Privacy Policy

At Reklaim Ltd. ("we," "our," "us," or "Reklaim"), your privacy is of the utmost importance. Thank you for taking the time to read our privacy policy (the "Privacy Policy"). This Privacy Policy sets out how we collect, use, process, store, and disclose your personal information on https://www.reklaimyou.com and affiliated websites, including but not limited to protect.reklaimyours.com (the "Website") and our mobile and web applications (the "Platform").

Reklaim helps you monetize your personal and derived non-personal information by licensing, selling, or otherwise disclosing it to third parties, including, but not limited to, brands, advertisers, ad agencies, market researchers, banks, investment firms, and adtech platforms such as DSPs and data management platforms (the "Purchasers") (collectively, the "Services") and others.

The Services provided through the Platform allow you to determine what personal information you would like to share with Purchasers in accordance with our Terms and Conditions. Reklaim negotiates the terms for these disclosures as described in our Notice of Financial Incentive. This Privacy Policy outlines how we collect, use, process, store, and disclose your personal information in connection with the provision of our Services.

By joining and using our Services, you freely and expressly consent to the collection, use, processing, storage, and disclosure of your personal and non-personal information as set out in this Privacy Policy.

Separate from our Services, we provide our business customers ("Customers") with 'Data Broker' activities, which consist of selling, sharing, or licensing personal information that Reklaim receives from third parties to our Customers for their own independent marketing, communications, or other business purposes. For example, Reklaim may use the insights from our Services to build an audience of prospective customers for advertisers to target with ads. If you are interested in exercising your privacy rights related to our Data Broker activities or would like to learn more about our Data Broker activities, please visit our Data Broker Privacy Notice.

We may collect personal information when you:

• Register or otherwise sign up for our Services;
• Use our Services;
• Visit our Website or Platform;
• Contact us;
• Through Third Parties;
• Provide us with your consent.

Information you provide:

• You provide information to create an account, such as your name, email address, and phone number. You can also upload a profile picture.
• Information you may choose to provide to Purchasers through the Platform, including:
  • Contact details include your name, email address, postal address, and phone number.
  • Biographical information includes your primary language, gender, date of birth, marital status, and education level.
  • Device information includes your mobile advertising ID, device model, device OS, phone service provider, IP address, and installed apps.
  • Household information includes your income, whether you rent or own, the type of mortgage and its rate, household size, and whether you are a parent.
  • Responses to specific questions about your interests, behaviours, and activities may include information deemed 'sensitive' under state-specific regulations. (See state-specific section below for more details.) These responses may consist of;
  • Health-related information, such as whether you are concerned about your health, whether you have contracted specific ailments, the medications you have taken, and your family's health history. This information is not deemed 'protected health information' under U.S. federal law.
  • Political information, such as whether you are a registered voter, your political party affiliation, and your political ideologies.
  • Information about your interests, including your reading and watching interests, your interest in alcohol and CBD/cannabis, and related taste preferences.
• Financial information, such as which credit cards you use, how many lines of credit you have open, your purchase history, and the charities you donate to.

Please note that any information you voluntarily provide through the Platform, such as responses to survey questions, is deemed to be affirmative written consent for Reklaim to 'sell' or 'share' the specific nature of these responses in conjunction with your personal information, unless otherwise restricted by you through use of the Platform.

Information You Provide That Is Necessary For Our Services

We require your payment details to compensate you for the information you share with our customers, such as your PayPal or Venmo account information. Information from your support inquiries about our Services, or from how you otherwise indicate you may be interested in our Services, may include your name, email address, phone number, and any message you send to us.

When you use our interactive chatbot, you may be prompted to provide your contact details.

Information We Automatically Collect:

Records of your consent (e.g., the date and time) for Reklaim to disclose your information to Purchasers.

• Metadata and analytics with your use of our Services, including IP address, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, and what you do on those pages.
• Use cookies, pixel tags, application programming interfaces (APIs), software development kits (SDKs), and similar tracking technologies to collect additional information as you interact with the Services automatically and to personalize your experience with our Services. Learn more about these tracking technologies below.
• When you select Reklaim to search for your data online by pressing 'scan for data,' Reklaim may collect your personal information from third parties, such as data brokers. This information may be disclosed to Purchasers unless you restrict its use through the Platform.
• When you elect to have Reklaim search for your information associated with public data security breaches, Reklaim does not obtain any additional data from these data breaches beyond confirmation if an email address or phone number is included in a publicly available data security breach. We make no claims regarding the accuracy of the information associated with a specific data security breach and disclaim all liability for information that Reklaim may enable you to view.
• When you interact with our accounts on our community forums or through our brand or community forums on a social media platform, we may collect certain information that you or the platform makes available to us, such as Website metadata analytics (above), your social media account ID, your social media 'likes,' click-throughs to our Website, or custom interactions.

