Privacy Notice

At With Reach UK Ltd., we and our affiliates and subsidiaries (collectively referred to as “Reach”), are committed to the responsible and respectful stewardship of the data in our custody, including your Personal Information. Depending on your location, “Reach” refers to With Reach (EU) Limited ÖU (registration #14571597, “Reach EU”), Reach Ltd. (“Reach Canada”), With Reach (Australia) Pty. Ltd. (“Reach Australia”), With Reach UK Ltd. (registration #08507554, “Reach UK”), or With Reach (USA) LLC (“Reach USA”).

To help you understand your rights and our responsibilities, we have created this Privacy Notice (“Notice”) and it applies to your use of this website, as well as any other website or application (collectively, “Sites”) that refers you to this Notice. It also applies to any of the Services we provide to our customers. It also applies to any information you provide to us via email, postal mail, or over the phone.

This Privacy Notice must be read in conjunction with our Cookie Notice and any of the supplemental notices that may apply to you if you are a resident of California, the European Union/European Economic Area, or the UK. If you are applying to join the Reach team, our Job Applicant Privacy Notice will also apply. All of these documents are incorporated into this Notice and will apply to our processing of your data as applicable, so please make sure you have read and understood them as well.

Acceptance of Privacy Notices

By accessing and using our Services, you signify that you have reviewed the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

Commitments & Responsibilities

Our Commitment and Responsibilities

If you are a visitor to our Sites, we act as a Data Controller of any of your Personal Information that you provide or that we gather automatically. When we are acting as a Data Controller, we have a responsibility to decide how personal data is processed and to protect it from misuse. We take that responsibility seriously and have built various policies and procedures to help us fulfill this commitment. This Privacy Notice provides further details about the measures we take to protect your data.

If you are a customer of one of our customers and have interacted with us in the course of transactions on another website or e-commerce application, we may be considered a Data Processor of your Personal Information. As a Data Processor, we have a responsibility to use your Personal Information only for the purposes specified by the Data Controller (the company who uses our Services) or for uses specifically permitted or required under applicable laws, and to protect it for as long as it is in our custody.

Your Responsibilities

It is your responsibility to make sure you have read and understand this Privacy Notice.

If you are a business customer of Reach, it is your responsibility to review our agreements with you because they may have other details regarding how we process your data.

If you are an individual user of a site that uses our Services, it is your responsibility to review the privacy notice for that site to understand how that company may have instructed us to process your data.

What Data We Collect & How We Collect It

When we refer to “Personal Information” or “Data” we mean any information that identifies, describes, relates to, or is reasonably capable of being associated with you as a uniquely identifiable individual person, including information that can be linked, directly or indirectly, with yourself of others in your household. Personal Information does not include information which has been irreversibly deidentified, anonymized, aggregated, or otherwise rendered incapable of being reassociated with your identifying information though reasonable means. “Personal Information” and “Data” may be used interchangeably throughout this Notice.

Data We Collect Directly from You

Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us. We will not collect any personal data from you we do not need in order to provide and oversee this service to you.

At various points during the provision of Services to you, we may request that you provide us with the following information:

• Identifiers: Customer identifying and contact information necessary for providing requested Services, such as a name, mailing or billing address, phone number or email address;

• Customer Records: Support or follow-up information, or any other Personal Information you voluntarily provide to us in order to communicate with you or answer your questions, such as through the “Contact Us” page or when you communicate with us, including any files or attachments you send us;

• Commercial Information: Contact information for business inquires, such as name, email address, mailing address, or phone number; Payment or financial information, such as credit card or other payment card information, bank account information, billing addresses, or other information necessary when you purchase services from us or one of our customers;

• Geolocation data: We may use your IP address to identify your location country for fraud detection purposes;

• Professional/Employment Data: Job Application information, if you apply for a position with us through our Site (see the Job Applicant Privacy Notice).

Data We Collect Indirectly from You

We receive and store certain types of information automatically. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, web-browser software (such as Chrome, Firefox, Safari, Internet Explorer, or Microsoft Edge), your Internet Protocol (IP) address/MAC address/device identifier and location country. We use this information so we can protect your information from being used fraudulently, for example, from a different IP address unrelated to you or country.

If you are using our Site or our Services, we may also collect information about your usage of via cookies, website analytics, capturing server logs, and other methods. See our Cookie Notice for more information about those practices.

How & Why We Use Your Data

Data protection laws require that we only use your Personal Information for certain reasons and where we have a legal basis for doing so. Here are the reasons for which we process your Personal Information.

