information will be subject to this Privacy Notice.
- Law enforcement and regulatory and other governmental agencies.
- Cookie information recipients, subject to their respective privacy notices.
- Other third parties (i) as part of a business transition (e.g., a merger or acquisition by another company); (ii) if we believe it is appropriate in order to investigate, prevent, or take action regarding illegal activities, potential threats to the safety of any person, violations of our Terms and Conditions or this Privacy Notice, or to exercise or defend our legal claims; or (iii) in any case where we have obtained your prior consent.
Aggregated and Deidentified Information. Reel2Media reserves the right to share aggregate, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, or research or other purposes, without restriction.
Your Rights and Choices. Reel2Media provides you the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Depending on where you reside, your options to control your Personal Information may include some or all of the following:
- Changing your preferences for what we communicate about with you and how we communicate with you.
- Correcting, updating, and deleting the Personal Information we have collected about you. Please note that certain legal obligations may limit or prevent our ability to fulfill these requests, and that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or the Skill for a period of time.
- Requesting that we delete or give you access to Personal Information we hold about you.
- Choosing whether to receive marketing communications from us, including promotions, surveys, and information about products and services that may be of interest to you.
- Asking us to not process your Personal Information for marketing purposes.
- Controlling how the cookies we use interact with your browser.
At any time, you may exercise any of these controls and choices, express concerns, lodge a complaint, or obtain additional information about the use of your Personal Information by contacting us at email@example.com. You can opt out of marketing emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving promotional emails, we may still send you emails about your use of the Skill or any other services or information you have requested or received from us.
Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests.
Privacy Notice to California Residents. Reel2Media adopted this section to comply with the California Consumer Privacy Act (the “CCPA”; Ca. Civil Code sections 1798.100–1798.199) with regard to users of our Site and Skills who are residents of the State of California (“California Consumers”). This section applies solely to California Consumers and provides California Consumers with the disclosures and notices required under the CCPA. Please note that exceptions and limitations may apply to a California Consumer’s rights and Reel2Media’s obligations under the CCPA.
Personal Information Collected. Reel2Media has collected the following categories of Personal Information from California Consumers within the last twelve (12) months:
- Internet or other similar network activity
- Commercial Information
- Geolocation data
Disclosing Personal Information. Reel2Media has not disclosed Personal Information to third parties during the preceding twelve (12) months.
No Sale of Personal Information. Reel2Media does not share, sell, rent, or transfer your Personal Information to any business that is not a Service Provider or as otherwise permitted by applicable law.
Your Rights and Choices. The CCPA provides California Consumers with specific rights regarding their Personal Information. The following paragraphs describe CCPA rights and explain how to exercise those rights. Each of these rights is subject to our receipt of a verifiable consumer request (see Submit a Consumer Privacy Request).
Right to Disclosure. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months, such as:
- Categories of Personal Information we have collected about you.
- Categories of sources for the Personal Information we have collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- Categories of third parties with whom we share that Personal Information.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Reel2Media is only required to respond to two disclosure requests within a 12-month period.
Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Reel2Media is prohibited by law from disclosing copies of certain pieces of Personal Information (e.g., government identification numbers, financial account information, and passwords or security questions and answers) because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Reel2Media is only required by law to respond to two access requests within a 12-month period.
Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. Reel2Media may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
Submit a Consumer Privacy Request. Reel2Media does not currently meet the applicability thresholds of the CCPA. California Consumers can inquire about their privacy rights or submit a request to Reel2Media by submitting a request to Reel2Media by email or online form. Reel2Media will process and respond to your request as required by applicable law.
- Using our online Consumer Privacy Request.
- By email at firstname.lastname@example.org.
Verification. We cannot respond to your request or provide you with Personal Information unless we can verify your identity and your authority to make the request and can confirm that the Personal Information relates to you. A verifiable consumer privacy request must:
- provide sufficient information that allows us to reasonably verify you are the person about whom we have collected Personal Information or you are an authorized representative.