We use the personal information we collect for the following purposes:

• To operate our Services, namely to facilitate the sale of your information to Purchasers with your consent.
• To search the Internet on your behalf to determine if your information may have been associated with a publicly available data security breach.
• To improve our Services.
• To provide our rewards program and otherwise process payments securely.
• For customer support.
• To communicate with you.
• For marketing and advertising, except for any phone numbers provided to Reklaim.
• For other business and legal purposes, such as detecting and preventing fraud, collecting amounts owing to us, and maintaining business records.

Otherwise, with your consent.

Purchasers generally use your personal information to help tailor their marketing and advertising programs, deliver more relevant advertising messages, conduct market research and product development initiatives, and gain a better understanding of consumer perceptions and behaviours. Purchasers also purchase this data with explicit consent, and to append it to an existing profile they may have. We act solely as an intermediary between you and the Purchasers. As such, we are not responsible for how Purchasers treat or use your personal information, and we hereby expressly disclaim any such responsibility. Where applicable, we ask Purchasers to honour the Digital Advertising Alliance self-regulatory codes and applicable law.

We disclose the information you choose to provide to Purchasers. To learn more about controlling these disclosures, refer to the 'My Orders' section of the Platform or visit the 'How To Earn' web page here.

We may also disclose your information to our corporate affiliates, as well as vendors or service providers who:

• Help us stay in touch by subscribing to our email updates.
• Manage and optimize our Services. As part of our Services, we may utilize third-party data brokers to provide information about you. These third parties are restricted from using the information shared for any purpose other than to give Reklaim information or related services, and you will only receive more marketing offers as a result of these disclosures if you provide us with specific consent for such use.
• Help us provide our chatbot. This may include disclosing communications with our service provider, Zendesk. The contents of the communications will not be used for any purpose other than to support us and are also subject to Zendesk's applicable Terms of Service and Privacy Policy.
• Provide marketing and advertising services (see 'Use Of Cookies And Tracking Technologies' for more information on your choices with these services).

In addition:

• We may share your personal information to:
  • Protect the legal rights of our company, employees, agents, and affiliates.
  • Protect the safety and security of our customers.
  • Detect and protect against fraud.
  • Comply with the law or legal process.
  • Conduct due diligence or complete a legal transaction related to the sale of our business or any assets.
• We may share your information at any time with your consent, except for any phone numbers provided to Reklaim.
• We may share de-identified, aggregate, or anonymous information for any purpose. This means the information we share does not identify specific individuals or is combined with other data to protect your privacy.

You have the right to exercise the following choices regarding our use of your personal information:

• Access or correct the personal information we maintain about you.
• Delete the personal information we maintain about you.
• Opt out of specific uses of your personal information, notably:
  • Email marketing. Follow the 'Unsubscribe' link in the footer of any commercial email message. Please note that we may continue to communicate with you about Service-specific messages even after you have requested to unsubscribe. To cease all communications, your account must be terminated.
  • SMS (text messages). Reply to any SMS with the keyword 'Stop.'
  • Tailored advertising using third-party cookies. Please refer to the 'Use of Cookies and Tracking Technologies' section below to learn how to opt out of tailored ads.

You can exercise these rights by contacting us at privacy@reklaimyours.com or via the Platform.

Like many companies, we use cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect information about your browsing activities, your interactions with our Websites and our Services, and to serve tailored ads and for the purposes described in this Privacy Policy. There are several ways to opt out of having your online activity and device data collected through these services, which we summarize below:

• Opting out of cookie use in our Cookie Preferences. You can opt out of third-party advertising cookies via our cookie preferences center or by clicking the 'Manage Cookies' link on our website footer. You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal).
• Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit the use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info

With Each of Our Vendors Individually.

The following advertising or marketing services partners offer opt-out features that let you opt out of the use of your information for interest-based advertising or profiling:

Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you must opt out on every browser and device you use.

