1. DATA WE MAY COLLECT
We may collect and process the following data about you:
• Personal data including, for example, your name, e-mail address, password, and in certain instances, telephone number, data about your usage of the Products and data collected by tracking technologies as further described in section 4 below that may identify you as an individual or allow online contact with you as an individual.
• Reverberation Tech Pvt Ltd does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data concerning in-app purchases made through the Apps, and our payment processor collects Payment Card data concerning purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored and your__ card’s type, expiration date, billing address, and the last four digits of your card number.__
• Facebook profile information, such as name, email address, and Facebook ID, if you log in to the Products through Facebook.
• Device information such as operating system version, device type, and system performance data.
• Data collected via tracking technologies, as fully described in section 4.
2. CONFIDENTIALITY AND SECURITY
The security of your data is important to us. We follow generally accepted standards to protect the personal data submitted to us during transmission and after receiving it. If you have any questions about the security of your data, you can contact us at email@example.com. Except as described under the “Disclosure of Your Data” section below, we do not provide your data to any third party without your specific consent, as defined by applicable law.
3. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials via email and (push notifications), we will use the data you give us to provide the communications you have requested. If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or emailing us at firstname.lastname@example.org, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level.
If you provide your phone number to us directly or through a third party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such an SMS message (the “SMS Service”). Standard text message rates will apply.
4. TRACKING TECHNOLOGIES
Reverberation Tech Pvt Ltd and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password, so you don't need to do it for every web page requested and to measure how people are using the Products.
We use local storage, such as HTML5, to store content data and preferences. Third parties with whom we partner to provide certain product features also use HTML5 to collect and store data. Various browsers may offer management tools for removing HTML5.
We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms and across your other devices based on your past visits to our Website. Our third-party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third-party platforms. You may also opt-out of receiving ads across devices by adjusting your ad preference in your Google account.
We use third-party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third-party platforms. The Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.
We will acquire consent from you in order to use such trackers to the extent required by applicable law.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
As true of most websites, we gather certain data and store it in log files. This data may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
5. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through the Products is stored on our secure servers located in the US. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on Reverberation Tech Pvt Ltd’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
6. SINGLE SIGN-ON
You may be able to log-in to our Products using sign-in services such as Facebook Connect or Google Auth. These services will authenticate your identity, provide you the option to share certain personal data (such as your name and email address) with us, and to pre-populate our sign-up form. Services like Facebook Connect give you the option to post data about your activities on our Products or to your profile page to share with others within your network.
7. YOUR DATA RIGHTS
As you may know, a recent European Union law called the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. Accordingly, we have implemented transparency and access controls to help such users exercise those rights. As required under applicable law, the rights afforded to you are:
A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy thereof. We provide you an access to such data, to get access please email us at email@example.com
A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, Reverberation Tech Pvt Ltd will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and Reverberation Tech Pvt Ltd may have legal or legitimate grounds for keeping such data.
A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
A right to data portability: you have the right to receive the personal data concerning you which you have provided to Reverberation Tech Pvt Ltd, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from Reverberation Tech Pvt Ltd. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of Reverberation Tech Pvt Ltd. Reverberation Tech Pvt Ltd may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by mailing us at firstname.lastname@example.org
A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Reverberation Tech Pvt Ltd’s personal data protection practices.
A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Reverberation Tech Pvt Ltd instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com
You may access your data to modify or update at any time by emailing firstname.lastname@example.org.
We will respond to your request in a reasonable timeframe by applicable law.
8. USES MADE OF THE DATA
We use information about you in the following ways:
- To provide you with the Products.
- To answer your questions or requests for information or handle your complaints.
- To ensure that content provided by the Products is presented most effectively for you and your computer or another device.
- To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law.
- To carry out our obligations arising from any agreements between you and us.
- To allow you to participate in interactive features of the Products when you choose to do so.
- To notify you about updates or changes to Product features and content.
- To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state, or country).
- To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Website.
- To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps, or across your devices, to the extent that you have provided consent for such uses under applicable law.
- To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
- We may also ask you to complete surveys we use for research purposes, although you do not have to respond.
- To manage your payments and orders.
- If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you, except if you are opt-out of such communications.
9. LEGAL BASES OF PERSONAL DATA PROCESSING
By GDPR, Reverberation Tech Pvt Ltd provides the following information regarding its Article 6 legal bases for personal data processing:
The performance of the contract (the Reverberation Tech Pvt Ltd Terms & Conditions) between you and Reverberation Tech Pvt Ltd for the data processing relating to your use of Reverberation Tech Pvt Ltd’s Products (including your orders and payments);
Reverberation Tech Pvt Ltd’s legitimate interest, more specifically:
- Our business interest is in providing you with emails and push notifications for timely introductory materials and information about your Reverberation Tech Pvt Ltd account, our Product features and updates, and offers to upgrade your free account to a subscription account.
- Our financial interest in providing you with promotional offers and discounts concerning paid subscriptions and special offerings, such as the Reverberation Tech Pvt Ltd Family Plan.
- Our business interest is in offering you particularized or adapted content based on your usage of the Products.
- Our business is interested in collecting data regarding your general usage activities to improve our Reverberation Tech Pvt Ltd user experience.
- Our business is interested in requesting that you participate in Product surveys to better understand your needs and expectations.
- Our financial interest in providing you the opportunity to purchase Reverberation Tech Pvt Ltd subscriptions for the benefit of a third party through the Reverberation Tech Pvt Ltd “referral” program.
- Our business interest in providing you with customer service communications regarding your account, questions about our content offerings or your mindfulness practice, or any other matters directed to customer service staff, to have clear and easy communication with you and to respond to all your requests.
