BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE THAT WE COLLECT, USE, STORE, AND DISCLOSE INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WHERE REQUIRED BY LAW, WE ASK YOUR CONSENT BEFORE WE PLACE OR READ CERTAIN COOKIES OR SIMILAR TECHNOLOGIES AS DESCRIBED IN THIS PRIVACY POLICY AND OUR TERMS OF USE, WHICH MAY BE ACCESSED HERE: REIGROVE.COM/TERMS-OF-USE. IF YOU DO NOT, OR NO LONGER, AGREE WITH THIS PRIVACY POLICY AND OUR TERMS OF USE, YOU MAY NOT ACCESS OR USE OUR SERVICES.
We at Innago LLC, the owner and operator of reigrove.com, operating as REI Grove (hereafter referred to as “REI Grove,” “us,” “our,” or “we”), respect the privacy of your personal information and make every effort to ensure your information is protected and remains private.
We have provided this Privacy Policy to explain how we collect, use, share, and protect information about users of reigrove.com and any associated REI Grove services (hereafter referred to as “user,” “you,” or “your”). We will not use or share your personal information with anyone except as described in this Privacy Policy.
For purposes of this Privacy Policy, our “Services” include the REI Grove platform at reigrove.com, the REI Grove+ paid membership program, and all associated content, tools, features, and resources (collectively, the “Services”).
For purposes of this Privacy Policy, “Your Information” or “Personal Data” means information about you which may be of a confidential or sensitive nature and may include personally identifiable information (“PII”). PII means individually identifiable information that would allow us to determine the actual identity of a specific living person.
The Data Controller for REI Grove is Innago LLC and our contact details are set out in the Contact section at the end of this Privacy Policy.
We may change this Privacy Policy from time to time. If we make material changes, we will inform you by posting the revised Privacy Policy on reigrove.com. Changes will go into effect on the “Effective Date” shown above. By continuing to use the Services, you consent to the revised Privacy Policy.
1. Information Provided Directly By You
We collect information you provide directly to us, such as when you create or modify your personal account, register for REI Grove+, complete a form, survey, questionnaire, or application, contact customer support, or otherwise communicate with us. This information may include, without limitation: name, email address, phone number (if provided), physical address, and any other personal information you choose to provide.
2. Information Collected Through Your Use of Our Services
We collect information about your activity on our Services, including how you use them (e.g., date and time you logged in, features you use, searches, clicks, and pages shown to you). The following are situations in which you may provide your information to us. When you:
- Fill out forms or fields through our Services;
- Register for an account with REI Grove;
- Subscribe to REI Grove+ or enroll in a trial;
- Provide responses to a survey or questionnaire;
- Join or enroll in an event through our Services;
- Sign up for newsletters or other communications;
- Provide information through a third-party application, service, or website;
- Communicate with us or request information about our Services, whether via email, SMS, or other means;
- Participate in any of our marketing initiatives, including contests, events, or promotions; and
Participate in forums, reviews, or provide user-generated content or other submissions.
3. Information Collected Automatically
We may automatically collect information through the use of various technologies, including Cookies, Pixel Tags, and Web Beacons. We may collect your IP address, browsing behavior, and device IDs. This information is used to better understand how our Services are being used and to administer and customize the Services to improve your overall experience.
4. Information Collected From Other Sources
We may also receive information from other sources and combine it with information we collect through our Services. For example, if you choose to link, create, or log in to your REI Grove account with a social media service, we may receive information about you from that service. The data we receive is dependent upon your privacy settings with the social network.
5. Cookies, Log Files, and Technology
We use cookies, pixels, SDKs, and similar technologies to operate and secure our Services, remember your preferences, and understand how our Services are used.
Cookie choices and consent. We use a cookie preferences tool that allows you to choose whether to allow non-essential cookies. Where required by applicable law, we do not deploy non-essential cookies unless you affirmatively consent through that tool.
