Privacy Policy
Last updated: March 03, 2022
This Application Privacy Policy (“Application Privacy Policy”) outlines the information that ReachOut gathers, how we use that information, and the options you have to access, correct, or delete such information when you use the ReachOut Application(s). As used in this Application Privacy Policy, “ReachOut,” “Us” or “We” refers to ReachOut, Inc. and its affiliates as listed at the end of this policy. Capitalized terms used but not defined herein have the meanings ascribed to them in the Application Terms of Service.
1. Scope of Policy
Our mission to help get more people, who ordinarily cannot afford it, securely online is rooted in the importance we place on establishing trust with the Internet community. To earn and maintain that trust, we commit to communicating transparently, providing security, and protecting the privacy of data on our systems.
This Policy only applies to ReachOut’s collection, use, and disclosure of personal information in connection with the use of the ReachOut Application(s).
2. Information We Collect
We only collect and store the minimum amount of data we believe is required to operate and improve the Application. There are three categories of data that we collect: Account Data, Operational Data, and DNS Resolver Information as described more fully below. Your Account Data and Operational Data are pseudonymized. Your DNS Resolver Information is anonymized at our edge data centres.
We do not collect your name, phone number, or credit card information (or records of any payments collected by the applicable App Store). The only information we receive from the applicable App Store is a limited amount of information that we need to confirm your subscription for a Service. We do not receive from the App Store any of your personal data or other information about your App Store account. We only receive your email address (and name, if you voluntarily provide it) if you have decided to give us feedback and/or report bugs.
We promise to keep your personal information personal and private. We will not sell or rent your personal information to anyone. We will not share or otherwise disclose your personal information except as necessary to provide our services or as otherwise described in this Application Privacy Policy without first providing you with notice and the opportunity to consent.
2.1 Account Data
When you install the Application on your device, create or update your account, sign up for a Paid Application Service, or participate in one of our referral programs, we collect and store the “Account Data” described below, depending on your use of the Application.
Account Data
Information Type | Purpose |
Account | We use account information, such as your account ID, to administer your account and authorize Internet requests from your device to the ReachOut network. |
Subscription | If you subscribe to Paid Application Services, we use subscription information, such as your order ID, to administer those subscriptions. |
Referral | If you participate in our referral programs, we use referral information, such as your registration ID, to credit referrals to you. |
2.2 Operational Data
ReachOut also collects and stores “Operational Data” when you connect to our network. This data is required to operate and improve our Application.
Operational Data
Information Type | Purpose |
Request data (Source IP, Source Port, Destination IP) | When you connect to our network, we see your IP address and use it to assign you a ReachOut IP address corresponding to the country in which you are connecting from. We do not retain a link between the IP address you use to access the Internet via our Application and the websites you visit. |
Performance data | We track the services you have enabled and the amount of data you have transferred via the Application. We also use performance data to understand how the Application impacts your Internet connection and to improve our Application. Performance Data does not include personal information. |
Device data | We use information regarding your device, such as device model and operating system, for troubleshooting and to improve our Application. This data does not include unique device identifiers. |
Crash Logs | We use crash log information regarding your device’s use of the Application for troubleshooting and to improve our Application. Crash logs do not contain your IP addresses or other personal information. |
Connection Data | We retain anonymized network information to look for connection problems between your device and ReachOut’s network. You may disable the reporting of anonymized network information in the Application. |
Feedback/Bug Reports | We require your email address when you provide feedback and bug reports. When you provide feedback, you can choose whether to share your console logs. Console logs can include your device name and IP address. We use this information for troubleshooting and to improve our Application. Your email address will be deleted 6 months from the date of collection. |
2.3 DNS Resolver Information
We collect limited DNS query data that is sent to the ReachOut Private DNS resolver when you have the Application enabled on your device. The DNS query data that we retain does not contain your IP addresses or personal information, and the bulk of the data is only stored for 24 hours.
3. How We Use Information We Collect
ReachOut only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. We use the information we collect, as described in Section 2 to operate and improve the Application, such as to assist us in our debugging efforts if an issue arises. We may also use the information we collect to comply with legal obligations as well as to investigate and prevent violations of the Application Terms of Service.
4. Retention
We store your personal data only as long as is necessary to provide our Application and the associated services, pursue legitimate interests, and comply with applicable laws. Your Account Data and Operational Data will be stored for no longer than two years after your last use of the Application. Information associated with feedback and bug reports may be retained longer as needed.
5. Information Sharing
We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us operate and improve the Application, including assisting with debugging and crash analytics. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Application Privacy Policy, ReachOut’s Privacy Policy and other applicable confidentiality and security measures and regulations.
Specifically, we do not permit our Service Providers to sell any personal information we share with them, or to use any personal information we share with them for their own marketing purposes or for any other purpose than to perform the services they provide to us.
In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:
Within the ReachOut Group (defined for the purposes of this Application Privacy Policy as the ReachOut entities listed at the end of this policy);
When we are required to disclose personal information to respond to subpoenas, court orders, or legal process; or in the case of an emergency to protect any person from the danger of death or serious physical injury; or to establish or exercise our legal rights or defend against legal claims.
In the event of a merger, sale, change in control, or reorganization of all or part of our business;
Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required to comply with our legal obligations; or as you may otherwise consent from time to time.
We do not sell, rent, or share personal information with third parties as defined under the California Consumer Privacy Act of 2018 (California Civil Code Sec. 1798.100 et seq.), nor do we sell, rent, or share personal information with third parties for their direct marketing purposes, including as defined under California Civil Code Sec. 1798.83.
6. Legal Basis for Processing
If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we need your personal information to perform a contract with you (e.g. to deliver the services you have requested), or (b) the processing is in our legitimate interests. In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. We will obtain your consent where required by law. Where we rely on our legitimate interests to process your personal data, you have the right to object. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@reachout.chat.
7. Data Subject Rights and Choices
In the event you elect to contact us to report an issue with the Application, to share feedback or to send console logs, we may receive limited personal data about you, such as your email address, that we retain for a limited period of time. You will have the right to access, correct, update, export, or delete your limited personal information that we retain.
Please keep in mind that except for when you provide feedback, we don’t receive personally identifiable information from you, and we are unable to associate your identity with your Account Data or Operational Data. As a result, our ability to comply with data subject rights is limited to those circumstances in which we have your personally identifiable data.
8. Data Security, Data Integrity and Access
We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us at privacy@reachout.chat .
9. Notification of Changes
If we make changes to this Application Privacy Policy that we believe materially impact the privacy of your personal data, we will promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated Application Privacy Policy on this website noting the effective date of any changes.
10. Business Transactions
We may assign or transfer this Application Privacy Policy, as well as information covered by this Application Privacy Policy, in the event of a merger, sale, change in control, or reorganization of all or part of our business.
11. English Language Controls
Non-English translations of this Application Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.
12. Contact Information
ReachOut, Inc.
251 Little Falls Drive Wilmington, DE 19808, USA
Attention: Data Protection Officer
privacy@reachout.chat
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