Privacy Policy
Last updated: January 5, 2025
Reflare.io ("us", "we", or "our") operates https://reflare.io (the "Service").
Company Information
Service operator: Reflare Ltd, registered in Cyprus
- Registration Number: Pending registration
- Address: Pending registration
- Legal Representative: Henri Griesmar
- Technical Contact & DPO: Nicolas Sénécal
- Support & Privacy Contact: support@reflare.io
- Hosting: OVH
This policy confirms data use aligns with stated practices and references our Terms and Conditions.
Definitions
- Personal Data: Information identifying living individuals
- Usage Data: Automatically collected information about Service access
- Cookies: Small data files stored on user devices
- Data Controller: Entity determining data processing purposes/methods
- Data Processor/Service Provider: Entity processing data on controller's behalf
- Data Subject: Individual subject to Personal Data processing
- User: Individual using the Service
Information Collection And Use
YouTube Data Usage
Collected data includes:
- Video metadata, statistics, performance metrics
- Channel information and analytics
- Engagement metrics and audience demographics
- Subtitles, captions, thumbnails
- Upload permissions for thumbnail modifications
Purpose: AI-powered content optimization services, video analysis, A/B testing, and dashboards.
Data Retention: Retained as long as your account remains active. You can revoke access at any time.
Compliance: YouTube Terms of Service compliance confirmed.
Google Profile Information: Name, profile picture, and email used for account identification only.
Google API Usage: Access YouTube account for video listing, performance analysis, and thumbnail updates. Data not shared with third parties. Revocation available via Google Security Settings.
Personal Data
Types collected: email address, first and last name, cookies, usage data.
Newsletter and promotional materials sent; users may opt out via unsubscribe options.
Usage Data
Collected information: IP address, browser type/version, visited pages, visit timing, time spent, device identifiers, diagnostic data.
Tracking & Cookies Data
Cookies track Service activity and retain information. Users can refuse cookies via browser settings, though this may limit Service functionality.
Cookie Types:
- Session Cookies: Service operation
- Preference Cookies: Settings and preferences
- Security Cookies: Security purposes
Customer Data
Includes personal information about end users, customers, and website visitors. Processing limited to agreement-specified purposes.
Use of Data
Data used for:
- Service provision and maintenance
- Change notifications
- Interactive feature participation
- Customer support
- Service analysis and improvement
- Usage monitoring
- Technical issue detection/prevention
- News, offers, and service information
Retention of Data
Personal Data retained as necessary per policy purposes. Usage Data retained shorter periods except when strengthening security or improving functionality. Legal obligations may extend retention.
Transfer Of Data
Data may transfer to computers outside user's jurisdiction. Adequate controls ensure secure treatment per policy. No transfer occurs without proper safeguards.
Business Transaction
Merger, acquisition, or asset sale may transfer Personal Data. Notice provided before transfer and new policy disclosure occurs.
Disclosure for Law Enforcement
Disclosure occurs if legally required or for valid public authority requests.
Legal Requirements
Disclosure made to:
- Comply with legal obligations
- Protect Reflare.io rights/property
- Prevent/investigate wrongdoing
- Protect user safety
- Prevent legal liability
Security Of Data
Implemented measures:
- TLS/SSL encryption in transit; industry-standard encryption at rest
- Strict access controls and authentication
- Regular security audits and vulnerability testing
- OVH hosting with ISO 27001 certification
- Encrypted OAuth token storage
No method of transmission is 100% secure. Breach notification within 72 hours per GDPR.
"Do Not Track" Signals
DNT not supported. Users can enable/disable via browser preferences.
GDPR Compliance and Your Rights
Legal Basis for Processing
- Consent (YouTube data, marketing)
- Contract Performance (SaaS services)
- Legitimate Interest (improvement, security, fraud prevention)
- Legal Obligation (regulatory compliance)
User Rights
- Right of Access: Request personal data copy
- Right of Rectification: Correct inaccurate data
- Right of Erasure: Delete data under certain circumstances
- Right of Portability: Transfer data in machine-readable format
- Right of Restriction: Limit processing
- Right to Object: Object to processing based on interests/marketing
- Right to Withdraw Consent: Revoke consent anytime
Exercising Rights
Via account dashboard, support@reflare.io, or privacy-specific inquiries.
Response Time: 30 days of receipt. Delays communicated with reasons.
Account Deletion Process
- Marked for deletion with 30-day grace period
- Account restoration possible during grace period
- Permanent deletion after 30 days
- Email confirmations provided
- Legal compliance data may be retained
Complaint Rights: Lodge complaints with local data protection authority.
CCPA Compliance (California Residents)
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information.
Your Rights Under CCPA
- Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you
- Right to Delete: Request deletion of your personal information, subject to certain exceptions
- Right to Opt-Out: Opt out of the sale of your personal information. Note: We do not sell personal information
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights
Categories of Information Collected
In the past 12 months, we may have collected the following categories of personal information: identifiers (name, email), internet activity (browsing history, interactions with our Service), and professional information (YouTube channel data).
Exercising Your Rights
To exercise your CCPA rights, contact us at support@reflare.io. We will verify your identity before processing your request and respond within 45 days.
Marketing Use of Your Content
As described in our Terms of Service, by using our Service you grant us a license to use thumbnails and related content for marketing purposes. This may include featuring your content on our website, social media, case studies, and promotional materials.
You may revoke this marketing license at any time by contacting us at support@reflare.io. For full details, please refer to the "Marketing License" section of our Terms of Service.
Service Providers
Third parties facilitate the Service. Access limited to assigned tasks; disclosure/unauthorized use prohibited.
Analytics
Google Analytics
Tracks website traffic and usage. Data shared with other Google services for advertising contextualization.
Opt-out via Google Analytics opt-out browser add-on.
Behavioral Remarketing
Cookies inform and optimize ads based on past Service visits.
Google AdWords
Remarketing service by Google Inc. Opt-out via Google Ads Settings. Google Analytics Opt-out Browser Add-on recommended.
Remarketing service by Facebook Inc. Interest-based advertising information available. Opt-out via Facebook instructions or Digital Advertising Alliance (USA, Canada, Europe).
Payments
Payment card details not stored; provided directly to third-party processors. PCI-DSS standards compliance. Stripe is the payment processor.
Links To Other Sites
Third-party links may appear. Users advised to review external privacy policies. Reflare.io assumes no responsibility for external sites.
Security
Reasonable, commercially acceptable security procedures implemented. No method guaranteed 100% secure.
Children's Privacy
Service doesn't address users under 13. Unknowing collection from children results in data removal. Parents/guardians should contact for concerns.
Changes To This Privacy Policy
Updates posted on page. Email and prominent Service notice provided prior to effectiveness. Review periodically recommended.
Contact Us
Questions directed to support@reflare.io