1. Introduction:
a. This privacy policy sets out the data processing practices carried out through the use of the internet and any other electronic communications networks by REACT GLOBAL OÜ, a company headquartered in Estonia (hereinafter "the Company", "we", "us", or "our").
b. This privacy policy applies to all personal data processed by the Company, regardless of the means of collection, including the use of our (REACTIVE COMMERCE) e-commerce and social media application (hereinafter "the Service").
c. The Company is committed to protecting all individual’s privacy rights and complying with all applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
2. Types of personal data we collect:
a. We may collect the following types of personal data from you when you use the Service:
i. Contact information, such as your name, email address, and telephone number
ii. Demographic information, such as your age, gender, location, and language preference
iii. Payment information, such as your credit card information or bank account details
iv. Profile information, such as your username and profile picture
v. User content, such as comments, reviews, and posts on the Service
vi. Technical information, such as your IP address, browser type, and device information
vii. Usage information, such as how you interact with the Service, including the pages you visit and the actions you take
b. We may also collect personal data from other sources, such as social media platforms when you connect your account to the Service.
3. Purpose of processing personal data:
a. The personal data we collect is used to:
i. Provide and improve the Service; including experience personalization, and communicating with you,
ii. Process your orders and manage your account; including fulfilling your requests and handling returns and cancellations,
iii. Enhance the security and integrity of the Service; including fraud and abuse prevention,
iv. Comply with legal obligations; including responding to subpoenas and complying with the regulatory requirements,
b. We may also use your personal data for marketing and promotional purposes, such as sending you promotional offers and updates on the Service.
4. Legal basis for processing personal data:
a. The legal basis for processing your personal data will vary depending on the specific processing activity and the type of personal data involved.
b. In general, we will process your personal data based on one or multiple legal grounds of the following:
i. Your consent: where you have provided your express consent for us to process your personal data for a specific purpose
ii. Performance of a contract: where the processing is necessary for us to perform our obligations under a contract with you, such as to fulfill your order and providing the Service
iii. Legal obligation is where the process is vital to comply with a legal obligation, such as responding to a subpoena or investigating fraudulent or suspicious activities.
iv. Legitimate interests, such as enhancing the Service security and integrity, and protecting the users' data, provided that these interests are not overridden by your rights and interests.
c. Other legal requirements: Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (such as a court or a governmental agency). The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
i. Comply with a legal obligation
ii. Protect and defend the rights or property of the Company
iii. Prevent or investigate possible fraudulent and/or suspicious activities in connection with your account using the Service
iv. Protect the personal safety of Users of the Service or the public
v. Protect against legal liability
5. Data retention and deletion:
a. We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable laws.
b. Upon your request, or if you delete your account, we will delete your personal data, within 15 days, unless we are required by law to retain it; provided that suspicious or fraudulent activities are connected to your account which require to be investigated. (For example, if we are required to retain your data to comply with applicable laws, resolve disputes, and enforce our legal agreements and policies.)
c. We may also retain your personal data in an anonymized form, such as for statistical analysis or to improve the Service.
d. The Company 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 Our Service, or we are legally obligated to retain this data for longer time periods.
6. Data sharing and transfers:
a. We may share your personal data with our affiliates, service providers, and business partners, as necessary to provide the Service and to comply with legal obligations.
b. We may also share your personal data in connection with a merger, acquisition, or sale of all or a portion of our assets.
c. We may transfer your personal data to countries outside of the European Union, including to countries that may not have an equivalent level of data protection as the European Union.
d. In such cases, we will take appropriate measures to ensure that your personal data is protected, such as standard legal contractual clauses with the parties receiving your personal data.
7. Data security:
a. We take reasonable and appropriate measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
b. The security of Your Personal Data is important to us, however, remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable and suitable means to protect your Personal Data, we cannot guarantee its absolute security.
8. Children’s Privacy:
a. Our Service does not address anyone under the age of 13.
b. We do not knowingly collect personally identifiable information from anyone under the age of 13.
c. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us.
d. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from Our servers.
e. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.
9. Links to Other Websites
Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
10. Your rights:
a. You have the right to access, correct, delete, or request the restriction of processing of your personal data.
b. You also have the right to object to the processing of your personal data for certain purposes, such as for marketing purposes.
c. You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to have your personal data transmitted to another controller.
d. You also have the right to file a complaint with a data protection authority, such as the Estonian Data Protection Inspectorate.
11. Contact information:
If you have any questions about this Privacy Policy, you can contact us through e-mail:
a. Department of Data Protection - Data Protection Officer: dpo@reactapp.me.
b. info@reactapp.me
12. Changes to this privacy policy:
a. We advise reviewing this policy, periodically, to stay updated.
b. You will be notified of major policy changes and updates, via email and/or a prominent notice on our Service, whenever it happens.
c. Changes to this Privacy Policy are effective when they are posted on this page.
d. You will see the "Last updated" date updated at the top of this Privacy Policy.
Date of Last Revision: February 25, 2023