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Privacy Policy
Effective Date: March, 2026
This Privacy Policy explains how REFLEKT LLC, a company established in Armenia (“Company”, “we”, “us”, or “our”), collects, uses, processes, stores, and discloses information obtained from users of www.mirror-app.com (the “Site”) and related products and services (collectively, the “Services”).
We are committed to protecting personal data in accordance with applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR) where applicable.
By accessing or using the Site or Services, you acknowledge that you have read and understood this Privacy Policy.
This Privacy Policy explains how REFLEKT LLC, a company established in Armenia (“Company”, “we”, “us”, or “our”), collects, uses, processes, stores, and discloses information obtained from users of www.mirror-app.com (the “Site”) and related products and services (collectively, the “Services”).
We are committed to protecting personal data in accordance with applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR) where applicable.
By accessing or using the Site or Services, you acknowledge that you have read and understood this Privacy Policy.
1. Information We Collect
We collect information necessary to operate, improve, and secure our Services.
Information collected may include non-personal technical information and personal information.
Information collected may include non-personal technical information and personal information.
1.1 Non-Personal Information
When you interact with the Site, we may automatically collect certain technical information that does not directly identify you as an individual.
This may include:
- device and hardware information
- browser type and version
- operating system
- IP address or approximate geographic location
- referring URLs and traffic sources
- cookies and similar tracking technologies
- usage statistics and interaction data
- timestamps and session activity
This information is used for analytics, security, performance monitoring, and service optimization.
1.2 Personal Information
We may collect personal information when you:
- create an account
- subscribe to our Services
- purchase a subscription
- contact support
- submit forms or requests
- participate in promotions or surveys
Personal information may include:
- name
- email address
- phone number
- company name
- billing information
- account credentials
- subscription and transaction records
You may browse portions of the Site anonymously, however certain Services require the provision of personal data.
1.3 Affiliate, Partner and Referral Tracking
Mirror App operates an affiliate and partner referral program.
When users visit the Site through a referral or affiliate link, we may store identifiers (such as URL parameters and cookies) to attribute user actions to partners.
Referral tracking may include:
- referral identifier
- click timestamp
- landing page URL
- device and browser data
- IP address or derived location
- signup and purchase events
Cookie duration for referral tracking: up to 120 days, unless deleted earlier by the user.
Attribution may use a last-touch attribution model, meaning the most recent valid referral interaction prior to purchase may receive credit.
Affiliate Reporting and Limited Customer Identifiers
For commission reporting purposes, partners may be able to view limited and partially redacted customer identifiers, such as masked email addresses.
Affiliate partners are strictly prohibited from:
- contacting referred customers directly
- using referral data for marketing
- selling or transferring customer data
- creating independent customer profiles
- processing customer data outside the scope of the affiliate program
Violation of these rules may result in termination from the affiliate program and potential legal action.
1.4 Legal Basis for Data Processing
Where the GDPR applies, we process personal data based on one or more of the following legal grounds:
- Performance of a contract
- Compliance with legal obligations
- Legitimate interests, including service improvement, fraud prevention, and business operations
- User consent, where legally required
Users may withdraw consent at any time where consent is the legal basis.
2. How We Use Information
We process personal data only for legitimate business purposes.
These purposes include:
We do not sell personal data to third parties.
These purposes include:
- operating and maintaining the Services
- providing customer support
- processing subscriptions, billing, refunds and payments
- operating the affiliate and partner program
- preventing fraud, abuse, and unauthorized access
- improving the functionality, reliability and performance of the Services
- communicating product updates and service notifications
- complying with legal and regulatory obligations
We do not sell personal data to third parties.
3. Sharing of Information
We may share personal data only in the following circumstances:
Service Providers
We engage trusted third-party providers to operate our Services. These may include:
- cloud infrastructure providers
- CDN and network security providers
- payment processors
- analytics platforms
- email communication services
- affiliate management systems
Such providers process data solely on our behalf and are bound by contractual data protection obligations.
Legal Requirements
We may disclose information when required to:
- comply with applicable law or regulation
- respond to lawful requests from authorities
- protect rights, property, or safety
- enforce our Terms of Service or contractual obligations
Business Transfers
If Mirror App or REFLEKT LLC undergoes a merger, acquisition, restructuring, or sale of assets, user information may be transferred as part of that transaction.
Users will be notified if such transfer materially affects their rights.
4. Third-Party Integrations
Mirror App enables integrations with external services, including social media platforms.
When connecting third-party accounts, users authorize Mirror App to access data permitted through the relevant platform authorization process.
