Privacy Policy – Reaction Media

Last modified: September 2024

Introduction

This Privacy Policy (“Privacy Policy” or “Policy”) describes how Reaction Media Group (“Company”, “we”, “our” or “us”) collects, stores, discloses or otherwise processes Personal Information (as defined bellow) about individuals who are using its Websites (the “Website(s)”) and other Company products and services (collectively, the “Services”).

This Privacy Policy is incorporated into and forms part of our Terms of Service which outline the terms and conditions you agree to when accessing and using the Websites and Services.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue, and avoid using our Website and\or Services. You are not legally required to provide us with any Personal Information (as defined below), but without it, we will not be able to provide you with the full range or with the best experience of using our Website and\or Services. We may revise this Privacy Policy at any time. You should visit this page periodically to review this Privacy Policy and any revisions.

1. What Types of Data We collect?

“Personal Information” means individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual. To provide and operate our Services, we may collect and process the following types of Personal Information:

Contact and Account Information: You are not required to register or provide any Personal Information in order to browse our Website and learn more about the Company and our Services. However, if you voluntarily contact us through any means of communications we make available (for example, digital contact forms, social media, etc.) for support or other general inquiries, when you choose to create an account, subscribe to our newsletter, or otherwise provide information directly to us, we will use such information to contact you, provide you with our newsletter, respond to your inquiry or provide you with the requested Service, as applicable. This information may include certain information you provide us with such as your name, email address and any additional information you decide to share with us.
If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we collect your user ID and username associated with that social networking service. We may also collect any information you make public using that social networking service or that the social networking service allows us to access.
Usage Data: When you interact with our Services, we collect your Internet Protocol (IP) address, Cookie ID, unique identifiers (e.g., MAC address and UUID).

Non-Personal Information

Means aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services.

We are not aware of the identity of the user from which Non-Personal Information is collected. Such Non-Personal Information may include aggregated Usage Data and other technical information transmitted by your device, such as browser type and Wi-Fi usage, non-precise geolocation data, as well as technical information pertaining to your clicks, your device, operating system, etc.

2. Why We Process Your Personal Information?

This section explains for what purposes we use your Personal Information and outlines the legal bases that underlie our usage.

Purpose	Legal basis
Provision of our Services; support. We use your Personal Information, such as your name and email address, to provide you with our services and provide customer support. This includes, for example, allowing you to log-in or responding to your inquiries.	The legal bases for processing this data are the performance of our contractual towards you; your consent (for example, when you provide Personal Information); and our legitimate interests. Our legitimate interests in this case are provision of our Services and supporting our customers.
Improve our Services. We collect and analyze information about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services, including debugging to identify and repair errors and undertaking internal research for technological development and demonstration.	The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving our Services.
Auditing related to counting ad impressions of unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with relevant specification and standards	The legal basis for processing this data is our legitimate interest. Our legitimate interest in this case is providing you with our Services, including content that better correspond with your interests, monetizing our Services and confirming our internal records and billing accuracy.
Marketing and Advertising. We use Tracking Technologies in order to provide you with advertisements when you visit our Services, including personalized and non-personalized advertising, in short-term, transient use, shown as part of a your current interaction with us.	The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests.
Integrity. We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, prevent fraud, identify your identity and enforce our policies.	The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users.
Compliance with applicable laws; assistance to law enforcement agencies. We process your Personal Information in order to comply with our legal obligation under applicable laws.	The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies.

3. Categories Of Recipients We Disclose Personal Information To:

We may disclose your Personal Information internally within our group, or externally to third parties that help us maintain, improve and provide our Services (for example, we share data with AWS Inc. and Snowflake Inc. who provide us with cloud storage services). We require these parties to process Personal Information subject to contractual obligations to privacy and data protection, in compliance with applicable laws, and subject to security and other appropriate safeguards. The categories of such third-party recipients include:

Entities Within the Company’s Group. We may share your Personal Information internally within the Company’s Group, as necessary for administrative, management or other business-relates purposes, to operate our Services, to communicate with you, to offer and provide our Services to you, etc.
Service Providers (including auditors and advisors). We may disclose Personal and non-Personal Information with our affiliated companies and additional third parties that perform services on our behalf, such as hosting, storage, analytics, advertising and marketing, database management, user engagement, cyber and data security. We may also share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputed etc.
Advertisers. We partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. We and our third-party advertisers use tracking technologies to gather information about your activities on our Services and other websites and apps to provide you with advertising based upon your browsing activities and interests. For further information on our and our advertisers’ use of tracking technologies please refer to the ‘Tracking Technology’ section.
Legal and Regulatory Entities. We may disclose any type of Personal Information, in case we believe, in good faith, that such disclosure is necessary to enforce our policies, take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, protect the security or integrity of the Service and protect the rights and property of the Company. We may also disclose your Personal Information when requested by legal or regulatory authorities in response to a verified request relating to terror acts, criminal investigations or similar illegal activity, or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.
Mergers and acquisitions. We may transfer and share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