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You do not have to register with Reel2Media to make a verifiable consumer privacy request. We will only use Personal Information provided in a verifiable consumer privacy request to verify the requestor’s identity or authority to make the request.
Authorized Agent. You may make a verifiable consumer request on behalf of your minor child. Otherwise, only you, or a person you have designated in writing as your authorized agent or who is registered with the California Secretary of State to act on your behalf or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465 (“Authorized Agent”), may make a verifiable consumer request related to your Personal Information. If you wish to have an Authorized Agent make a verifiable consumer request on your behalf, they will need to provide us with sufficient written proof that you have designated them as your Authorized Agent; we will still require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information.
Reel2Media’s Response. We endeavor to respond to a verifiable consumer request within 45 days of receipt. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response to you by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response. We do not charge a fee to process or respond to your verifiable consumer privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not do any of the following as a result of your having exercised your right under the CCPA:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California Civil Code sections 1798.83-1798.84 (the Shine the Light Act) entitles California residents to request disclosure regarding Personal Information sharing with affiliates and/or third parties for marketing purposes. If you are a California resident and you would like to request this disclosure, please contact us at hey@heyReel2Media.app with the subject line “Request for California Privacy Information.”
Privacy Notice to European Economic Area (“EEA”) Residents. Reel2Media adopted this section to comply with the General Data Protection Regulations (“GDPR”). This section applies solely to Site visitors, Skill end users, and others who are residents of the EEA (“EEA Residents”) and provides EEA Residents with the notice and disclosures required under the GDPR.
Data Controller. Data Controller means the natural or legal person who (either alone, jointly, or in common with other persons) determines the purposes for which, and the manner in which, any personal information is, or is to be, processed. For the purpose of this Privacy Notice, Reel2Media is a Data Controller of your Personal Information.
Data Processor. Data Processor, or Service Provider, means any natural or legal person who processes the data on behalf of the Data Controller. Reel2Media may use the services of various Service Providers in order to process your data more effectively.
Lawful Basis. Reel2Media processes your Personal Information (a) when applicable, with your direct consent; (b) if we have a legitimate interest in doing so, including fulfilling our obligations under a contract with you, administering our business, maintaining the quality of the Site or the Skill, providing customer service, or identifying new business opportunities; or (c) as authorized or required by law.
Additional rights: you have the following rights in relation to the Personal Information we hold about you:
- Right to Know. We must provide you with notice about the Personal Information we collect and how we will use it. We have set the required notices in this Privacy Notice. We may provide you with additional notice about other ways we process your Personal Data, such as by sending you a notice via email or by other means of communication.
- Right of Access. If you request it, we will provide you with access to your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We will notify you if we have a legally valid reason for refusing your request in whole or in part.
- Right to Rectification. We are required to correct the Personal Information we have about you if you inform us that it is incorrect. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (for example you change address), please inform us and we will update our records.
- Right to Erasure. Upon your request and when required by law, we are must delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request.
- Right to Restrict. In certain cases, we are required to restrict our processing of your Personal Information. You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.
- Right to Data Portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a format that allows the other organization to read and use it. You have the right to request that we transfer your Personal Information to another organization (i.e., another data controller) in a structured, commonly used machine-readable format, so that the other organization can read and use it.
- Right to Object. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request. You may object to the processing of your Personal Information in certain circumstances. If you make this request, we will consider certain legal, contractual and business interests and obligations against your right to object to the processing. You can also object to our use of your Personal Information for direct marketing purposes.
- Right to Not Be Subject to Automatic Decision-Making or Profiling. We are required to keep records of automated processing that we carry out, if any, and, in certain circumstances, provide you with information about the way that the decisions are made, and to respond to your objections to being subject to decisions made.
If you want to exercise any of these rights, please make a request to email@example.com.