Strictly necessary technologies. We use strictly necessary cookies to provide core site functionality (e.g., log-in, security, page navigation). These cannot be disabled because they are required for the Services to function.
Analytics (Google Analytics; Heap). With your permission where required, we use analytics tools such as Google Analytics and Heap to understand how visitors use our Services. These tools may collect information such as pages viewed, links clicked, device and browser information, and IP address.
Cross-service analytics. We may associate usage and interaction data with your account or a common identifier such as your email address to understand usage across our Services and improve our products and communications.
Managing your choices. You can update your cookie choices at any time using our cookie preferences tool or through your browser settings.
Our Site may use remarketing services to serve ads on our behalf across the internet to previous visitors to our Site. Third-party vendors, including Google, may use cookies to serve ads based on your past visits. Where these technologies are active, this activity may constitute a “sale” or “sharing” of personal information, or “targeted advertising,” under U.S. state privacy laws. You may opt out at any time through our cookie preferences tool, through the “Your Privacy Choices” link on our Site, or by using an opt-out preference signal such as Global Privacy Control, which we honor as a valid opt-out request, as described in Section 27. You may also opt out of interest-based advertising by participating companies generally by visiting the Network Advertising Initiative at www.networkadvertising.org/choices.
You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site, but some features may be limited.
6. Table of Cookies
The following is a list of cookies we may use in our Services. Cookie names and technologies may change over time.
| Cookie Name | Duration | Purpose |
|---|---|---|
| REI Grove Token | Session | Used to verify a visitor's authentication and maintain session data. |
| REI_Grove_Tracking_Email | 13 months | Used to pass the email address you submit on our Site into our database, including where you begin but do not complete a registration or sign-up process. |
| utm_medium | 12 months | Used to track the medium a visitor came from (e.g. organic, referral, email, etc.) |
| utm_source | 12 months | Used to track the source a visitor came from (e.g. Google, Bing, etc.) |
| utm_campaign | 12 months | Used to track the digital marketing campaign a visitor came from. |
| utm_term | 12 months | Used to track the keywords a visitor used that brought them to the website. |
| _ga (Google Analytics) | 2 years | Analytics cookie used to distinguish users and generate usage statistics. |
| _hp2_id.APP_ID (Heap) | 13 months | User cookie (stores user_id, identity, other IDs). |
| _hp2_ses_props.APP_ID (Heap) | 30 minutes | Session properties cookie (stores timestamp and cookie domain/path). |
| _hp2_props.APP_ID (Heap) | 13 months | Event properties cookie for heap.js v4. |
| _hp5_meta.APP_ID (Heap) | 13 months | User and session cookie for heap.js v5. |
| _hp5_event_props.APP_ID (Heap) | 13 months | Event properties cookie for heap.js v5. |
| _hp5_let.ENV_ID (Heap) | 13 months | Contains last event time in Heap v5.2.7+. |
| _hp2_hid (Heap) | Should not persist | Used to determine which domain a cookie can be set on. |
7. Information Third Parties Provide
We may collect information about you from sources other than you, such as from social media websites, analytics providers, business affiliates and partners, and other users. This includes identity data, contact data, marketing and communications data, behavioral data, and technical data.
8. Device Information
When you use our Services through your computer, mobile phone, or other device, we may collect information regarding your device, such as hardware models, device type, operating system version, and basic usage information. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
9. Location Information
When you use the Services, we may collect your approximate location derived from your IP address.
10. Phone Number, Calls, and Text Messages
A valid phone number is required to create a REI Grove account. We use it to secure your account and communicate with you about your account and our Services.
Call and SMS Data. In connection with providing our Services, we may collect and store data related to calls and text messages between you and REI Grove, including the date and time of the communication, the phone numbers involved, and, for text messages, the content of the message. This information is used for security, fraud prevention, quality assurance, and service delivery. By providing your phone number and using our Services, you consent to this collection and storage.
