Privacy Policy

This Privacy Policy of Reflexion Interactive Technologies, Inc. ( “Reflexion”) applies to the Reflexion website located at https://reflexion.co/ and the Reflexion Store (collectively, the ”Website”); the software applications we make available for download (“Software Apps”); Reflexion products (“Reflexion Products”) and our data services available through the internet made available to users of Reflexion Products or Software Apps that provide and permit the access, collection, storage, processing, analysis and/or transmission of data generated by a Reflexion Product or Software App (“Data Services”); as well as any email or other messages that we send to you that link or refer to this Privacy Policy (collectively, including the Website, the Software Apps, the Reflexion Products, the Data Services, and the messages we send to you, the “Products and Services”).

We refer to each user of our Products and Services, and any parent or guardian acting on behalf of such user, as “you” or as a “User.” We also refer to any company on whose behalf a User is using Reflexion Products or Services as “you” or a “User.” This Privacy Policy is subject to the applicable Reflexion Terms of Service (https://reflexion.co/terms-of-service/), and if there is a conflict between this Privacy Policy and the Reflexion Terms of Service, the terms of this Privacy Policy will control. By accessing or using the Reflexion Products and Service, you agree with the terms of this Privacy Policy.

If you are in the European Economic Area, the United Kingdom, or Switzerland, the sections “Legal Bases for Processing,” “Your Privacy Rights,” “International Data Transfers,” and “Our EU and UK Representative” below apply to you.

Personal Information We Collect and Receive.

We collect and receive the following categories of personal information about you:

“Registration and Ordering Information” is information you or another User who subscribes to Reflexion Products and Services or makes the Reflexion Products and Services available to you provides in connection with the Reflexion Products or Services. This information may include your name, address, telephone number, email address, and date of birth; your sport, position, team, school, and institution; information regarding payment and payment accounts; information regarding your Designated Recipients; and information regarding use of Reflexion Products and Services;
“Feedback Information” is response, reaction, recommendation, review, suggestion, and input information you submit to us in connection with your access to or use of Reflexion Products and Services, including the metadata relating to that information;
“Data Services Information” is information we receive and transmit through our Products and Services, including any of the data generated or used by Reflexion Products and Services or otherwise available to us through Reflexion Products and Services, such as data used for technical support. This may include your height, weight, athletic performance data, training data, training frequency, goals, and personal bests; and, when you use Reflexion Breathe, audio recordings and motion data from your device, used to estimate your breathing. Some of this information may constitute health information that is sensitive personal information;
Information provided by you or about you by another person you have designated to receive any of your personal information through functionality of a Reflexion Product or Service (we call each such person a “Designated Recipient”);
Information from a third party data service that you authorize to be provided to us, either through that third party data service or through an option we make available to you through our Data Services (we call each such third party data service which you authorize to provide information to us, or to which you authorize us to provide your information a “Designated Third Party Service”);
“Store Subscription Information” is information we receive from an application store or platform through which you purchase or subscribe to a Software App, rather than from you directly. If you subscribe through the Meta Horizon Store, we receive from Meta an identifier for your Meta account and the status of your subscription, in order to activate and maintain your Reflexion subscription. We do not receive your payment card or other payment credentials from Meta. We use the Meta account identifier only in the Meta Quest version of the Software App, where it is stored as an opaque identifier on your Reflexion account; we do not transmit it to the Reflexion iPad, web, or Reflexion Edge applications, and we do not disclose it to any third party. It is deleted when your Reflexion account is deleted;
Information we receive automatically from the computer, mobile phone or other device you use in connection with Reflexion Products and Services, and information we receive from those Products and Services regarding your use, which may include your IP address and other information regarding your computer, your internet service, the browser you use, and your activities while using Reflexion Products and Services (collectively, “Use Information”);
Information we receive from you in connection with our request for comments or feedback;
Physical characteristics or descriptions, such as if you provide us with photographs, audio, or video of you;
Information about your geolocation, such as your physical location based on IP address, device data, or region;
Information we may receive from advertisers and other third parties, including information about the pages you visit, your activity, and your transactions when you click on advertisements or links to third party websites while using Reflexion Products and Services; and
“Derived Information” is information that we create by combining and/or analyzing some or all of your personal information.