Voluntary health-related information provided to Reklaim as part of the information collected via the Platform is not considered to be 'protected health information' as defined by the Health Insurance Portability and Accountability Act ("HIPAA"). All health-related information is self-reported by you with affirmative consent for Reklaim to use such information for any commercial purposes described in this policy and/or through our Services. As some of this information may be deemed 'sensitive' under state-specific laws, refer below for more information on exercising your choices with our use of this information.

We protect the information we collect about you by maintaining physical, electronic, and procedural safeguards to prevent unauthorized access to user data stored on our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We take reasonable precautions to protect your information both online and offline. The servers on which we store data are kept in a secure environment.

We will retain your information for as long as your account or inquiry is active or as needed to provide you with the website or any requested services and for a reasonable time after that in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Any account that has yet to be logged into and for which no rewards have been earned or redeemed for 180 days or more may be deemed inactive. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for any disclosure of your data resulting from errors or unauthorized acts by third parties.

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or "CPRA" (collectively, the "CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), the Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), Utah Consumer Privacy Act ("UCPA"), Oregon Consumer Privacy Act ("OCPA"), Texas Data Privacy and Security Act ("TXDPSA"), Florida Digital Bill of Rights ("FDBR"), the Montana Consumer Data Privacy Act ("MTCDPA"), the Iowa Consumer Data Protection Act ("IADPA"), the Delaware Personal Data Privacy Act ("DEPDPA"), the Nebraska Data Privacy Act ("NEDPA"), the New Hampshire Privacy Act ("NHPA"), the New Jersey Data Privacy Act ("NJDPA"), the Tennessee Information Protection Act ("TNIPA"), the Minnesota Consumer Data Privacy Act ("MNCDPA"), the Maryland Online Data Privacy Act ("MDODPA"), the Indiana Consumer Data Protection Act ("INCDPA"), the Kentucky Consumer Data Protection Act ("KYCDPA"), and the Rhode Island Data Transparency and Privacy Protection Act ("RIDTPPA") create additional privacy obligations for businesses and provide their residents with additional privacy rights.

Additional Privacy Rights:

In addition to the rights granted in 'Your Privacy Choices' above, if you are a resident of the above states, you have the right to:

• Opt out of the "sale" or "share" of your personal information for targeted advertising. Some third-party cookies placed on our website or mobile advertising identifiers collected through our application may be considered a 'sale' or 'share' for targeted advertising. You may opt out of such cookies as detailed in the 'Use Of Cookies And Tracking Technologies' section above or mobile ad identifiers used in the 'Mobile Privacy' section above. Additionally, with your consent, we 'sell'/'share' the information you provide us to Purchasers. You can update your consent in the Platform at any time.
• Control the use of 'Sensitive Personal Information'. Certain U.S. states have the right to consent to or otherwise limit the use of your sensitive personal information, including information you provide through our Platform, such as ethnicity or health-related information. In addition, we endeavour to remove any 'sensitive personal information' records associated with residents from Maryland from commercial sales activities. We only collect sensitive personal information you choose to provide, which is deemed affirmative consent for the 'sale' of such information. You can update your consent to collect, process, and disclose your sensitive personal information on the Platform at any time. NOTICE: We may sell your sensitive personal data.

You can exercise these rights by contacting us at privacy@reklaimyours.com or via the Platform.

Appeal:

If we deny your privacy request, you may appeal that decision by emailing us at privacy@reklaimyours.com. If you remain unsatisfied with our response, you have the right to file a complaint with your state's attorney general.

Authorized Agent:

If you are an authorized agent submitting a request on behalf of another person, you must provide a copy of a lawful power of attorney or written authorization signed by the consumer. If you request an authorized agent, you may receive additional instructions. Depending on the type of request, we may contact you or the consumer as permitted by law.

Right to Non-Discrimination:

We do not discriminate against customers who exercise their privacy rights.

Service Provider/Processor Designation:

We operate as a Controller (and a Business under CCPA).

We qualify all of our Services as available exclusively to visitors at least 18 years of age. If you believe we have obtained personal information associated with children under 18, please contact us at privacy@reklaimyours.com, and we will delete it.

Our Services may contain links to other websites or services. We do not control the information you provide or the information collected by these third-party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

We reserve the right to update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy on this page, accompanied by a "Last Updated" effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services.

If you have any questions about our privacy or security practices, or if you would like to request access to or correction of your personal information, you can contact us by email at privacy@reklaimyours.com or at:

Residents of Canada may also reach out to our Privacy Officer: privacy@reklaimyours.com