Privacy Notice

Official Release

Reelay Meetings, Inc. and its affiliates (the “Company”, “we”, “our”, or “us”) respects your privacy and are committed to protecting it through this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the type of information we may collect from you or that you may provide to us when you visit www.reelay.com, our mobile application, and the affiliated subdomains (the “Site”), use our Service (as defined in the Terms of Service) that we provide to you or which are available through our Site and our policies and practices regarding how we collect, use, and disclose that information. If you engage in Service offered by us, then you may be subject to other terms and conditions and disclosures relevant to the Service that are not included in this Privacy Notice.

BY ACCESSING OR BROWSING THE SITE OR USING THE SERVICES, YOU CONSENT TO THE COLLECTION AND USE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE, AS MODIFIED FROM TIME TO TIME BY US.
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This Privacy Notice applies to information we collect:
• From participating meeting hosts (“Hosts”).
• From meeting viewers (“Viewers”). 
• From Viewers’ colleagues and clients (“Teammates”). 
• From visitors to the Site (collectively, with Hosts, Viewers, and Teammates “you”).
• In email, text, and other electronic messages between us.
• When you engage with us to use our Service or request information about our Service.

We reserve the right, at any time and without notice to you, to add to, change, update, or modify this Privacy Notice. If we decide to change our Privacy Notice, we will post a new notice on our Site and change the date at the top of the Privacy Notice. Any change, update or modification will be effective immediately upon posting on our Site and will apply to any Personal Information (as defined below) provided to us on and after that date. Your continued use of the Site or Service after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.

If we make a material change to our Privacy Notice that affects how we collect or use your Personal Information, we will notify you via email, SMS text message, or other notification. If you have any questions about this Privacy Notice or our use of your information, you can email us at support@reelay.com.

THE TYPES OF INFORMATION WE COLLECT.
Personal Information
We collect “Personal Information,” which is information that can be used to identify you individually. For example, we collect an Internet Protocol (“IP”) Address from all visitors to our site, and, if the visitors choose to engage with us by submitting a form or requesting further information, we may also collect their names and e-mail addresses.  

Your provision of Personal Information in connection with the use of the Services is voluntary. You determine the extent to which you provide Personal Information. 

We collect the following Personal Information from Hosts: full name, mailing address, email address, complete date of birth, email address, phone number, IP Address, and other information that permits us to contact you at a physical location, online, or by electronic communication, including telephone number, email, or text messages. We also collect payment and billing information, such as credit or debit card information, checking or ACH information, or other similar financial or banking information related to any transactions you enter into with us. 

We collect the following Personal Information from Viewers and Teammates: full name, email address, IP Address, and other information that permits us to contact you at a physical location, online, or by electronic communication, including telephone number, email, or text messages.

Registration and Transactional Data
If you are using our Site or Services, you are required to submit an email address, password, and additional Personal Information. We may collect and store access information related to your account.

When you have an account with us, the combination of your username and your password is the key to your account with our Services. We recommend that you use a unique combination of letters, numbers, and special characters to create your password. You are responsible for all actions taken in the name of your account. You should not disclose your password to anyone. You may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us at support@reelay.com and, if available, login to your account at the Site and change your password.

We may also track and retain the details of all transactions and communications between Customers, target audiences, and other visitors on our Site and Services such as emails, feedback, ratings, sale and purchase of Services, and any other forms of communications. We may use and display your name when you send an email or other communication through our Site or Services.

Payment Information
‍If you use our Services, we collect information related to your transaction. This information includes your payment method (credit card or debit card number, account, and authentication information), billing information, and shipping and delivery details. This information is processed through a third-party payment processor.  You should look to the third-party payment processors’ terms regarding payments and contact them directly if you have any inquiries.

Your payment for purchased Services may be charged directly by us through a third party payment processor. Please review the following link to review the terms: TERMS OF SERVICE. To the extent the Services or any portion thereof is made available for any fee or through a subscription, your access will be granted following payment of the applicable fees to Company. Your account and access to the Services may be suspended in the event of non-payment of applicable fees.

