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. 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. 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. 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.

2. 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

3. 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. 1. 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.

4. 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. WHEN YOU COMMUNICATE WITH OPENREEL ELECTRONICALLY OR OTHERWISE SUBMIT YOUR PERSONAL INFORMATION, YOUR COMMUNICATION IS SUBJECT TO ALL OF THE RISKS OF COMMUNICATION AND OTHER FACTORS THAT MAY COMPROMISE THE SECURITY OF PERSONAL INFORMATION.

5. 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.

6. 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 HTTPS://WWW.EUGDPR.ORG

7. 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.

8. 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.

9. 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

10. 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.

11. 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.

80 ORVILLE DR.

SUITE 100

BOHEMIA, NY 11716

EMAIL: INFO@OPENREEL.COM

EFFECTIVE DATE: 3 / 5 / 17

LAST UPDATE: 2/1/19