4. Marketing Communications

We use your Personal Information ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at legal@reactionm.com. If you want to stop receiving our newsletter and any promotional materials, follow the unsubscribe instructions at the bottom of each promotional email or other method of notification.

Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

5. Tracking Technologies

We store Tracking Technologies on your device when you visit or access our Services – these are called “First Party Tracking Technologies“. In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners and advertisers), who provide content and ads on our Services – these are called “Third party Tracking Technologies“. Both types of Tracking Technologies be stored either for the duration of your visit on our Services or for repeat visits.

There are various ways in which you can manage and control your Tracking Technologies settings:

You can learn more of our use of tracking technologies and change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions).
We use the services of Retention.com to enhance and personalize your experience. If you prefer not to have your Personal Information processed for these purposes, you may opt-out via the link available here.
Other methods of managing your Tracking Technology preferences include changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.

Below is a list of useful links that can provide you with more information on how to manage your cookies:

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

6. Your Rights

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

Right to access to your Personal Information: You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information.
Right of data portability: You have the right to request to receive the personal data concerning you, which you have provided us with, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
Right of rectification: You have the right to request rectification of your Personal Information in our control in the event that your believe the Personal Information held by the Company is inaccurate, incomplete or outdated.
Right of erasure: You have the right to request that the Company erase your Personal Information.
Right to restriction or objection to processing: You have the right to request that the Company restrict or cease to conduct certain Personal Information processes at any time.
Right to withdraw your consent: To the extent we process Personal Information on the basis of your consent, you have the right to withdraw your given consent at any time.
Right to limit use and disclosure of your sensitive Personal Information: You have the right to request to limit the collection of your sensitive Personal Information, to the extent such data is processed by us.
Right not to be subject to automated decision making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you, to the extent such processing is conducted by us.
Right to opt-out from profiling in furtherance of decisions that produce legal or similarly significant effects concerning you: You have the right to request to opt-out from processing involving profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. “Profiling” means any form of automated processing performed on Personal Information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Right to Opt-Out of the Sale or share of Personal Information: In the event that we sell or share your Personal Information for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Information. After you opt-out, we may continue disclosing some Personal Information with our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services is working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
Right to non-discrimination: you have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
Right to appeal: You have the right to appeal our decisions regarding your requests to exercise your rights. Any appeal you wish to raise may be delivered via the contact information available below.

In addition, you also have the right to lodge a complaint and appeal our decisions: all requests, complaints or queries may be addressed to the Company to the following email address: legal@reactionm.com. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

7. International Transfer of Personal Information

We operate globally, and as a result we may share or process your Personal Information in the US, UK, EU, Israel or other countries, including via our affiliates, service providers and partners. However, the Company is committed to protect Personal Information in accordance with legal and privacy requirements and applies appropriate lawful mechanisms and contractual terms requiring adequate data protection to ensure Personal Information continues to be protected in the jurisdiction to which such data is transferred.

In case of a Personal Information transfer outside of the EEA or the UK we will, in the absence of an adequacy decision or other legal mechanisms, seek to rely on appropriate safeguards such as entering into the EU standard contractual clauses, the UK Transfer Addendum to such clauses, or a similar approved transfer mechanism, and only transfer data to such recipients which have entered into legal agreements with us ensuring an adequate level of data protection.

8. How We Protect Your Personal Information

We are strongly committed to the protection of your Personal Information, and we will take reasonable technical steps, which are accepted in our industry, to keep your Information secured and protect it from loss, misuse or unauthorized access, disclosure, or modification of Personal Information. We further protect Personal Information by restricting access to Personal Information to those employees, contractors, advisers, affiliates and service providers that the management of the Company has determined reasonably require access to such information to perform their duties and obligations or provide their services to us, as applicable.

Despite these efforts, please note that no data transmission or storage efforts can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us.

9. Minors

We do not knowingly collect information from anyone under the age of majority (as determined in accordance with applicable laws). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

If you believe that we might have any information from or about a minor, please contact us at legal@reactionm.com.