You agree to provide accurate and complete billing information, including valid credit card information, your name, mailing address, and email address.

Contact Us Information and Feedback
‍We may collect information that identifies you personally when you submit comments, questions, or suggestions to us or to the Services using the Contact US form or by email, including attached files in an email sent to us. Any comments and any emails we receive from you are subject to the terms of this Privacy Notice.

‍Computer and Device Information
We use the following data collection platforms to obtain information from or about the computers and devices that you use to access the Services, as determined and allowed by the personal settings you have for those computers and devices: MixPanel and Kissmetrics.
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We collect information from or about the computers and devices that you use to access the Services, as determined and allowed by the personal settings you have for the computer and device. We collect the Internet Protocol (IP) address, domain name, browser type, operating system, device settings, location, web log files, and other code tracking devices from any device you use to access our Services and any pages at our Site. You can turn-off and adjust settings on your computers and devices that will not allow us to collect information. For example, in many cellular devices, you can turn off location settings by selecting the “Settings” feature, choosing “Privacy” and turning-off “Location.” To learn more, see below at Manage Your Settings.

How We Use and Share Information.
Provide our Services
We use Personal Information to provide you with the features available through the Site and Services, to respond to your requests, to process orders and facilitate any transactions that you may initiate through the Site or Services, and to communicate with you.

Your payment for purchased goods may be charged directly by us through our payment processor, through your mobile application provider, or through another third party payment processor.  You can look to the terms of the third party provider’s regarding payments and contact them directly if you have any inquiries.

‍Contact By Mobile Phone
By providing us with your mobile phone number, you hereby expressly consent to receive automated text messages (including SMS and MMS) from us at the mobile phone number you provided. You represent that you are 18 years of age or older and you have the consent of the wireless account holder associated with the mobile phone number you provided. 

You are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message and data rates may apply.

Text messages may be sent using an automatic telephone dialing system or other technology. Your consent to receive automated text messages is not required as a condition of purchasing any goods or services. If you have opted in, we may provide updates via text messages through your wireless provider to the mobile number you provided. Message frequency varies.

‍Internal Analysis and Promotions
We may use Personal Information, non-personal, and aggregate information to evaluate and improve our services, and for our own internal statistical, design, or operational purposes, or, for example, to estimate our audience size, measure aggregate traffic patterns, and understand demographic and other trends among our Users. 

‍Marketing Purposes
If you provide us with feedback, we will collect that information and we may use it in our marketing materials, use it on our Site or Services, or disclose it for any purpose we choose. Your Personal Information will not be disclosed or associated with any feedback that we use or disclose unless you have given us permission to use your Personal Information for this purpose. 

We may outsource all of the tasks described in this Privacy Notice to third parties on a confidential basis. If you do not want us to use your Personal Information for marketing or promotion purposes or you do not want to receive promotional materials from us or third parties to whom we outsource certain tasks, see below at How You Can Manage Your Information.

‍Legal Requirement
We may disclose Personal Information, non-personal information, and aggregate information: 
(a) to comply with the law, cooperate and respond to requests and claims or comply with legal process served on us (e.g., a lawful subpoena, warrant, or court order);
(b) to enforce or apply our Terms of Service, policies, or agreements (including to initiate, render, bill, and collect for amounts owed to us);
(c) to protect and defend us or our user's rights or property, the Site, Services, our employees, visitors, or the public, (including protecting and defending from fraudulent, abusive, or unlawful use of, the Site or Services); or
(d) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.

‍Company Sale
Information collected through our Site or Services is considered our trade secret or proprietary information. As the owner of such information, we may disclose or sell such information as an asset of the company in conjunction with the sale to a third party of our company or a portion of our assets.

‍How You Can Manage Your Information
‍You may choose not to provide us with any Personal Information. In that case, you can still visit and browse our Site; however, you will not have access to or be able to use our Services.

