LAST UPDATED: 2021-10-19
Introduction
Welcome to REEF. REEF Global Inc. (“the Company,” “we” or “us”) and its affiliates and subsidiaries (collectively “the Company,” “we” or “us”) are committed to protecting the privacy of information collected from you when you access our websites (the “Sites”), products, services, mobile applications (the “Apps”), when you place an order using our Sites or Apps, when you visit a physical location owned or operated by us, such as a parking or kitchens facility (together, the “Services”). The nature of our business requires that we gather and maintain information of a personal nature that you may wish to keep protected. When you access or use the Services, we collect information that identifies, relates to, describes, and is reasonably capable of being associated with a particular consumer, household, or device (“Personal Information”).
This Privacy Policy (“Policy”) describes our policies and practices regarding the collection, use and disclosure of Personal Information you submit or we obtain in connection with your use of our Services. Please read this Policy carefully before using any of our Services or submitting information to us. By using the Services, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this Policy.
If you do not want your information to be collected, used, and shared as described in this Policy, please do not use our Services or provide us with such information. If you are located in the United Kingdom, you may have additional rights. Please see our UK section below for more information.
Changes to this Policy
We reserve the right to change this Policy at any time. In the event we make material change(s) to the Policy, changes will be effective immediately upon posting to our Sites and/or Apps and will apply to your use of our Services after the “Last Updated” date listed above. You understand that your continued use of our Services after the Last Updated date, means that the collection, use, and sharing of your information is subject to the updated Policy.
Except to the extent we obtain your consent or as permitted or required by applicable law, we will handle your Personal Information collected through our Services in accordance with the terms of the Policy in effect at the time of such collection.
Information We Collect
As you are probably aware, we may collect information from a variety of sources to operate our Services, carry out our business, comply with law and other purposes described herein.
Information You May Provide. When you use our Services (such as registering an account with us, placing an order using our Services or using our Apps) or otherwise correspond with us, we collect Personal Information you provide to us. Personal Information collected in this manner includes your name, postal address, zip code, email address, telephone or mobile number, user name and password, room or table number, your order details and payment information; it may also include the make, model, and color of your car, your license plate number, driver’s license and other government-issued identification documentation.
To subscribe to newsletters, e-blasts, e-news, respond to surveys, contact us or to request information, we may ask you to provide your name, email address, postal address, organization, or affiliation. If you respond to a job posting or apply for employment with us, we collect Personal Information you provide in your application, resume, or other communications.
Information From Third Parties. We may receive Personal Information from other sources. For example, if you connect your social media account(s) to your account with us, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We have no responsibility for and are not liable for the data collection and use practices of those social media sites.
Information Collected Through Automated Technologies. We and our Service Providers also collect Personal Information and other data through automated data collection technologies, such as cookies or pixel tags. This information tells us about how people use our Services so that we can analyze their effectiveness and provide you with a better web or app experience. We collect and use this information through a variety of technologies, as discussed below.
1. Statistical Data
To monitor use of our Services and improve their quality, certain information is gathered automatically and stored in log files. This information includes:
2. Cookies and Other Tracking Technologies
We may use technologies such as cookies, pixel tags, and browser analysis tools, to recognize you when you return to our Sites and to help us improve the quality of our service when you visit our Sites. We may also use cookies and related technologies to tailor our products and services to suit your personal interests, estimate our audience size, track visits to our Sites and, as applicable, to process your requests.
A cookie contains a unique alphanumeric identifier that websites use to help identify unique visitors to our Sites, whether or not those visitors are repeat visitors, and the source of the visits. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Please note that certain features of our Sites may not be available once cookies have been disabled. Please refer to the Help feature of your browser for information on disabling cookies.
We may also use pixel tags (also called web beacons or clear GIFs), which are tiny invisible graphic images, in the Sites. Pixel tags may be used by us to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We may also collect location information, which may include precise location information when you permit our Services to access your device location.
Some of our email or text communications to you may contain a “click-through URL,” which links to content on our Sites. When you click one of these URLs, it passes information through our web server before you arrive at the destination web page. We track this click- through data to help determine interest in particular products and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails or texts you receive from us.
3. Third Party Analytics
We use applications supplied by third parties, such as Google Analytics, to evaluate usage of our Sites and Apps. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our user experience. These devices and applications may use cookies, tracking pixels and other tracking technologies to perform their services. The analytics service providers may transfer information they collect or receive to third parties in case of a legal obligation or if a third party processes data on behalf of that service provider. 4. Do Not Track “Do Not Track” is a draft standard developed by the World Wide Web Consortium designed to allow you to set your internet search browser to send a signal to a website that you do not want the website operator to track certain browsing information about you. As this Do Not Track is still a draft standard, our Sites and Apps are not configured to respond to Do Not Track requests. In the 12 months preceding the Last Updated date of this Policy, we have collected the following categories of Personal Information from consumers: CATEGORY EXAMPLE Identifiers Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Commercial Information. Internet or other similar network activity. Geolocation data. Sensory data. Inferences drawn from other Personal Information. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, vehicle license plate, account name. A name, address, telephone or mobile number, bank account number, credit card number, debit card number, education, employment. Some Personal Information included in this category may overlap with other categories. Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Physical location or movements. Audio, electronic, visual, thermal, or similar information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
How We Share Your Data
We will not disclose your Personal Information we collect through our Services except as described in this Policy. We may disclose your data for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non- affiliated entities, as we deem necessary to carry out those purposes. We do not sell or share your Personal Information to third parties for purposes of cross-contextual behavioral advertising.
