Privacy Policy

Privacy Policy 
Effective Date: September 11, 2025

OUR COMMITMENT 
ReflexMedia.com (the “Website”), which is owned and operated by Reflex Media, Inc. (“Reflex”), respects your privacy. 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 Website or interact with us. 

APPLICABILITY OF PRIVACY POLICY 
This privacy policy applies to all information we collect through our Website from current and former users and visitors. When you are no longer a user, we continue to share your information as described in this policy. This policy only applies to the Website and does not apply to the practices of any other Reflex website or service. This policy also covers our treatment of any personally identifiable information that our business partners share with us. 

INFORMATION COLLECTED 
When you use the Website, you may be asked for certain personal information, including your name, email address, phone numbers, and work and education history. Our Website also automatically receives and records information on our server logs from your browser, including your IP address, browser type and cookie information (as defined below). We may also obtain information about you from third parties such as identity verification, fraud prevention, and similar services. Reflex collects data to operate effectively. If you do not agree to our collection of the information, you may be limited or restricted in what you can do on the Website. 

HOW REFLEX USES PERSONAL DATA
Reflex uses this information to:

  • Provide, maintain, and improve the Website;
  • Personalize the content you see;
  • Help protect the safety of the Website and its users, which includes enforcing the Reflex Media Terms of Use and Privacy Policy;
  • Inform you of updates to our services, security alerts, and other support and administrative messages;
  • Communicate with you about employment opportunities and job application status; and
  • Monitor and analyze trends, usage, and activities in connection with the Website.

WEBSITE VISITORS
We gather information about all users collectively, such as what areas users visit most frequently and what features 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. 

COOKIES 
When you utilize the Website, we—along with certain business partners and vendors—may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies as outlined in the “How Your Information Is Used Section.”   Certain aspects and features of the Cookies are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Website may be limited or not possible.

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.

SHARING INFORMATION 
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 Reflex.
  • 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 Reflex, 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.

DOMESTIC DATA

Reflex Media is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, You consent to the processing, transfer, and storage of information in and to the U.S.

California

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.

Please note: If You have used our services in the preceding twelve (12) months, then we have collected Personal Data from You, the devices You use, our partners, and from sources otherwise described in this Privacy Policy. 

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.
  • You have the right to correct your Personal Data.
  • You have the right to limit the use and disclosure of sensitive personal information (as defined in the California Rights Act of 2020).

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.

Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah & Virginia

Under Colorado’s Consumer Privacy Act (the “CPA”), Connecticut’s Data Privacy Act (the “CTDPA”),  Delaware’s Personal Data Privacy Act (the “DPDPA”), Iowa’s Consumer Data Protection Act (the “ICDPA”), Montana’s Consumer Data Privacy Act (the “MTCDPA”), Nebraska’s Data Privacy Act (the “NDPA”), New Hampshire’s Privacy Act (the “NHPA”), New Jersey’s Data Privacy Law (the “NJDPL”), Oregon’s Consumer Privacy Act (the “OCPA”), Texas’ Data Privacy and Security Act (the “TXDPSA”), Utah’s Consumer Privacy Act (the “UCPA”), and Virginia’s Consumer Data Protection Act (the “VCDPA”), residents of these states have certain rights around collection, use, and sharing of their Personal Data. These rights are as follows:

  • You have the right to confirm processing and 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 Colorado or Connecticut law.
  • You have the right to request deletion of your Personal Data.
  • You have the right to correct your Personal Data.

Reflex does not sell the Personal Data of our users and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law. Similarly, Reflex does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Reflex may engage in “targeted advertising” as that term is defined in the CPA, CTDPA, MTCDPA, OCPA, TXDPSA, and the VCDPA.  You have the right to opt-out of targeted advertising here.

Any requests are subject to identity verification.

Nevada

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them.  Reflex does not sell the Personal Data of our users and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.

INTERNATIONAL DATA
Reflex Media 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 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 Reflex Media’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.

Any requests are subject to identity verification.

United Kingdom
In connection with Reflex Media’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.

Any requests are subject to identity verification.

Brazil
In connection with Reflex Media’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.

Any requests are subject to identity verification.

New Zealand
In connection with Reflex Media’s processing of personal data, we adhere to the New Zealand Privacy Act. Please note that while Reflex Media strives to ensure the privacy of your personal data, by using the Services your personal data may not be given the same protection as provided by the New Zealand Privacy Act.

Any requests are subject to identity verification.

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. 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 use of the Website. If Reflex learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Website, you agree that Reflex may communicate with you electronically. Reflex may post a notice on the Website 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.

DATA RETENTION POLICY
All user data is retained as long as a user’s account is active or unless a user requests deletion, subject to permissible retention exceptions permitted by applicable privacy laws. Once a user’s account has been inactive for 365 days, all user data is deleted, subject to permissible retention exceptions permitted by applicable privacy laws, pursuant to our Data Retention Policy.

UPDATING ACCOUNT INFORMATION
Reflex allows you to change and update your personal information at any time. To do so, simply log on to My Account with your username and password, and you will be able to update the information you have submitted.

CHOICES
If you no longer want to receive electronic communications from Reflex, simply change your preferences on your account settings or communicate your preferences to us via email. As a Data Subject in the E.U., EEA, Switzerland or the U.K., 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 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 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.

If you deactivate your account or request that Reflex delete your Personal Data, Reflex may still retain certain information associated with your account for analytical purposes and record-keeping integrity, as well as to prevent fraud, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our Website, or take other actions otherwise permitted by the GDPR and other U.S. and international privacy laws. In addition, if certain information has already been provided to third parties as described in our Privacy Policy, retention of that information will be subject to those third parties’ policies.

CHANGES TO OUR PRIVACY POLICY
We may update this Privacy Policy from time to time. We will place any updates to this policy on our Website. You may also request a paper copy of the Privacy Policy by contacting us at the email or address noted below. You are bound by any changes to the Privacy Policy if you use the Website after such changes have been posted to the Website.

DATA PROTECTION OFFICER
To communicate with our Data Protection Officer, please email [email protected].

CONTACT US
If you have any questions, You can contact Reflex via the following email [email protected] or at the following addresses Reflex Media, 3250 Pepper Ln, Las Vegas, NV 89120.

You can also contact our Data Protection Officer at the e-mail noted above, or our Data Protection Representative located in the EU, EEA, or Switzerland at www.datarep.com/reflex, or our Data Protection Representative located in the U.K. at www.datarep.uk/reflex, of write to:

DataRep, 72 rue de Lessard, Rouen, 76100, France

DataRep, Leutschenbachstrasse 95, Zurich, 8050, Switzerland

DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

APPENDIX I
Types of Reflex Vendor Third Parties:

  • Web server hosting
  • Data analysis
  • Security services

To receive a copy of the complete list of third parties, please contact: [email protected] and use the subject line “Third Party Request.”  The list is proprietary and confidential and may not be used for any other purpose or distributed in any form; violation of this requirement is a violation of the Terms of Use governing the Website.