‍Account Settings
‍Individuals who set up an account with us may elect to receive or stop receiving information from us or any third party as described by this Privacy Notice. If you receive email communications from our Services, you may use the unsubscribe link contained in the email. Please contact us at support@reelay.com if you need assistance.

‍Request Changes
‍You may also review and request changes to your Personal Information and obtain removal of content or information you have publicly posted at our Site by sending an email with a detailed description of the specific content or information to support@reelay.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested. 
Please be aware that we cannot always delete records of past interactions and transactions. For example, we are required to retain records relating to previous sales and purchases for financial reporting and compliance reasons.

‍Manage Your Security Settings
‍You may manage how your browser handles cookies and related technologies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. You can opt-out of being targeted by certain third-party advertising companies online at http://www.networkadvertising.org/choices/.

You may manage how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. The NAI’s main webpage is located at www.networkadvertising.org.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through the Services. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt-out on the DAA or NAI websites, your opt-out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Links to Other Websites 
‍Please be aware that we may provide links to third-party websites as a service to our visitors, and that we are not responsible for the content or information collection practices of those pages. Please note that these websites' privacy policies may differ from our Privacy Notice. We encourage you to review and understand the privacy practices at third-party websites before providing them with information.

Opt Out
‍You may opt out of receiving emails or text messages from us at any time either by texting the word “STOP” to any text message using the mobile device that is receiving the messages, by using the unsubscribe link contained in the email, or by contacting the sender. If you are unable to resolve this through these means, contact us at support@reelay.com. Despite your election to opt-out, we may send you emails or contact you by other means regarding your account, transactions, and your activities with the Services.

Changes to the Service
‍We may change any short code or telephone number we use to operate the texting services at any time and will notify you of these changes. You acknowledge that any messages, including any STOP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honoring requests made in such messages. Please contact us at support@reelay.com if you need assistance.

What Else Should You Know About Our Privacy Practices
AI
We utilize artificial intelligence (“AI”), including (i) Recall.AI powered by Hyperdoc Inc., (ii) AssemblyAI, and (iii) ChatGPT, which is powered through Open AI, to provide our Services. You should look to their terms regarding privacy, available at https://www.recall.ai/privacy, https://www.assemblyai.com/legal/terms-of-service, https://openai.com/policies/. The AI we utilize performs the various services, including but not limited to:(a) Services: Streamlining virtual meetings by providing post-meeting transcripts and action items(b) Analytics and Insights: We use AI to analyze aggregated and anonymized data to gain insights, improve our Services, and understand consumer behavior.

Audio and Video Recordings
‍For quality control purposes, we monitor and record all audio and video meetings associated with the use of the Services, to enable us to provide you with more efficient and better Services, or to allow us to resolve any disputes or concerns that you may have. By engaging in the Services, you explicitly consent to our monitoring and recording of your audio and video calls and meetings.  If you do not wish for your meetings to be monitored or recorded, do not us our Services. 

Audits
‍We reserve the right to conduct audits, including review of audio or video recordings processed by AI and review of transcriptions through MUX, Inc., to ensure accuracy and adherence to our standards. All auditing processes are completed for the purposes of quality assurance, improvement of services, and training. Audits are conducted with strict confidentiality and compliance with applicable privacy laws. You should look to their terms regarding privacy, available at https://www.mux.com/terms.

Security
‍We follow generally accepted industry standards to protect Personal Information, including your email address, submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Children
‍We will not collect information from children under age 18. Our Services are for general audiences and are not designed nor intended to collect Personal Information from children under the age of 18. We require that registrants affirm that they are 18 years or older, prior to creating an account on the Site or using our Services. If we learn that a person under the age of 18 has submitted personally identifiable information to us, we will delete that information from our Services. If you believe that we might have information from or about a person under the age of 18, please contact us immediately at support@reelay.com.

