Privacy Policy

We primarily use personal data that you provide to us market, sell, license and deliver our Products or services to you, as described above, or to maintain, customize and add new resources and products and services that may be of interest to you, to enable you to participate in Site services such as the Reflection Software Community, and to allow communication and interaction between you and Reflection Software. In addition, we will share the personal data we collect from you under the following circumstances:


a. Protection of Rights. We will share personal data if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is appropriate to enforce the Terms of Use for the Site, including any investigation of potential violations thereof, (iii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Products or Site services, or (iv) such action is appropriate to protect the rights, property or safety of Reflection Software, its employees, customers, Site users, or others.


b. Asset/Equity Transfers. If we become involved in a merger, acquisition or other transaction involving the sale of some or all of Reflection Software’s assets or equity, information on customers and Site users, including personal data collected from you through your use of the Site and its services, could be included in the transferred assets, subject to applicable law. Users of the Site will be notified via a prominent notice on the Site prior to a change of ownership or control that would involve a transfer of your information held by us, subject to applicable law, including any statutory periods restricting disclosure.


c. Service Providers. In the event that we engage service providers as data processors on our behalf, then subject to appropriate confidentiality and security measures, including compliance with this Privacy Policy, we may share your personal data with them.  Any such third-party data processors are and/or will be subject to contractual agreements to ensure that they only process personal data provided by Reflection Software in a manner consistent with our obligations under GDPR requirements as more fully described and made accessible to you below. Reflection Software remains liable under such Principles if its agent processes your personal data in a manner inconsistent with the Principles, unless we can prove that we are not responsible for the event giving rise to any damage. 


d. Marketing Purposes. We will occasionally use your personal data for our own marketing purposes, subject to applicable law, and subject to your clearly indicated right to opt-out of receiving any such communications from us. If you are a resident of the European Union, we will require your express consent in order to be able to send your marketing-related communications. See the expanded Marketing section below.


e. Usage Data. We may share Usage Data and other aggregated, anonymized information that shows patterns, trends, preferences, and other collective characteristics of our customers and Site users, with third parties. Disclosure of this information helps us and our marketing partners evaluate and tailor our communications, advertisements, services and general business practices to the needs of our Users.


f. Public Authorities. We may disclose your personal data in response to lawful requests by public authorities, including to meet national security or enforcement requirements.