° To manage the Sites or the Apps;
° To provide you with products or services
° To manage our relationship with our partners where we provide our services to you;
° To provide you with offers or opportunities;
° To manage your relationship with our partners who you have an ongoing relationship with (for example, your employer who provides you with a parking benefit or privilege);
° To engage in fundraising related activities;
° To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies;
° To protect our interests and legal rights, such as by responding to subpoenas or defending or prosecuting legal claims; and
° To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data
° Fulfill our obligations under relevant law or contract;
° Investigate, prevent, or take action regarding suspected or actual illegal activities, security incidents, or to assist law enforcement agencies;
° Protect the security or integrity of the Site or the Apps;
° Investigate, prevent, or take action regarding suspected or actual illegal activities, security incidents, or to assist law enforcement agencies;
° Protect the security or integrity of the Sites or the Apps;
° Investigate, prosecute, or defend ourselves in connection with any allegations or claims; or
° Protect our rights and the rights and safety of others.
Safeguarding of Information
We take a number of steps to safeguard the security of Personal Information obtained through our Services. For example, we maintain administrative, technical and physical controls to reasonably safeguard data from unlawful use, unauthorized access or disclosure. Individuals who have access to confidential and otherwise nonpublic data are required to maintain the confidentiality of such information. However, no system for safeguarding personal or other information is 100% secure and even though we have taken steps to protect your Personal Information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with the collection, use, and sharing of Personal Information.
Links to Third Parties’ Sites
We may provide links to websites or resources outside of our Sites or Apps for your informational purposes only. You acknowledge and agree we are not responsible for the availability of such sites or resources, and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through or provided by such sites or resources. We are not responsible for the privacy or other practices of such sites and cannot guarantee the security of any Personal Information that you provide or may be collected by such sites. We encourage you to review the privacy policies and terms and conditions on all linked sites before you provide any Personal Information or complete any transactions with such third parties.
Information of Minors
The Services are not directed to children as the products and services we offer through the Sites or the Apps are intended for persons 18 years of age and older. The Company does not knowingly collect, use or disclose any Personal Information from children. If you are under 18, do not use our Services and do not provide your information to us.
Our Commitment to Data Security
We have taken certain physical, administrative, and technical steps to help protect the information we collect from unauthorized access, use or disclosure. While we make every effort to help ensure the integrity and security of our networks and systems, remember that no method of transmission over the Internet or method of electronic storage is 100% secure.
UK Residents.
If you are located in the United Kingdom, the following section applies. REEF Global Inc. is the data controller in respect of your Personal Information. You have various rights in connection with our processing of your Personal Information, each of which is explained below.
You will not have to pay a fee to exercise any of your rights, except that we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We try to respond to all valid requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Note that the rights outlined above only extend to Personal Information. You can exercise any of your rights above by contacting us at [email protected].
For your own privacy and security, in our discretion we may require you to prove your identity before providing the requested information. Complaints.
If you would like to lodge a complaint about how we have processed your Personal Information, you can contact the Information Commissioner’s Office at:
Failure to provide Personal Information. Where we are required by law to collect your Personal Information, or we need to collect your Personal Information under the terms of a contract we have with you, and you fail to provide that Personal Information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the Personal Information we need in order to provide the product or services you or any of our Service Providers have requested from us. In this case, we may have to cancel the provision of the relevant product or services to you, in which case we will notify you.
Transfers. We only transfer Personal Information in accordance with the requirements of the UK GDPR, including entering into the approved UK International Data Transfer Agreement where required for transfers to third countries not recognised in the UK as providing an adequate level of data protection.
Submission of Requests for Information or Requests to Delete. To submit a request for information or a request to delete, you may:
Fill out the Privacy Webform
To protect your privacy and security, we will also take reasonable steps to verify your identity before providing your Personal Information and before deleting your information. Only you or someone legally authorized to act on your behalf may make a verifiable request related to your Personal Information. If you want to authorize someone else to make a request on your behalf, please contact us at [email protected].
Responses to Requests. We do not charge a fee to respond to your request unless it is manifestly unfounded or excessive. We will respond to your request within one month of its receipt. If we need more time to fulfill your request, we will inform you of the reason in writing or via email and we may take up to an additional two months to complete fulfilling your request.
Retention
We retain your Personal Information only for the period of time needed to fulfill the purposes stated in this Policy or as required by applicable legal, regulatory, or operational needs.
Notice to Site Users Located Outside the United States
When you access our Sites or Apps from outside the United States, we may transfer the Personal Information that we collect from you to a location outside of your jurisdiction, including to the United States. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using our Services, you acknowledge that these laws may provide a different standard of protection and you understand your Personal Information will be transferred to other jurisdictions, including to the United States.
Your Choices Regarding Your Personal Information
You can always limit the information you directly provide to us, but if you choose not to provide certain requested information, you may be unable to access some of our Services, including functionality and content on the Sites and the Apps. You can also limit the communications that we may send you by following a simple opt-out or unsubscribe process. Simply follow the instructions in our email, newsletter or other communications to opt-out of receiving, or unsubscribe from, future communications.
How to Contact Us
If you have any questions regarding this Policy, your privacy, or our policies, you may contact us at: [email protected]