California Privacy Rights; California Consumer Privacy Act (“CCPA”) as Amended by the California Privacy Rights Act (“CPRA”); other California Consumer Rights
‍California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not provide your Personal Information to any third parties for direct marketing purposes as defined in California Civil Code Section § 1798.83. Please contact us privacy@reelay.com for any questions regarding your Personal Information.

A. Categories of Personal Information Collected
‍Under the CCPA, as amended by the CPRA, you have the right to know what personal information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom the business discloses personal information, and the specific pieces of Personal Information we have collected about you.

As set forth above, we collect the following categories of information: identifiers (such as your name, credit/debit card or bank account numbers, password, and email address), other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected Personal Information.  This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information or when you enter into a contract with us) or automatically as you navigate through the Site.  We use this information for one or more legitimate business purposes, including to provide our Services, improve our Services, and offer information about our Services to you, and allow you as the Client/User to purchase/use our Services. The specific pieces of information we have collected about you vary, depending on whether you are browsing the Site, a Client, or a User, but we have defined these different types of Personal Information in Section 1.A of this Privacy Notice. We also disclose certain Personal Information to third parties who are providing services to you.

We do not sell or share Personal Information as defined by the CCPA, and have neither sold nor shared any of your Personal Information with third parties in the past twelve (12) months.

B. Rights of California Residents
‍If you are a resident of California, you have other rights under the CCPA/CPRA:

• Right of Access: You can access your collected personal information by contacting us at privacy@reelay.com. 
• Right to correct, update, or delete: You can request to correct, update or delete your personal information by contacting us at privacy@reelay.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.
• Right to Request Disclosure of Information Collected: Please contact us at privacy@reelay.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
• Right to Disclosure of Information Sold or Shared and Right to Opt-Out of the Sale or Sharing of your Personal Information: You have the right to know what information of yours we have sold, and you have the right to opt-out of any sale of your information. We do not sell or share any of your information.  If you have any questions about these rights, please contact us at privacy@reelay.com. 
• Rights to Disclosure of Sensitive Information: You have a right to know how we collect, process, and disclose “Sensitive Personal Information” (SPI). SPI includes highly sensitive data such as: social security number; driver’s license; passport number; financial account information and log-in credentials; precise geolocation data; genetic data; and ethnic origin. We collect and process the following types of SPI: financial account information, log-in credentials, and precise geolocation data. We use the SPI to provide the Services to Users and to be able to process payment from Clients. Please note that Company does not directly collect payment information and is not a money-services business. If this functionality is made available in the Services, it is provided by an unaffiliated third party, and like any other third-party service, subject to their terms of use. Notwithstanding the foregoing, Company may send you invoices according to an applicable MSA. If you have any questions about the disclosure of SPI, please contact us at privacy@reelay.com.
• Right to Retention Details: You have a right to know the length of time we retain each category of Personal Information or if that is not feasible, the criteria we will use to determine that retention period. If you have any questions about this right or our data retention protocol, please contact us at privacy@reelay.com. Company stores and retains data including Personal Information for so long as may be required under the terms of an applicable agreement, or for so long as may be required to comply with a legal obligation, resolve disputes, maintain security, prevent fraud and abuse, enforce our terms of service, or fulfill your request to “unsubscribe” from further messages from us.  Questions regarding data storage, recovery, and deletion should be directed to: privacy@reelay.com
• Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA.

When you contact us regarding any of your rights under the CCPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at privacy@reelay.com.

VI. COLORADO PRIVACY ACT (“CPA”), CONNECTICUT DATA PRIVACY ACT (“CTDPA”), NEVADA PRIVACY OF INFORMATION COLLECTED ON THE INTERNET FROM CONSUMERS ACT (“NPICICA”), UTAH CONSUMER PRIVACY ACT (“UCPA”), VIRGINIA CONSUMER DATA PROTECTION ACT (“VCDPA”)v

A. Categories of Personal Information Collected
As set forth above, we collect the following categories of information: identifiers (such as your name and email address), personal information (such as your name and contact information), internet or other similar network activity, and inferences drawn from the collected personal information.  This information is collected directly from you when you provide it to us (for example when you submit information for us to create a profile for you) or automatically as you navigate through the Site.  We use this information for one or more legitimate business purposes, including to improve our Services and offer information about our Services to you.