• General Business Operations: This includes operating our Site and Services (including logging in and authenticating users) and processing payments. Legal Basis: Entering or Performing a Contract; Legitimate Interests

• Providing our Services: We process your Personal Information to provide you with our services that you request. We share this information with third-party service providers upon your request, or our service providers or partners to the extent necessary to provide you with our Services. We cannot provide you with Services that you have requested without processing your Personal Information. We may also use your data as is necessary to fulfill our Terms and Conditions. Legal Basis: Entering or Performing a Contract; Legitimate Interests

• Communicating with You:
• Account-Related Communications: When you sign up for our services, we will use your contact information to send administrative or account-related information to you to apprise you about our services. We consider these required operational messages, therefore even if you have unsubscribed from our marketing communications you may receive these messages as they may be required by law, essential to the functioning or security of your account, or otherwise reasonably required. Legal Basis: Entering or Performing a Contract; Legal Requirements; Legitimate Interests
• Marketing Communications: If you subscribe to our newsletters, we will use your name and email address to send them to you. Specifically, we may process your contact information and information about your interactions with our services to: (i) send you marketing communications; (ii) provide you with information about events, webinars, or other materials; (iii) deliver targeted marketing to you; and (iv) keep you updated about our services. You can opt-out of our marketing activities at any time and free of charge. If you do not wish to receive such communications from us, you may follow the instructions in these communications to “unsubscribe,” or contact us using the information listed under “Contact Us” at the end of this Notice. Legal Basis: Consent
• Responding to You: When you contact us, such as with questions, concerns, feedback, disputes or issues, we process your Personal Information to respond to you or to ensure your continued ability to use and enjoy our services. Legal Basis: Entering or Performing a Contract

• Maintaining and Securing our Services: We may process any of your Personal Information to: (i) combat fraud, malware, malicious activities, illegal activities, or security risks; (ii) improve and enforce our security measures; (iii) to monitor and verify your identity so that unauthorized users do not access your account with us; and (iv) generally maintain and secure our Site and services. We cannot ensure that our Site works as intended and in a secure manner if we do not process your Personal Information for these purposes. Legal Basis: Entering or Performing a Contract; Legitimate Interests

• Personalizing our Services for You: We use cookies and similar tracking technology to personalize your experience on the Site. By personalizing our services, you get to enjoy our services even more because we keep track of your preferences (e.g., your language selection, your time zone, etc.). Without processing your Personal Information for such purposes, you may not be able to access or personalize part or all of our services. Legal Basis: Entering or Performing a Contract; Legitimate Interests

• Legal Purposes: We may process any of your Personal Information to: (i) monitor, investigate, prevent, and mitigate any alleged or actual prohibited, illicit, or illegal activities on our services; (ii) investigate, prevent, or mitigate violations of our terms, agreements, or policies; (iii) enforce our agreements with third parties and partners; and (iv) comply with applicable laws, such as business, privacy, employment and recruitment laws. We cannot perform our services in accordance or compliance with our terms, agreements, or policies or applicable laws without processing your Personal Information for such purposes. Legal Basis: Legitimate Interests

• Improving our Services: To continue to provide you with our innovative services, we may collect information about the way you use and interact with our Site for research and development purposes. Research and development help us improve our services and build new services and customized features or services. We take additional security measures when processing your personal information for such purposes, by de-identifying or pseudonymizing your information, limiting access to personnel that may conduct research and development, and applying other technical, physical, and administrative security measures. Without processing your Personal Information for such purposes, we cannot guarantee your continued enjoyment of part or all of our services. Legal Basis: Entering or Performing a Contract; Legitimate Interests

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission.

You may choose not to have your personal information shared with third parties where we rely on consent as the lawful basis for processing your personal information. You may also choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization.

If you choose to limit the use of your personal information, we may not be able to continue to offer our Services to you, or your usage of our Services may be limited or impaired; if your choices trigger such limitations, we will do our best to explain the impact so that you can make an informed choice.

We do not combine your data with data from other sources, or combine it with data collected from our own activities, for any purpose other than providing our Services as described above; we do not use your data for behavioral ad targeting, nor do we share your data with any third party for that purpose.

How We Share Your Data

We may disclose your Personal Information in the following circumstances to the extent permitted under applicable law:

• Financial Transaction-Related Disclosures. Information that you provide, or that we collect automatically, may be used in order to facilitate the requested financial transactions. This may include capturing and sharing information with certain government authorities, such as tax authorities. We may share this data with other financial institutions as may be required to facilitate the transactions requested. We may also use this information to communicate with you about your transactions.

• Vendors/Service Providers. We may share your Personal Information under confidentiality agreements with other companies that work with, or on behalf of, us to provide products and services. These companies may use your Personal Information to assist us in our operations. However, these companies do not have any independent right to share this information.