Data Security. We have implemented precautions and safeguards to protect the Personal Information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We use encryption and asset management solutions to protect information online and when stored in our systems. All information you provide to us is stored on our secure servers. The Skill runs in a virtual private cloud that restricts access from the public Internet. We have appropriate network restrictions in place so that data related to the Skill is only accessible to the Skill infrastructure. Access to the Skill data is password restricted, and the password is rotated on an appropriate schedule. All communication between the Skill and both your devices and first-party platform services (such as Amazon Alexa and the Google Assistant) is encrypted by industry-standard transport layer security. Additionally, all requests from first-party platform services to our game services are verified for authenticity using the best available means on each platform before being serviced. We update and test our technology to improve the protection of Personal Information and to assure the integrity of that information. Please note, however, that no transmission of data over the internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.
Passwords. If you have a password for the Site or the Skill, you should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity.
Data Storage and Processing Location. Reel2Media stores your Personal Information in the United States of America. We will strive to ensure that the data in our possession is always processed in accordance with this Privacy Notice and the local laws.
For residents of the EEA: Please note that the Personal Information we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By giving us your Personal Information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
Third-Party Websites. The Site and the Skill may contain links to nonaffiliated websites. Note that this Privacy Notice applies only to information collected by Reel2Media. We may provide links to third-party websites as a service to our Site visitors, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites. Any access to and use of such linked websites is not governed by this Privacy Notice, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. We encourage you to review and understand the privacy notices of such websites before providing them with any information.
Cookie Notice. Cookies are small pieces of data that are stored on your computer or other device when websites are loaded in a browser. Cookies are used to recognize your device and to store your preferences. Some cookies store your preferences for a single visit, while others store your preferences for multiple repeat visits. Cookies may be set by the website that you are visiting or by third parties to serve content or provide advertising or analytics services on the Site.
Where We Place Cookies. We set cookies on the Site and the Skills. We may also place cookies in the emails we send to our customers or Site users to track when the email is opened.
Types of Cookies. The table below explains the types of cookies we use on our Site and why we use them.
- Google Analytics. We use various Google Analytics cookies to help us understand how users engage with the Site. These cookies to collect information and report Site usage statistics without personally identifying individual visitors.
- The Site deploys AWS security cookies to help identify and prevent potential security risks.
Please note that the specific cookies used on the Site can change from time to time as necessary to ensure that the Site functions as intended and, for third-party cookies, as determined by the third-party cookie host. Reel2Media is not responsible for how third-party cookies behave or may change from time to time. You can control how cookies, including third-party cookies, interact with your browser as described below.
Controlling Cookies. Most browsers provide for ways to control cookie behavior, either through built-in functionality or by using third-party plugins. You can opt out of accepting cookies by adjusting your browser settings to not accept cookies or to notify you when you are sent a cookie. Specifically, you can opt out of Google Analytics by installing Google’s opt-out browser add-on. On a mobile device, you can adjust your settings to limit ad tracking. However, certain features of our Site or other services may not work if you delete or disable cookies.
Websites and HTML emails may also contain tracking technologies like “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
Cookie Consent Banner. You may see a “cookie consent banner” on our Site that lists the categories of cookies we use and that provides you the option to consent to or reject that type of cookie. When you consent in this manner, Reel2Media may set cookies on the Site that correspond with the categories of cookies to which you consented. We will display the cookie consent banner to you periodically in case you change your mind.
Terms and Conditions. Our Terms and Conditions govern all matters not set forth in this Privacy Notice. We encourage you to familiarize yourself with our Terms and Conditions.
Changes to this Privacy Notice. Reel2Media reserves the right to modify this Privacy Notice at any time by updating this posting without notice and revising the effective date. All changes are effective immediately when posted and apply to all access to and use of the Site, the Skill, and any other services we offer. Your continued use of the Site or the Skill following the posting of changes constitutes your acceptance of such changes.
For More Information. Please let us know if you have any questions or comments regarding this Privacy Notice, or if you wish to exercise any of your rights over your Personal Information. If you have any questions about this Privacy Notice, you can contact us at firstname.lastname@example.org.