B. Rights of Colorado, Connecticut, Nevada, Utah, and Virginia Residents
‍If you are a resident of Colorado, Connecticut, Nevada, Utah, or Virginia, you have other rights under your respective states’ consumer privacy statutes:
• Right of Access: You can access your collected personal information by contacting us at privacy@reelay.com. 
• Right to correct, update, or delete: You can request that we correct, update or delete your personal information by contacting us at privacy@reelay.com. We can’t make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.
• Right to Request Disclosure of Information Collected: Please contact us at privacy@reelay.com to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
• Right to Disclosure of Information Sold or Shared and Right to Opt-Out of the Sale or Sharing of your Personal Information: You have the right to know what information of yours we have sold, the categories of Personal Information shared, and you have the right to opt-out of any sale or sharing of your information. We do not sell or share any of your information.  If you have any questions about these rights, please contact us at privacy@reelay.com.
• Right to Disclosure of Targeted Advertising and Right to Opt-Out (Colorado, Connecticut, Utah, & Virginia): If you are a resident of Colorado, Connecticut, Utah, or Virginia, you have the right to know what information of yours we have processed for targeted advertising. We do not engage in targeted advertising. If you have any questions about these rights, please contact us at privacy@reelay.com. 
• Right to Disclosure of Profiling (Colorado, Connecticut, Utah, & Virginia): If you are a resident of Colorado, Connecticut, Utah, or Virginia, you have the right to know what information of yours we have processed for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. If you have any questions about these rights or wish to opt-out of any processing of your personal information as it relates to profiling, please contact us at privacy@reelay.com.
• Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CPA, CTDPA, NPICICA, UPA, or VCDPA.

VII. EXERCISING YOUR RIGHTS UNDER THE CCPA, CPRA, CPA, CTDPA, NPICICA, UPA, OR VCDPA

A. SUBMITTING a Request 
‍To exercise the rights described in this Privacy Notice, please submit a verifiable consumer request to us via email: privacy@reelay.com.

Only you, or someone legally authorized to act on your behalf (if in California, the person legally authorized to act on your behalf must be registered with the California Secretary of State), may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows Company to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include the user’s:
• First name
• Last name
• Email address
• Please describe your request with sufficient detail that allows Company to properly understand, evaluate, and respond to your request.

B. Verifying Requests
Company cannot respond to your request or provide you with Personal Information if Company cannot verify your identity or authority to make the request and confirm the Personal Information that relates to you. If Company cannot initially verify your identity or authority, Company will follow internal procedures to verify your identity and authority. Company attempts to respond to a verifiable consumer request within forty-five (45) days of its receipt. If Company requires more time (up to 45 days), Company will inform you of the reason and extension period in writing.

If you have an account with Company, Company will deliver Company’s written response to that account. If you do not have an account with Company, Company will deliver Company’s written response by mail or electronically, at your option.

Any disclosures Company provides will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response Company provides will also explain the reasons Company cannot comply with a request, if applicable. For data portability requests, and to the extent that Company is able, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the Personal Information from one entity to another entity. If we are not able to do so, we will let you know.

Company does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Company determines that the request warrants a fee, Company will tell you why Company made that decision and provide you with a cost estimate before completing your request.

If you have any questions or comments about your rights under the CCPA, CPRA, CPA, NPICICA, VCDPA, and CTDPA please contact us at privacy@reelay.com.

Contact Us. “Company” means Reelay Meetings, Inc. To learn more about our privacy practices or this Privacy Notice, you may contact us at support@reelay.com.