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OpenReel Privacy Policy


OpenReel
Privacy Policy


The
website located at 
www.OpenReel.com (the
“Website”) and any related mobile application (the “App,” and
collectively with the Website, the “Services”) are operated by
OpenReel, Inc. (“OpenReel”, “we,” “us,” or “our). This
Privacy Policy explains how we collect and use personally
identifiable information and non-identifying information about our
Users (“User”, “you”, “your”) when you access or use the
Services.


Please
read this page carefully. By accessing the Services or submitting
your Personal Information (defined below) in order to receive the
Services, you agree to the terms set forth in this Privacy Policy. IF
YOU DO NOT ACCEPT THE TERMS OF THIS PRIVACY POLICY, DO NOT ACCESS OR
USE THE SERVICES.


OpenReel
will notify you of any changes to this Privacy Policy by posting the
modified Privacy Policy and its effective date on this page.
Accordingly, you should visit this page periodically to identify and
understand any such changes. By continuing to access or use the
Services after a modification, you agree to be bound by the modified
Privacy Policy.




  1. INFORMATION
    COLLECTED BY OPENREEL






      1. Collection
        of Personal Information





Personal
Information” means all personally-identifiable information (such as
e.g., your name, physical address, e-mail address, home and mobile
telephone numbers, or birth date) that you submit in connection with
the Services. OpenReel does not collect Personal Information unless
you voluntarily submit it in connection with your use of the
Services, send inquiries to OpenReel, send inquiries through forms
located on the Website, or participate in certain activities
available via the Services. We collect Personal Information when you
choose to use certain features of the Services, including when you:
(i) create an account on the Website or the App; (ii) engage in
certain activities available via the Services, such as viewing or
engaging with content, videos, or photographs; or (iii) consent to
receive commercial or promotional email, direct mail, or SMS/text
messages about upcoming information, promotions or events
. You
can always choose not to be contacted or to “opt-out” of further
contact or solicitations from OpenReel by following the instructions
in the email.






      1. Information
        Gathered Automatically





OpenReel
automatically collects certain non-identifying information about you
(such as your movement about the Website or App, how you engage with
videos, the pages you visit most frequently, the type of browser or
computer operating system you use, or the domain name of the website
from which you link).


In
addition, OpenReel may collect certain information automatically,
including, but not limited to, the type of mobile device you use,
your mobile devices’ unique device ID, the IP address of your
mobile device, your mobile operating system, the type of mobile
internet browsers you use, and the information about the way you use
the Services.


OpenReel
may collect other passive information using technologies such as
standard server logs, cookies and clear GIFs (“Web Beacons”). Web
Beacons are small pieces of information or data stored on your
computer or mobile device that are used to determine your preferences
and track your search terms and other behaviors or activities as you
navigate around the Internet (collectively, “User Behavior”). If
you object to this practice, you may erase or block certain Web
Beacons. We recommend, however, that you allow Web Beacons to be
stored on your computer or mobile device as they may be needed to
properly use the Services.






      1. Information
        on Location Data





When
you use our Services, we may use GPS technology (or other similar
technology) to determine your current location in order to determine
the city you are located within and display a location map with
relevant advertisements. Based on your user setting, we may share
your current location with other users or partners to customize your
Services experience and view more relevant information.


If
you do not want us to use your location for the purposes set forth
above, you should turn off the location services for the mobile
application located in your account settings or in your mobile phone
settings and/or within the mobile application.






      1. Your
        Content





OpenReel
assumes no responsibility for securing any other content you submit
via the Services. OpenReel has no obligation to use, or solicit or
enable others to use any content you submit to us.


We
also may collect limited information from the people with whom you
interact by email when you use the Site and Services. This
information may include the number of times that the recipient opens
your email, engages with your videos, the recipient’s IP address
and the computer platform that the recipient is using.




  1. CHANGING
    OR REMOVING YOUR PERSONAL INFORMATION



OpenReel
will retain any Personal Information that you submit in connection
with your account unless OpenReel deems such Personal Information to
violate this Agreement or until such time as you decide to remove
such Personal Information. You understand that deleted Personal
Information may persist for a reasonable period of time in backup
copies but will not be available to others.