This may include:
Mirror App does not store passwords for third-party platforms.
The use of third-party services is also governed by the respective privacy policies of those platforms.
When connecting third-party accounts, users authorize Mirror App to access data permitted through the relevant platform authorization process.
This may include:
- email address
- username
- profile information
- content or media available through the integration
Mirror App does not store passwords for third-party platforms.
The use of third-party services is also governed by the respective privacy policies of those platforms.
5. Cookies and Tracking Technologies
We use cookies and similar technologies to:
Users may control cookie preferences via browser settings.
Disabling cookies may affect functionality of certain features of the Services.
Further details are available in our Cookie Policy.
- operate and secure the Site
- remember user preferences
- analyze traffic and usage patterns
- manage affiliate attribution
- improve performance
Users may control cookie preferences via browser settings.
Disabling cookies may affect functionality of certain features of the Services.
Further details are available in our Cookie Policy.
6. User Rights
Subject to applicable law, users may have the right to:
Requests may be submitted to: support@mirror-app.com
We may require identity verification before fulfilling requests.
Users located in the European Economic Area also have the right to lodge a complaint with their local supervisory authority.
- access their personal data
- request correction of inaccurate data
- request deletion of personal data
- restrict or object to processing
- request data portability
- withdraw consent where applicable
Requests may be submitted to: support@mirror-app.com
We may require identity verification before fulfilling requests.
Users located in the European Economic Area also have the right to lodge a complaint with their local supervisory authority.
7. Marketing Communications
We may send marketing communications where permitted by law.
Users will receive such communications only if:
Users may unsubscribe at any time via:
Operational communications such as billing notifications, account security alerts, and service updates cannot be opted out of.
Users will receive such communications only if:
- they have opted in, or
- they previously engaged with our Services and have not opted out where permitted by applicable law.
Users may unsubscribe at any time via:
- the unsubscribe link in emails
- account settings
Operational communications such as billing notifications, account security alerts, and service updates cannot be opted out of.
8. Data Retention
We retain personal data only for as long as necessary to:
When data is no longer required, it is securely deleted, anonymized, or destroyed.
- provide the Services
- comply with legal and accounting obligations
- resolve disputes
- enforce agreements
When data is no longer required, it is securely deleted, anonymized, or destroyed.
9. Data Security
We implement appropriate technical and organizational security measures designed to protect personal data against:
Security measures include:
Despite our efforts, no internet transmission or electronic storage method is completely secure, and absolute security cannot be guaranteed.
- unauthorized access
- disclosure
- alteration
- destruction
Security measures include:
- encryption via SSL/TLS
- access controls and authentication systems
- monitoring and security logging
- infrastructure security practices
Despite our efforts, no internet transmission or electronic storage method is completely secure, and absolute security cannot be guaranteed.
10. International Data Transfers
REFLEKT LLC is registered in Armenia, which is outside the European Economic Area.
While our primary infrastructure may be hosted within the European Union, authorized personnel located in Armenia may access personal data in order to operate and maintain the Services.
Such access constitutes an international transfer of personal data.
Where required by law, we implement safeguards including:
While our primary infrastructure may be hosted within the European Union, authorized personnel located in Armenia may access personal data in order to operate and maintain the Services.
Such access constitutes an international transfer of personal data.
Where required by law, we implement safeguards including:
- Standard Contractual Clauses (SCCs)
- adequacy decisions where applicable
- EU–US Data Privacy Framework where relevant
- other legally recognized transfer mechanisms
11. Children's Privacy
Our Services are not directed to individuals under the age of 16.
We do not knowingly collect personal data from minors.
If we become aware that personal data of a minor has been collected without appropriate consent, we will take reasonable steps to delete such information.
We do not knowingly collect personal data from minors.
If we become aware that personal data of a minor has been collected without appropriate consent, we will take reasonable steps to delete such information.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
If material changes occur, we will provide notice through:
Continued use of the Services after such changes constitutes acceptance of the updated Privacy Policy.
If material changes occur, we will provide notice through:
- prominent notice on the Site
- email notification where appropriate
Continued use of the Services after such changes constitutes acceptance of the updated Privacy Policy.
13. Contact Information
If you have questions about this Privacy Policy or our data practices, please contact:
REFLEKT LLC
Email: support@mirror-app.com
Website: https://mirror-app.com
REFLEKT LLC
Email: support@mirror-app.com
Website: https://mirror-app.com
Data Processing Addendum
For customers acting as data controllers under applicable data protection laws, our Data Processing Addendum (DPA) forms part of the contractual framework governing processing of personal data on their behalf.
More About DPA
More About DPA
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