- Our business interest is collecting data related to unplanned downtime or errors in the Products.
- Our business interest is complying with our legal obligations, such as maintaining accurate financial records.
10. DISCLOSURE OF YOUR DATA
We may disclose your data to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries.
We may also disclose your data to third parties as follows:
- In some circumstances, based on your specific requests, we may need to disclose your data to a third party so that it can provide a service you have requested from such party or fulfill a request for data from such party. An example of this is the SMS Service.
- In some circumstances, we may disclose the personal data that you have provided to Reverberation Tech Pvt Ltd to a third party that offers and provides goods or services complementary to our own to enhance our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
- If Reverberation Tech Pvt Ltd’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Reverberation Tech Pvt Ltd., Reverberation Tech Pvt Ltd requires each of its service providers to agree to maintain the confidentiality and security of your data.
- If we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets.
- If Reverberation Tech Pvt Ltd or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
- If we are under a duty to disclose or share your data to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, or similar legal process, to enforce or apply our agreements with you; or to protect the rights, property, or safety of Reverberation Tech Pvt Ltd, our customers, or others. This includes exchanging data with other companies and organizations for fraud protection and credit risk reduction.
- With third parties, such as Facebook, to serve Reverberation Tech Pvt Ltd advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.
12. DATA RETENTION
The retention periods applied by Reverberation Tech Pvt Ltd comply with applicable legislation in effect on the date hereof, namely:
- For data relating to your account: such data will not be retained beyond your request that your account be deleted.
- For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Reverberation Tech Pvt Ltd.
- For data collected based on your consent to receive our marketing communications: we will use such data until you withdraw consent or applicable law requires that such data is no longer used.
- When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
- When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months.
Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
13. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing email@example.com
14. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.
15. SOCIAL MEDIA WIDGETS
Our Products include social media features, such as the Facebook Like button, and widgets, such as the “Share This” button, or interactive mini-programs. These features may collect your Internet protocol address, which page you are visiting on or Products, and may set a cookie to enable the feature to function properly. Social media features and widgets are hosted by a third party or hosted directly on our Products. Your interactions with these features are governed by the privacy statement of the company providing it.
16. USE OF Reverberation Tech Pvt Ltd BY MINORS
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such a person's account.
17. DATA POSTED ON FORUMS
Reverberation Tech Pvt Ltd users may have the ability to post content to one or more Reverberation Tech Pvt Ltd forums. All such users may request and obtain removal of such posted content by contacting Reverberation Tech Pvt Ltd at firstname.lastname@example.org and specifically identifying the content to be removed. Please be advised that any such removal does not ensure complete or comprehensive removal of all traces of the content posted on the Reverberation Tech Pvt Ltd forum(s).
20. DATA TRANSFER
You agree that all Personal Information collected via or by Reverberation Tech Private Ltd may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Reverberation Tech Pvt Ltd, you explicitly consent to the storage of your Personal Information in these locations.
1. INFORMATION WE MAY COLLECT FROM YOU
Our Products collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Products have collected the following categories of personal information from consumers within the last twelve (12) months:
1. Identifiers : First and last name, email address, Internet Protocol address, online identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). : First and last name.
3. Internet or other similar network activity : Browsing history or information on a consumer’s interaction with the Products or our advertisements on third-party platforms.
Personal information does not include: (1) deidentified or aggregated consumer information; (2) publicly available information from government records; or (3) information excluded from the CCPA’s scope.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete when registering for the Products.
Indirectly from you. For example, from observing your actions on our Products.
2. USE OF PERSONAL INFORMATION
3. SHARING PERSONAL INFORMATION
We may disclose your personal information to third parties for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category 1: Identifiers
- Category 2: Personal Information
- Category 3: Internet activity
4. YOUR RIGHTS AND CHOICES
Access to Specific Information and Data Portability Rights
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
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. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The categories of personal information we share with third parties.
- The specific pieces of personal information we collected about you (also called a data
- portability request).
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, and take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by emailing us at email@example.com.
Only you, or someone legally authorized to act on your behalf, 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 12 months. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify that you are the person we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot reply to your submission or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We also provide a snapshot of your personal information that we have processed via mail on your request. For this, you can email us at firstname.lastname@example.org.
Response Timing and Format.
Upon receiving a request for access, portability, or deletion, we will confirm receipt within ten days and provide information about our verification process and how we will process the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. We will inform you of the reason and extension period in writing if we require more time.
We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.
Any disclosures we provide will only cover the 12 months preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the proposal warrants a price, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
5. Cookie-Based Marketing Opt-Out
Like most companies, we partner with third parties, such as Facebook and Google, to manage our marketing of Reverberation Tech Pvt Ltd on other platforms, where such advertising is based on your past visits to our Products. These third-party partners may use technologies, such as cookies, to gather information about your activities on the Products to deliver such advertising to you when you visit their platforms. For instance, if you visit https://urban.health, a cookie may be attached to your browser in the form of the Facebook Pixel that allows Reverberation Tech Pvt Ltd to deliver advertising to you on the Facebook platform.
We do not sell or rent your personal information to any third parties for advertising or marketing purposes.
We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:
- 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 with 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.
However, we may offer you specific financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires prior opt-in consent, which you may revoke at any time.
7. Changes to our CCPA Addendum
We reserve the right to amend this CCPA Addendum at our discretion and at any time. When we make changes to this CCPA Addendum, we will post the updated notice on the Website and update the effective date. Your continued use of our Products following the posting of changes constitutes your acceptance of such changes.
8. Contact Information