If
you wish to review, change, or remove any Personal Information that
you have provided in connection with the Services, or if you wish to
delete your account with us, please email us at info@OpenReel.com




  1. USE
    OR DISCLOSURE OF YOUR INFORMATION



OpenReel
may use your Personal Information to contact you regarding the
Services. We may also use your Personal Information to provide
services requested by you and for internal research and marketing
purposes. We may share your Personal Information and non-identifying
information that we collect from you with our parent, subsidiaries,
divisions, or affiliates.


OpenReel
may share your User Behavior on the Website with certain advertisers
and such advertisers may respond to your User Behavior on the Website
with advertisements or sponsored content.


OpenReel
will not use, disclose, or sell your Personal Information to any
third parties for any purposes other than those necessary to deliver
the Services. Otherwise, we will not sell or transfer to unaffiliated
third parties any Personal Information that you submit or any
non-identifying information collected without your consent.


The
Personal Information and non-identifying information we collect from
you may be used as follows:






      1. to
        personalize your experience and better respond to your individual
        needs;



      2. to
        improve the Services;



      3. to
        improve customer service;



      4. to
        administer contests, promotions, surveys or other features for the
        Services;



      5. to
        send periodic mailings concerning information and updates
        pertaining to OpenReel;



      6. to
        send special or promotional offers or discounts related to
        OpenReel or its affiliates and information related to products you
        have viewed via the Services; or



      7. as
        an asset in connection with a proposed or actual merger or sale
        (including any transfers made as part of an insolvency or
        bankruptcy proceeding) involving all or part of our business or as
        part of a corporate reorganization, stock sale or other change in
        control.





Notwithstanding
the foregoing or any other statements or representations here or
elsewhere, OpenReel reserves the right to disclose any Personal
Information in our possession if OpenReel believes that such
disclosure is necessary: (i) to conform to legal requirements or to
respond to a subpoena, search warrant, or other legal process
received by OpenReel, whether or not a response is required by
applicable law; (ii) to enforce or protect OpenReel’s rights; or
(iii) to protect the safety of users of OpenReel’s Services and
members of the general public.


Use
of Remote Capture Technology


If
you use our Remote Capture Technology as a Subject (as defined
below), please be advised that your Personal Information, including
the recording of your video, will be automatically shared with the
User (as defined below). If you do not agree to the sharing of your
Personal Information with the User, then DO NOT use the Remote
Capture Technology.


For
purposes of this subsection, Subject shall mean the individual who is
being recorded. For purposes of this subsection, User shall mean the
OpenReel customer using the App to remote capture the Subject.



WE
ARE NOT RESPONSIBLE FOR THE PERSONAL INFORMATION AND OTHER
NON-IDENTIFYING INFORMATION YOU CHOOSE TO SUBMIT IN ANY PUBLICLY
ACCESSIBLE AREA OF THE SERVICES.




  1. SECURITY



OpenReel
has reasonable security measures in place to protect Personal
Information you submit in order to receive the Services. While no
computer system or server is completely secure, we believe the
measures we implement reduce security problems. Notwithstanding the
foregoing, OpenReel cannot guarantee the security of your Personal
Information. When you communicate with OpenReel electronically or
otherwise submit your Personal Information, your communication is not
necessarily secure and is subject to all of the risks of
communication, including unauthorized entry or use, hardware or
software failure, and other factors that may compromise the security
of Personal Information at any time. OpenReel assumes no
responsibility for the security of any Personal Information you
submit.




  1. LINKS



We
may permit certain third parties to link to our Services, and the
Services may contain links to third-party sites. We may also
incorporate third party software (including open source software) in
the Services. OpenReel is not responsible for the privacy policies or
practices of such third parties, including on such third parties’
websites. When linking to a third party website, you should read the
privacy policy stated on that website. This Privacy Policy only
governs Personal Information, non-identifying information and content
collected in connection with the Services.