Please note that “personal information” for the purposes of this Privacy Policy does not include aggregate information or information from which individual identities have been removed.

Cookies and Other Technologies.

Cookies: Please see our Cookie Policy for information about our use of cookies and other tracking technologies (collectively, “cookies”) with respect to your access to and use of our Products and Services.
Cookie choices: You can change your choice regarding non-essential cookies at any time via Cookie preferences in the page footer.
Analytics: We may use third-party analytics, such as Google Analytics, in connection with the Products and Services. Such third-party services may use cookies and similar technologies to collect and analyze information about use of the Products and Services and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online services.
Marketing: We may use cookies in connection with some of our Products and Services to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns, and compile statistics about use and response rates.
Interest Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Products and Services and other websites or online services, based on information relating to your access to and use of the Products and Services and other websites and services. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). You can withdraw consent at any time via Cookie preferences in the site footer or the Privacy & Data screen.

Your Responsibilities Regarding Submitting Personal Information.

You agree to keep your Registration and Ordering Information current at all times while your account is active.
If you submit any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Use the Personal Information We Receive.

We may use the personal information we collect or receive for the following purposes:

to deliver the Reflexion Products and Services,
to provide and manage your User account and Reflexion Products and Services applicable to you,
to authenticate you and authorize access to Reflexion Products and Services,
to contact you regarding your account,
to provide customer service and support services,
to process your financial transactions,
to activate and maintain a subscription you purchase through an application store or platform, such as the Meta Horizon Store,
to link your use of Reflexion Services and Software Apps with your use of Reflexion Products,
for advertising, marketing, and other communications with you, third parties, or the public,
for analysis, development, and improvement of the Reflexion Products and Services,
for our operations, administration, maintenance and support,
to detect security incidents and to verify your identity;
to protect against, detect, and investigate fraud;
to tailor to you and your Designated Recipients, if applicable, the experience when using Reflexion Products or Services and the content viewed when using Reflexion Products or Services,
to improve our business and provide new website and product and service features, and to otherwise manage our business,
to conduct research and development for the further development of our Products and Services, including in order to provide you and others with a better experience, drive User growth and engagement on our Products and Services,
to investigate, respond to and resolve complaints and Product and Service issues (e.g., bugs),
to evaluate or conduct a corporate sale, merger, acquisition or dissolution involving Reflexion;
for security purposes, to protect our or other’s rights and property, or to investigate possible fraud or other violations of our Terms of Service or this Privacy Policy and/or attempts to harm us, our Users, or third parties, and
for purposes other than those disclosed in this Privacy Policy but only after you consent to such use.

How We Disclose your Personal Information.

We may disclose the personal information we collect or receive as described below:

Service Providers: In the ordinary course of our business, we use service providers to perform services or functions on our behalf, such as data storage vendors, cloud hosting providers, customer support providers, marketing and analytics providers, technical infrastructure providers, and payment processors. We will not authorize those service providers to keep, use or disclose your personal information except for providing the services we have asked them to provide. A current list of our sub-processors is published at reflexion.co/data-processing-agreement.
Application Stores and Platforms: Where you purchase or subscribe to a Software App through an application store or platform, that store provides us with the limited information we need to establish and maintain your subscription, as described under “Store Subscription Information” above. For subscriptions purchased through the Meta Horizon Store, Meta collects your payment: no payment is collected by us or by our billing provider for those purchases, and we record the Meta subscription identifier in our billing and accounting system, for record-keeping and accounting purposes. We do not disclose your Meta account identifier to any third party, and we do not use it for advertising or marketing.
Business Partners: We may disclose personal information to our business partners or allow them to collect your personal information to offer you certain products, services, or promotions or to evaluate or improve our or their products, services, or marketing. Please note that we do not knowingly disclose the personal information of minors to business partners. Where an organization — such as a club, school, university, federation, or research institution — enrolls its athletes, screening participants, or other end users under its own account, we process those members’ personal information on that organization’s behalf as a processor: we do not disclose those members to advertising platforms and do not use their personal information for our own advertising, except on the basis of an adult member’s own direct, opt-in consent given to Reflexion. Minors are always excluded.
For a Change in Control: We may provide your personal information to third parties in conjunction with a corporate sale, merger, acquisition or dissolution involving Reflexion.
Law Enforcement and Legal Proceedings: We will use and disclose personal information as we are required to do by applicable law, including laws outside your country of residence, and may disclose personal information when requested by law enforcement authorities or regulatory agencies, or when we determine that such disclosure is appropriate under the circumstances; in each case in accordance with applicable data protection laws. We may use and disclose personal information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy or our Terms of Service; and to allow us to pursue available remedies or limit the damages that we may sustain; in each case in accordance with applicable data protection laws.

What Happens to Personal Information You Share With Others.

You may choose to share your personal information with Designated Recipients, including through the Reflexion Products and Services. Reflexion has no control over Designated Recipients, and once a Designated Recipient receives your personal information, use by the Designated Recipient is between you and the Designated Recipient. We do not verify the contact information you provide for each Designated Recipient. Once you provide such contact information, until you terminate the designation, we may facilitate your request to send personal information to the contact information you have provided, and you are responsible for the accuracy of that information.
Your Designated Recipients may share your personal information with Reflexion, and we will process such personal information of yours in accordance with this Privacy Policy.
Once you share or direct Reflexion to share your personal information with a third party, including Designated Third Party Services, Reflexion has no control over that personal information and how it is used by any such third party. You should refer to the terms of service, privacy policy and other provisions of the websites for each third party to whom you provide any personal information yourself, and for any Designated Third Party Service you authorize.

Children’s Privacy.

Our Products and Services are intended for a general audience and are not directed toward children under the age of 13. In the European Economic Area and Switzerland the digital-consent age is 16 unless national law sets a lower age; in the United Kingdom, Portugal, and the United States it is 13. Reflexion accounts can only be created and paid for by an adult account owner. We do not knowingly collect personal information from children under the age of 13 without express consent from a parent or legal guardian. The adult account owner enrolls a minor by adding them to their own account, providing the minor’s birth date and certifying that they are the minor’s parent or legal guardian. Notices about the account go to the adult account owner’s email address, and the adult account owner can review the minor’s personal information, download it, or have it deleted at any time from the account or by contacting [email protected].

Reflexion does not sell personal information from minors to third parties, does not use personal information from minors for marketing, and does not share personal information from known minors with third parties for advertising purposes. Reflexion otherwise collects, uses, and discloses personal information from minors as described above in this Privacy Policy.

Legal Bases for Processing (EEA, UK, and Switzerland only).

Where the GDPR or UK GDPR applies, we process personal information on the following legal bases:

Performance of a contract: creating and managing your account; providing services and products, providing training drills, scores, and other assessment and performance information; processing subscriptions and payments, including activating and maintaining a subscription you purchase through an application store or platform such as the Meta Horizon Store; and facilitating functionality of our products and services.
Consent: non-essential advertising cookies, leaderboard participation for athletes (if given by the parent or guardian for minor athletes), and your explicit consent to our processing of sensitive personal information, including any data concerning health within the meaning of Article 9 GDPR (we obtain this explicit consent at onboarding, or from the holder of parental responsibility for minor athletes); you can withdraw any consent at any time, without affecting prior processing.
Legitimate interests: providing customer support, securing our services, preventing fraud and abuse, improving our products and services, communicating with you about services, programs, accounts, direct marketing, and sending you personalized information. Please note that the personal information of minors is not used for marketing.
Legal obligation: retaining and processing certain information to comply with legal obligations, such as invoices and tax records and honoring data-protection requests.

