Introduction

Reflection Sciences, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

• The types of information we may collect or that you may provide when you use the MEFS App™ (the “App”).
• Our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies only to information we collect in this App and in e-mail, text, and other electronic communications sent in connection with this App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. Unless explicitly agreed otherwise in a signed writing, this policy applies to you. If you do not agree with our policies and practices, do not download, register with or use this App. By downloading, registering with or using this App, you agree to this privacy policy (except to the extent we have agreed otherwise in a signed writing). This policy may change from time to time (see www.reflectionsciences.com). Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Parental Consent

The App is intended for children ages 2 and up. Some organizations may require Parental/legal guardian consent before the MEFs App™ is administered to children. That is an organizational decision, and not a policy of Reflection Sciences, Inc. The MEFS App™ is most often an assessment that is used in the normal course of school instruction and evaluation.

Information We Collect and How We Collect It

We collect information from and about users of our App:

• Directly from you when you provide it to us.
• Automatically when you use the App.

We will never sell your information.

When you download, register with or use this App, we may ask you provide information:

• By which a user may be personally identified, such as child’s first and last name, parent or teacher’s first and last name, or any combination of information that makes the individual’s identity easily traceable (“personal information”).
• That is about a user but individually does not identify the user, such as sex, ethnicity, month of birth, postal code and whether the child is receiving special education services.

This information includes:

• Information that you provide by filling in forms in the App. This includes information provided at the time of registering an individual to use the App.
• We may also ask you for information when you report a problem with the App.
• Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.

Automatic Information Collection.

When you download, access and use the App, it may use technology to automatically collect:

• Usage Details.
• When you access and use the App, we may automatically collect certain details of your access to and use of the App, including time of day and total test time.

Stored Information and Files.

The App does not access metadata and other information associated with other files stored on your device. 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the App and its contents, and any other information, products or services that you request from us.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

• Refine and improve our service.
• Norm the assessment tool (providing age and sex-standardized scores and percentiles for users).
• Disclose Your Information – we may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect and/or you provide:

• To contractors, service providers and other third parties we use to support our website, the App and our online services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Reflection Science’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Reflection Sciences, Inc. about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, to report the results of an individual assessment.
• For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Reflection Sciences, Inc., our customers or others and to the extent permitted by law.

Linking to Outside Webpages

Our website may contain links that enable you to visit other websites of interest. Once you have used these links to leave our site, note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide while visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Your Choices about Our Collection, Use and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. The following sections describe mechanisms we provide for you to control certain uses and disclosures of  your information.

Tracking Technologies & Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added via a cookie and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

Parental Rights

By contacting us using the contact information included below, the parent or legal guardian of a child under the age of 13 can review or have deleted their child’s personal information in our possession and may refuse to permit further collection or use of the child’s personal information. We reserve the right to terminate services provided and access to the App for any child whose parent has refused to permit our further use or collection of personal information established in this policy. 

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

De-identification of Personally Identifiable Information

Upon expiration of a subscription period or otherwise specified in a user license agreement, Reflection Sciences will permanently erase all user names associated with your organization’s account (if any). Only the user data (test results), age in months at the time of testing, sex, ethnicity, and postal code will be retained for the purposes specified above.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on our Privacy Policy page at www.reflectionsciences.com/privacy-policy.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address and/or phone number for you and for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Vice President of Technology

E-mail: support@reflectionsciences.com

Last modified: August 15, 2022