  1. INTERNATIONAL
    VISITORS




The
Services are hosted and operated in the United States (“US”) and
elsewhere in the world. By using the Services, you are consenting to
the transfer of your personal information to the US. If you are
accessing our Site from outside the US, please be advised that US law
may not offer the same privacy protections as the laws of your
jurisdiction.



General
Data Protection Regulation


We abide by the General Data Protection
Regulation (GDPR). The GDPR provides a framework for organizations
to ensure protection of the personal information of European citizens
and gives European citizens certain rights.


Legal Basis for Processing


If you are an individual from the EEA or
Switzerland, our legal basis for processing your personal information
will depend on the personal information concerned and the specific
context in which it is collected. However, we will normally collect
or process personal information from you only where:



  • We have your consent to do so;


  • Where we need the personal
    information to perform a contract with you (e.g. to deliver
    services); or


  • Where the party is in our or a third
    party’s legitimate interests (and not overridden by your data
    protection interests or fundamental rights and freedoms).




In some cases, we may also have a legal obligation to process
personal information from you, or may need the personal information
to protect your vital interest or those of another person.



Where we rely on your consent to process the personal information,
you have the right to withdraw or decline your consent at any time.
Please note that this does not affect the lawfulness of the
processing based on consent before its withdrawal.



Our Services may contain links to other websites and the information
practices and the content of such other websites are governed by the
privacy statements of such other websites. We encourage you to review
the privacy statements of any such other websites to understand their
information practices.



Retention



We will retain your personal information for as long as is needed to
fulfill the purposes outlined in this Privacy Policy, unless a longer
retention period is required or permitted by law.



Rights to Access and Control Your Personal Data



Individuals residing in the EEA and Switzerland have certain rights
to access and control their personal data. These rights include:



  • the right to be informed;


  • the right of access;


  • the right to rectification;


  • the right to erasure;


  • the right to restrict processing;


  • the right to data portability;


  • the right to object; and


  • rights in relation to automated
    decision making and profiling.







For a full list of
rights, please visit [HYPERLINK TO GDPR WEBSITE
https://www.eugdpr.org/].




  1. ACCESS TO PERSONAL DATA




This
Policy explains how Users may access and/or submit requests to
review, correct, update, or delete personal information. Our Users
can ask to review and correct personal data that we maintain about
them by sending an email to info@openreel.com



If
you are a customer of a User, please contact the User directly with
your request to limit the use or disclosure of your personal data.




  1. ADDITIONAL
    PROTECTIONS FOR CHILDREN



The
Services are not designed for or targeted to children under the age
of 13, and OpenReel will never knowingly solicit or collect the
Personal Information of a child under the age of 13. If we discover
that Personal Information of a child under the age of 13 has been
submitted without verifiable parental consent, we will immediately
delete such Personal Information.




  1. CALIFORNIA
    PRIVACY RIGHTS



Under
California’s “Shine the Light” law, California residents who
provide personal information in obtaining products or services for
personal, family or household use are entitled to request and obtain
from us once a calendar year information about the customer
information we shared, if any, with other businesses for their own
direct marketing uses. If applicable, this information would include
the categories of customer information and the names and addresses of
those businesses with which we shared customer information for the
immediately prior calendar year (e.g. requests made in 2017 will
receive information regarding 2016 sharing activities).


To
obtain this information, please send an email message to
info@OpenReel.com with “Request for California Privacy Information”
on the subject line and in the body of your message. We will provide
the requested information to you at your e-mail address in response.
Please be aware that not all information sharing is covered by the
“Shine the Light” requirements and only information on covered
sharing will be included in our response




  1. DO
    NOT TRACK POLICY



The
Website does not currently respond to a “do not track” or similar
signal. Our Application has a “forget this device” function.
You can access the “forget this device” function by clicking on
the menu within the application.




  1. CONTACT
    INFORMATION



If
you have any questions about this Privacy Policy or your dealings
with OpenReel, please feel free to contact us at:


OpenReel,
Inc.


425
N. Broadway


#201


Jericho,
NY 11753


Email:
info@OpenReel.com


Effective
date: 3 / 5 / 17


Last
Update: 2/1/19