Last amended: 20 June 2019

Welcome to Reflect!

Reflect is an online based face swap application that allows you to generate a unique content.

Here at Reflect we are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information to provide the Services only after obtaining your consent to the collection and processing of your personal data on the terms specified below.

This Privacy Policy explains when, where, how and why we collect personal information about you, how we use the information, the conditions under which we may disclose it to others, your rights in respect of your personal information, as well as how we keep it secure.

This Privacy Policy is an integral part of the Reflect Terms and Conditions and applies to all visitors, users, and others who access the Services.


We collect from you the following data:


Reflect collects and uses the information to:

Uploaded Content is collected for their display in the library for the User’s repeated use and convenience of the Application usage. Uploaded Content is stored at the on-line secured data storage and displayed to you exclusively while your usage of the Application. By submitting this content for the swapping you expressly agree for their collection and storage as set forth herein.

If Reflect decides to change the purposes of processing specified above, we will inform you on such changes prior to use your personal information within the newly set purposes.


In order to provide high-quality Services, Reflect hires people, may enter the agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For those reasons some of your personal information may be passed to the persons mentioned. First of all, our employees may have access to your data. Then, we may transfer your data to our sub-contractors and affiliates. Where applicable, we secure such transmission by including standard contractual clauses adopted by the European Commission into our data processing agreements.

Reflect uses only secure places of storage, such as Google Cloud. Google LLC is located in the United States of America and complies with the requirements of the EU-US Privacy Shield. Here is some information on data protection practices of Google LLC. So, this well-known software provider ensures your data is processed in accordance with the strictest data protection standards.

Please note, Reflect is managed by NEOCORTEXT, INC. is registered in Delaware, United States, so your data may be transferred to the company in the United States. Your data may also be accessed by third party providers Reflect engages in other regions.

If you are from the EU, it will be important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation of the contractors from the USA in Privacy Shield Program or on the bases of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws. By using our Services, you agree to such transfer and processing within the purposes set herein.

In all cases we pass the information to other persons we ensure that your information is being protected and used only within the purposes specified in Section 2 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.

You also have to be aware of the fact that Reflect may disclose your personal information to enforce and comply with the law. In other words, Reflect may disclose to officials information necessary for the investigation or legal process on official request or the official bodies acting within their powers.


Data retention. Your personal data will be stored by Reflect no longer than is necessary for the purposes for which the personal data are processed. That is why the Uploaded Content is temporary stored on the Reflect’s server, until you finish the editing session. Uploaded Content is stored for the period that the Reflect Services are provided to you. After the expiration of retention period, Reflect terminates the processing of your personal data or pseudonimize such data, unless other retention period is set by the relevant legislation.

Data security. Reflect processes your data using computers and/or other IT enabled tools. Reflect takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. For example, Reflect uses verified contractors that might have access to the data as specified in Section 2 of the Privacy Policy with which the relevant data processing agreements are signed. We also guide and train our personnel to process your data securely according to our internal data protection policies.


You have a right to access to your personal data processed by Reflect and right to data portability

This means that you can ask Reflect what personal data of yours is processed. You can also ask for the clarifications on the information described above, i.e. purpose of collecting and processing, period of processing, third parties which have access to information. You have a right to request from Reflect your personal data in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller, if the processing is based on your consent or on contract and the processing is carried out by automated means.

You have a right to request from Reflect to rectify your personal data

This means you can require all the inaccurate personal data concerning you being corrected. You can also complete the personal data if you feel there is a need to do so.

You have a right to request Reflect to erase personal data

You can request Reflect to erase personal data if its processing is no longer necessary to achieve purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases, Reflect will erase it unless otherwise required by legislation.

You have a right to restrict the processing of your personal data by Reflect

In some cases, prescribed by law you will be able to restrict the processing of your personal data, for example, if you contest the accuracy of your personal data being processed or in case Reflect is not interested in processing of your personal data any longer, but you want Reflect to do this on different reasons, for example, to bring some claim for somebody and, instead of the erasure of information, its processing will be just restricted.

You have a right to withdraw your consent

You can withdraw your consent for the collection and processing of your personal data by Reflect at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. After we at Reflect receive such withdrawal request from you, we will process it in a timely manner and we will no longer process your personal data, unless otherwise is set by law.

You have a right to object to processing of your personal data by Reflect

In some cases, prescribed by the applicable laws you can object to processing of your personal data.

You have a right to object to processing of your personal data when the processing is related to the performance of our task carried in the public interest or in the exercise of official authority vested in us; or we process your data to pursue our or third party’s legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms.

If you make a request objecting to processing, we will no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing.

Please note that when processing of your personal data is carried for direct marketing purposes, you have the right to object at any time to such processing without providing any justification. We will no longer process your data for such direct marketing purposes. You may refer to relevant sections of this Privacy Policy to learn whether we process your data for direct marketing purposes.

How to exercise your rights as to your personal data?

Any requests to exercise your rights can be directed to Reflect through the contact details provided below. These requests are free of charge.


Reflect will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if Reflect is overwhelmed by the number of requests or the request at issue is complicated and requires a lot of action. Reflect will inform you of any such extension within one month of receipt of the request, together with the reasons of such delay.

If you have doubts as to our reply or reaction, or absence of such, you have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.


The privacy of children is one of our major concerns.

General age limitation. At Reflect we can provide services only in case you as the user are aged 13 or older and any use or access to the Service by anyone under thirteen (13) is strictly prohibited and in violation of these Terms. If you are under 13 you will need to get your parent’s/guardian’s permission before providing any private information to Reflect. We reserve the right to request reasonable proof of such permission, and you must provide such proof within a reasonable period of time, but no later than in three (3) business days following such request.

Age limitation for EU residents. Due to requirements of the EU General Data Protection Regulation you shall be at least 16 years old in order to use our Services. To the extent prohibited by applicable law, we do not allow use of the Service by the EU residents younger than 16 years old.

If we unintentionally collect personal data, find any content with, or related to a child under age 13, we will delete such information as quickly as possible. Besides, if you are aware of anyone younger than 13 or 16 using our Services, please contact us at


We may change this Privacy Policy from time to time if doing so will be deemed necessary in order to comply with the applicable laws and actual circumstances of the functioning of this Application, so please periodically check this page to ensure that you’re satisfied with any changes. Additional notifications on any amendments will be displayed or otherwise communicated to you when using the Application after the amendments were made. If within one week after such notification has been shown to you, you continue to use the Application, you will be considered as having accepted all the amendments made, unless there is an obligation imposed on Reflect by an applicable law to obtain your explicit consent to the amendments. This can be a case when, for example, the nature of your data processing and purposes for processing change.


We hope this Privacy Policy helped you understand how your personal information is dealt with at Reflect. Reflect will undertake its best effort to make your personal data protected. If you have any questions regarding this Privacy Policy and our Services, please contact us at or to:

300 Delaware Ave Ste 210-A, Wilmington, New Castle, 19801
Delaware State, United States, registration number 7226991.

Enjoy your swaps!

Reflect team