10. Additional Disclosures for U.S. Residents

This Section supplements the Privacy Policy and addresses specific disclosures requirements under US Privacy Laws. Most of the statements, rights and obligations under this part are common to all US Privacy Laws and apply to you only to the extent determined in the applicable law according to your residency.

10.1. Exercising your rights (pursuant to section 6 above) using an authorized agent

You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

The authorized agent is a natural person or a business entity; and
You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

The request must:

Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request 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; and
Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.

10.2. In the preceding 12 months, we have collected the following Personal Information:

Categories of Personal Information	Data Types
A – Identifiers	For example, IP address, name, surname, email, phone number.
F – Internet or other similar network activity	Your interactions with the Services, as well as IP addresses, unique device identifiers, device and operating system, browser version, pages visited, advertisements viewed or clicked on, your geographic location, log data and other information derived from your interaction with our Services.
G – Geolocation data	IP address and your non-precise geographic location.

10.3. Sources of Information

In the preceding 12 months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

Directly, through your activity on our Services. For example, from forms you complete on our Websites.
Indirectly from you. We track your activities across the internet, for example, when you view or interact with certain content, web page or ad, or when we collect your usage data automatically from measurement tools such as those implemented on our websites.
From third parties. for example, from advertisers, service providers who assist us in performing the Services for our customers, internet service providers, data analytics providers, social networks, recruitment agencies, and data brokers.

10.4. Selling, Sharing and Disclosing Personal Information

We do not “Sell” Personal Information, but we do “Share” Personal Information about you (in the meaning assigned to the terms “Sell” and “Share” under US Privacy Laws).

In the preceding twelve (12) months we have shared and disclosed your Personal Information, as described below:

Category of Recipient	Type of Data	Disclosed or Shared
Advertisers	Unique identifiers, IP address, user activity data (interaction with Ads)	Shared
Service Providers	All types of Personal Information	Disclosed
Any acquirer of our business	All types of Personal Information
Entities within the Company’s group	All types of Personal Information
Legal and regulatory entities	Subject to law enforcement or a competent authority request.

When we disclose Personal Information, we ensure that the recipient only has access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the Personal Information they receive, and where applicable, to use it for pre-agreed purposes only. We also take measures to contractually ensure any recipient complies with applicable data protection laws.

10.5. Opt-Out of Selling or Sharing Personal Information

To opt-out of sharing your Personal Information, as described above, please click here.

Additionally, California Civil Code Section 1798.83 permits customers of Company who are California residents to request certain information regarding its disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to legal@reactionm.com. Please note that we are only required to respond to one request per customer each year.

11. Updates to this Policy

The Website and our Services may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right, in our sole discretion, to update or modify this Privacy Policy at any time (collectively, “Modifications“). Modifications to this Privacy Policy will be displayed by the “Last Updated” date at the top of this Privacy Policy. Please review this Privacy Policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services following any Modifications to this Privacy Policy constitutes acceptance of those Modifications. If any Modification to this Privacy Policy is not acceptable to you, your sole remedy is to cease accessing, browsing and otherwise using the Services.

12. Controlling Version

The Privacy Policy has been drafted in English, serving as the original and controlling version of this Privacy Policy. Any translations of this Privacy Policy into other languages are provided for convenience only and shall not dictate the meaning or application of this Privacy Policy. In the event of any discrepancy between the meanings of any translated versions of the Privacy Policy and the English language version, the interpretation of the English language version shall prevail.

13. Contact Us

To ask questions or comment about this privacy policy and our privacy practices, contact us at: legal@reactionm.com.

If you reside in the EU, you may also contact our EU representative:
via mail: legal+EU@reactionm.com
Attn: EU Data Representative

If you reside in the UK, you may also contact our UK representative:
via mail: legal+UK@reactionm.com
Attn: UK Data Representative

Name of Third Party	Privacy Policy
Sovrn/Pub Media	https://www.sovrn.com/privacy-policy/
Verizon Media	https://www.verizonmedia.com/policies/us/en/verizonmedia/privacy/
Rhythmone	https://www.rhythmone.com/privacy-policy/
Index Exchange	https://www.indexexchange.com/privacy/
YieldMo	https://www.yieldmo.com/privacy-policy/
Nativo	https://admin.nativo.com/privacy
Appnexus	https://www.appnexus.com/de/platform-privacy-policy
Google	https://policies.google.com/privacy?hl=en-US
Retention.com	https://retention.com/compliance/