Reflective Customer Solutions (“RCS,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information entrusted to us.
This Privacy Policy explains how Reflective Customer Solutions collects, uses, stores, protects, and discloses information when you visit our website or landing pages, submit an inquiry, communicate with us, or otherwise interact with us regarding our services.
For purposes of this Privacy Policy, “personal information” means information about an identifiable individual, subject to applicable privacy legislation.
About Reflective Customer Solutions
Reflective Customer Solutions provides outsourced administrative, operational, customer support, and process support services to businesses, including Canadian Licensed Insolvency Trustee (“LIT”) practices and other professional organizations.
Our services may include administrative support relating to insolvency workflows, document processing, Proof of Claim administration, case setup and data entry, proposal and bankruptcy administrative support, creditor administration, debtor administrative support, quality control, reporting, and other related back-office functions.
RCS does not provide Licensed Insolvency Trustee services through this website or landing page, and submitting an inquiry through our website does not create a professional, trustee, fiduciary, or client relationship.
Information We Collect
We generally collect information directly from you when you voluntarily provide it to us.
For example, we may collect information when you:
- Submit an inquiry or contact form;
- Request information about our services;
- Communicate with us by telephone, email, video conference, social media, or other electronic means;
- Meet with our representatives;
- Respond to our business development communications; or
- Otherwise engage with RCS regarding a potential or existing business relationship.
Information collected through our website or landing pages may include:
- Firm or company name;
- Contact person’s name;
- Business email address;
- Telephone number;
- Best time to contact you;
- Job title or professional role, where provided;
- Information contained within correspondence or communications with us; and
- Any additional information you voluntarily provide.
Our landing pages are intended primarily for business-to-business inquiries. We do not request sensitive personal financial information through our general inquiry forms.
Please do not submit Social Insurance Numbers, banking information, credit card information, debtor files, tax records, passwords, medical information, or other sensitive or confidential client information through a general website inquiry form unless specifically requested through an authorized and secure RCS process.
How We Use Your Information
We may use information collected through our website, landing pages, or communications for purposes including:
- Responding to your inquiry;
- Contacting you regarding RCS services;
- Providing information requested by you;
- Understanding your firm’s operational or administrative requirements;
- Assessing whether RCS services may be suitable for your organization;
- Arranging meetings, demonstrations, consultations, or follow-up discussions;
- Preparing proposals or service information;
- Establishing and managing business relationships;
- Providing and improving our services;
- Operating and improving our website and landing pages;
- Maintaining appropriate business and communication records;
- Conducting internal reporting, analytics, quality assurance, and business planning;
- Protecting against fraud, misuse, security threats, or unauthorized activity;
- Complying with contractual, regulatory, and legal obligations; and
- Carrying out other purposes to which you have consented or that are otherwise permitted or required by applicable law.
Submitting an inquiry authorizes RCS to contact you using the contact information you provide for purposes reasonably related to your inquiry.
Consent
Where required by applicable law, RCS obtains consent before collecting, using, or disclosing personal information.
Consent may be express or implied depending upon the nature and sensitivity of the information, the circumstances in which it is collected, and applicable legal requirements.
You may withdraw your consent to certain uses of your information, subject to contractual, legal, regulatory, or operational restrictions and reasonable notice.
Withdrawal of consent may affect our ability to provide certain services or respond to certain requests.
Business Communications and Marketing
If you request information from RCS, submit an inquiry, or otherwise establish a business relationship with us, we may communicate with you regarding your inquiry and our related services.
Where required by applicable Canadian anti-spam legislation or other applicable laws, we will obtain the appropriate consent before sending commercial electronic messages.
You may unsubscribe from marketing communications at any time by using the unsubscribe mechanism contained in the communication or by contacting us.
Unsubscribing from marketing communications will not prevent RCS from sending communications that are necessary for an existing business relationship, contractual matter, service request, security matter, or other non-marketing purpose permitted by law.
Disclosure of Information
RCS does not sell or rent your personal information.
We may disclose information to employees, contractors, affiliates, professional advisors, and service providers where access is reasonably necessary to operate our business, provide our services, maintain our technology, communicate with you, or fulfil our contractual and legal obligations.
These service providers may include providers of:
- Website hosting and infrastructure;
- Customer relationship management systems;
- Email and communication services;
- Cloud computing and data storage;
- Analytics and website measurement;
- Cybersecurity and information technology services; and
- Other business systems used by RCS.
Where appropriate, RCS uses contractual, technical, organizational, or other safeguards designed to require service providers and personnel to appropriately protect information entrusted to them.
We may also disclose information where reasonably necessary:
- To comply with applicable laws, regulations, court orders, subpoenas, or lawful requests from governmental authorities;
- To investigate suspected fraud, misuse, security incidents, or unlawful activity;
- To establish, exercise, or defend legal rights;
- To enforce contractual obligations;
- In connection with a proposed or completed merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction; or
- Where otherwise permitted or required by applicable law.
Information Processed on Behalf of Clients
Where RCS provides outsourced administrative or operational services to a client organization, RCS may process information on behalf of that organization pursuant to contractual arrangements and the client’s instructions.
In those circumstances, the client organization generally determines why the information is collected and how it is used, while RCS acts as a service provider processing information for authorized business purposes.
RCS personnel are expected to access client information only to the extent required to perform authorized services.