• Legal Disclosures. We may provide information about you to respond to subpoenas, court orders, legal process, or governmental regulations, to establish or exercise our legal rights or defend against legal claims, or where we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

• Mergers and Acquisitions. We may share your Personal Information with other business entities in connection with the sale, assignment, merger, or other transfer of all or a portion of our business to such business entity. If as a result of this activity there are any substantive changes to our practices regarding your Personal Information, you will be provided with notice and an opportunity to object.

• Communications. We may share your information in order to provide requested communications, service update notices, and promotional offers based on your communication preferences and consent (where this is permitted by, and in accordance with, applicable law).

Sale of Data

We do not sell your data.

How We Protect Your Data

We understand how important your privacy is. While we take reasonable precautions and use commercially reasonable measures to protect your data, no systems are guaranteed to be perfectly secure. We use various industry standard safeguards, such as firewalls and data encryption, to keep all your personal information, including payment details, secure. We regularly review our practices and have a dedicated security team that monitors and maintains our systems. Where required by law, regulation, or contract, we adhere to applicable security standards and practices.

Data Retention

We store data that identifies for only so long as is necessary to provide our Services to you, or for the duration of our business relationship with you. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. For example, we may retain certain purchase information for accounting, tax, security, and compliance purposes even after the immediate purpose of the data collection has been fulfilled or beyond the point at which our business relationship ceases.

Transfers to a third country and safeguards

Reach utilizes service providers that may store, transfer, and otherwise process your personal information in countries outside of the country of your residence. We execute data processing agreements with any third party who may process your data in which those service providers agree to provide at least the same level of privacy safeguards as required under applicable data protection laws and this privacy policy.

Children’s personal information

We do not knowingly request to collect personal information from any person under the age of 18.

Your Rights

You have the right to:

• Request access all personally identifiable information that we hold about you;

• Request to restrict or object to the processing of the personal data we hold about you;

• Request to erase your personal data;

• Request to receive personal data about you that you have provided to us in a structured, commonly used, machine readable format where we use it with your consent;

• Request to opt-out of sale or sharing of personal information;

• Request to correct any inaccurate data;

• Request to limit use of sensitive information;

• Right to non-discrimination for exercising rights under law.

To exercise your rights, please email using the information contained in the Contact Us section below. We will respond a quickly as we can, usually within 72 hours, and provide you with further information on how to exercise these rights. Applicable law may require us to undertake reasonable measures to verify your identity, therefore we may request further information reasonably necessary to do so; if you do not provide us with such information in a timely manner, we may not be able to act upon your request.

Please note: applicable law may prevent us from certain corrections or deletions of data; if we are unable to comply with your request, we will provide you with an explanation and where applicable advise you of any further options you may have.

If you are located in the European Union or European Economic Area, the UK, or Switzerland, please also see our EU/EEA Privacy Notice for more information.

If you are a resident of California, please also see our California Privacy Notice for more information.

Cookies

For information about how we use Cookies, please see our Cookie Policy.

Changes to this Privacy Policy

We may periodically post changes to this Privacy Policy. When required by law, we will notify you of any changes to this Privacy Policy. If we make any material changes we will notify you by email (sent to the e-mail address provided to us) or by means of a notice prior to the change becoming effective.

Links

Throughout our Sites we may provide links to other websites or services. We provide those links for your convenience and, unless otherwise stated, we do not endorse the information provided on those websites, and we do not control their privacy or security practices. If you follow any links from this site, you do so at your own risk and you should familiarize yourself with their privacy and security practices before sharing any Personal Information.

Questions About this Notice

If you have any questions about this Notice, or any of the supplemental notices referenced above, please use the Contact Us information below.

Contact Us

With regards to this privacy policy, or if you have a complaint or request related to your rights and personal information, please contact us at compliance@withreach.com. You may also send written correspondence to:

• Reach UK: 3 Lloyd’s Avenue, London, UK EC3N 3DS

• Reach Canada: 2300, 150 9 Avenue SW, Calgary, AB T2P 3H9

• Reach EU: Maakri 19, 10145 Tallinn, Estonia 10145

• Reach Australia: 152 Elizabeth Street, Melbourne, Victoria, Australia 3000

• Reach USA: Fibercove, 1700 S. Lamar Blve #338, Austin TX 78704

Complaints

You can also complain about our processing of your personal information to the relevant data protection authority. To do so, you should contact the data protection authority in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.

In the UK, the relevant data protection authority is the Information Commissioner’s Office (ICO).

Need to add Canadian data protection authorities here as well.