Your Privacy Rights (EEA, UK, and Switzerland only).

Subject to applicable law, you have the right to access your personal information and receive a portable, machine-readable copy; to correct inaccurate personal information; to have your personal information deleted; to restrict or object to certain processing (including direct marketing, which we will always honor); and to withdraw consent at any time. The Privacy & Data screen in the Reflexion GO app provides these tools directly: review and change choices, download your data, and permanently delete your account. You or your authorized agent can also email [email protected]; we respond within one month. EEA/UK residents also have the right to lodge a complaint with your local supervisory authority and may contact our representative as described below.

International Data Transfers (EEA, UK, and Switzerland only).

Our services are hosted in the United States. Where personal information of EEA, UK, or Swiss residents is transferred outside the EEA, UK, or Switzerland, we rely on the European Commission’s Standard Contractual Clauses (and the UK International Data Transfer Addendum and Swiss equivalent) together with appropriate technical and organizational safeguards.

Our EU and UK Representative (EEA, UK, and Switzerland only).

We have appointed iuro Rechtsanwälte GmbH, trading as Prighter, Schellinggasse 3, 1010 Vienna, Austria, as our representative in the European Union pursuant to Article 27 GDPR, and Prighter Ltd, 20 Mortlake High Street, London SW14 8JN, United Kingdom, as our representative in the United Kingdom pursuant to Article 27 UK GDPR. You can contact either representative or submit a privacy request through our Prighter portal: https://app.prighter.com/portal/reflexion

Email Marketing Communications.

We give you the ability to opt-out of the email marketing communications we may send. You can opt-out of receiving marketing emails by selecting the “unsubscribe” link at the end of our communications to you. Please note that even after you opt out, you will continue to receive certain required informational communications, such as messages confirming orders and notifying you of order status.

Retention.

We will retain your personal information for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your personal information for as long as you are a customer of ours so that we may process and complete any orders you may make with us. We may also be required to hold some types of personal information to fulfill legal purposes. When the relevant processing activity has been completed, we may destroy your personal information, or alternatively anonymize the data, such that the data is not personally identifiable.

Security.

Reflexion uses commercially reasonable standards of technology and operational security to protect personal information within our organization. Personal information transmitted through Reflexion Products and Services is transmitted in encrypted form. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section, below. In addition, the safety and security of your personal information also depends on you. Where you have chosen, or where we have given you a user name and password for access to certain parts of the Reflexion Products or Services, you are responsible for keeping the user name and password confidential.

Links to Third-Party Sites.

Reflexion Products and Services may contain links to third-party websites, applications or other items. We assume no responsibility for the information practices of those third-party websites, applications or other items, and the inclusion of a link does not imply our endorsement of the linked site or service. In addition, this Privacy Policy does not apply to the privacy, information, or other practices of any third parties, including any third party operating any site or service to which our Products or Services link. We encourage you to review each third-party’s privacy policy before disclosing any personal information to any third party or using its products or services.

Contact Us.

If you have any questions about this Privacy Policy, please: (1) send us an email at [email protected]; or (2) write to us (and include your email address) at the following address:

Reflexion Interactive Technologies INC

ATTN.: Privacy Officer

355 E Liberty Street, Suite 300

Lancaster, PA 17602

Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.

Updates to the Privacy Policy.

This Privacy Policy was last updated on August 4, 2026.

We may change this Privacy Policy by posting a new version of this Privacy Policy at https://reflexion.co/privacy-policy. Any changes will become effective when we post the updated Privacy Policy on our Website, and your use of our Products and Services following these changes means that you accept the updated Privacy Policy. If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further personal information.