This website Privacy Policy is primarily concerned with information collected directly through RCS websites, landing pages, business development activities, and communications. Information processed by RCS on behalf of an existing client may also be governed by contractual confidentiality, privacy, security, and data-processing requirements agreed upon with that client.
International Access and Transfer of Information
RCS operates internationally and provides services to organizations in Canada.
Depending on the services being provided and the technology systems involved, personal information may be stored, processed, transferred, or accessed in Canada, India, the United States, or other jurisdictions in which RCS or its authorized service providers operate.
As a result, information may be subject to the laws of the jurisdiction in which it is stored or accessed and may be accessible to courts, law enforcement agencies, regulatory authorities, or national security authorities where permitted by applicable law.
RCS uses reasonable contractual, administrative, organizational, and technical safeguards designed to protect information that is transferred or accessed across borders.
Organizations considering RCS for outsourced services may contact us for further information regarding our operational, privacy, confidentiality, and information-security practices.
Cookies, Analytics and Website Information
When you visit our website or landing pages, certain technical information may be collected automatically.
This may include:
- Internet Protocol (IP) address;
- Browser and device information;
- Operating system;
- Approximate geographic location;
- Pages viewed;
- Time spent on pages;
- Referring website or advertisement;
- Interactions with website content;
- Form and conversion activity; and
- Other website usage information.
We may use cookies, pixels, tags, scripts, and similar technologies to operate our website, understand website usage, measure advertising performance, improve user experience, prevent fraud, and evaluate the effectiveness of our marketing activities.
We may use third-party analytics, advertising, customer relationship management, and measurement providers for these purposes.
Depending upon your browser and applicable laws, you may be able to restrict or disable cookies through your browser settings or available consent controls. Disabling certain cookies may affect the functionality of parts of our website.
Advertising and Landing Pages
RCS may operate advertising campaigns through online platforms, including professional networking platforms, search engines, and social media platforms.
If you arrive at an RCS landing page through an advertisement, the advertising platform and RCS may receive information regarding the interaction with the advertisement, such as whether an advertisement was viewed or clicked and whether certain website actions occurred.
RCS may use this information to measure campaign performance, understand the effectiveness of our advertising, and improve our business development activities.
RCS does not intend to use its business-development landing pages to collect sensitive debtor or consumer financial information.
Information Security
RCS takes reasonable administrative, technical, organizational, and physical measures designed to protect information against unauthorized access, disclosure, alteration, misuse, loss, or destruction.
These measures may include access controls, authentication measures, technology safeguards, confidentiality obligations, security procedures, staff training, and restrictions on access based upon business requirements.
Access to personal or confidential information is intended to be limited to individuals who reasonably require access for legitimate business purposes.
However, no electronic transmission or information-storage system can be guaranteed to be completely secure. Accordingly, RCS cannot guarantee absolute security of information transmitted electronically.
Data Retention
RCS retains personal information only for as long as reasonably necessary to fulfil the purposes for which it was collected and to meet legitimate business, contractual, regulatory, security, and legal requirements.
Retention periods may vary depending upon the nature of the information and our relationship with you or your organization.
When information is no longer reasonably required, RCS may securely delete, destroy, or anonymize it, subject to applicable legal and contractual requirements.
Your Privacy Rights
Depending upon the jurisdiction and applicable privacy laws, you may have rights concerning your personal information, including the right to:
- Request access to personal information held about you;
- Request correction of inaccurate or incomplete information;
- Withdraw consent where processing is based upon consent, subject to legal and contractual restrictions;
- Ask questions about how your information has been collected, used, or disclosed; and
- Request deletion of certain information where applicable and legally permitted.
Before fulfilling a privacy request, RCS may take reasonable steps to verify the identity and authority of the individual making the request.
Certain information may need to be retained notwithstanding a request for deletion where retention is required or permitted for contractual, regulatory, security, dispute-resolution, or legal purposes.
Third-Party Websites
Our website may contain links to third-party websites, platforms, or services.
RCS is not responsible for the privacy, security, content, or practices of third-party websites. We encourage users to review the privacy policies of those organizations before providing them with personal information.
Children’s Privacy
RCS’s business services and this website are intended for businesses and professionals and are not directed toward children.
RCS does not knowingly use its business-development website or landing pages to solicit personal information from children.
Changes to This Privacy Policy
RCS may update this Privacy Policy periodically to reflect changes in our business practices, technology, services, regulatory requirements, or applicable laws.
The revised Privacy Policy will become effective when posted unless otherwise indicated.
The “Last Updated” date at the beginning of this Policy identifies when the Policy was most recently revised.
Contact Us
Questions, concerns, access requests, correction requests, or other inquiries regarding this Privacy Policy or RCS’s handling of personal information may be directed to:
Privacy Officer – Manish Kukreja
Reflective Customer Solutions
Email: info@reflectivecs.com
Address: Office 609 & 610 - 6th Floor, Centrum IT Park, Wagle Estate, Thane West - 400604
Mumbai - State of Maharashtra (India)
When contacting us regarding a privacy request, please provide sufficient information for us to understand and respond to your request. We may request additional information where reasonably necessary to verify your identity.
Complaints
If you believe RCS has not appropriately addressed a privacy concern, you may contact the applicable privacy or data-protection authority in your jurisdiction.
For matters governed by Canadian federal privacy legislation, individuals may have the right to contact the Office of the Privacy Commissioner of Canada.
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