Transactional Communications. We may contact you by SMS, text message, or phone call regarding your account, membership, billing, security, or any other service-related matters. These communications are necessary to provide the Services and do not require separate marketing consent.
SMS Marketing Communications. With your consent, REI Grove may also contact you by SMS and text message with marketing and promotional communications, including product updates, offers, events, and requests for feedback. By checking the applicable box at signup, you agree that REI Grove may contact you at the phone number you provide for these purposes. Message and data rates may apply. Message frequency varies. You may withdraw this consent at any time by replying STOP to any marketing message.
Phone Calls. REI Grove representatives may also contact you by phone, including for product feedback, customer research, user experience, or to provide information about REI Grove+. These calls are placed manually by REI Grove personnel and do not use autodialing technology or prerecorded messages. You may ask to be removed from our calling list at any time by informing a representative during any call or emailing help@reigrove.com.
You may still receive transactional communications after opting out of marketing communications.
11. Email Communications
We use the email address you provide to send you transactional and marketing communications about REI Grove and REI Grove+ membership. Transactional emails include membership confirmations, billing receipts, account notifications, and service-related updates. Marketing emails include promotional offers, content updates, newsletters, events, and other information we believe will be of interest to you.
REI Grove uses Brevo to send email communications. Your email address may be shared with Brevo solely for the purpose of delivering messages on our behalf. Brevo’s use of your data is governed by their privacy policy and applicable law.
You can opt out of marketing emails at any time by using the unsubscribe link in any marketing email or by contacting us at help@reigrove.com. We may still send you non-marketing messages, such as service-related, transactional, security, or account-related communications.
12. Third-Party Benefit Providers
As part of the REI Grove+ membership, we may provide you with access to certain third-party platform benefits. In order to activate and maintain your access to these benefits, REI Grove may share certain personal information with our third-party benefit providers, including your name, email address, membership status, and any other information the parties agree to in writing.
Such data sharing is limited to the purpose of activating and maintaining your access to the applicable third-party benefit. Our third-party benefit providers are contractually required to use your personal information only for that purpose and may not sell, rent, or share it with any other party. Once your personal information is transmitted to a third-party benefit provider, that provider’s collection, use, and storage of your data is governed by their own privacy policy, over which REI Grove has no control.
By activating a third-party benefit as part of your REI Grove+ membership, you consent to REI Grove sharing the necessary information with the applicable third-party provider for the purpose described above. REI Grove is not responsible for the privacy practices, data handling, or security of any third-party benefit provider.
13. Aggregated Data
We may collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data is de-identified or anonymized and does not constitute Personal Data as it does not directly or indirectly reveal your identity.
14. Children’s Privacy
Our Services are intended for users who have attained the age of majority under applicable law (18 years of age or older in most jurisdictions). We do not knowingly collect personally identifiable information from persons under the age of 13 in the United States, or under the age of 16 in the European Union. If you believe we may have accidentally received information from a child under the applicable protected age, please contact us immediately at help@reigrove.com.
15. The Legal Basis and Reasons For Collection and Processing Your Personal Information
The legal bases upon which we rely for the collection and processing of your Personal Information under the GDPR include:
- You have given REI Grove consent to provide you with our Services and to process your information in accordance with this Privacy Policy;
- It is necessary for entering into, or performing, the obligations of a contract between you and REI Grove, including our Terms of Use available at reigrove.com/terms-of-use;
- It is necessary for registering you as a user, managing your account and profile, and authenticating you when you log in;
- It is necessary for our legitimate interests in the proper administration of our platform and business, analyzing the use of the Services, and maintaining the security of the platform;
- To send communications via email and within the Services, including responding to your comments, questions, and requests, providing customer support, and sending you technical notices, product updates, security alerts, and account management messages;
- To contact you with promotional offers, newsletters, or other information that we believe will be of interest to you, where you have consented to receive such communications;
It is necessary for our compliance with certain legal provisions which may require us to process your personal data.
16. Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some safeguards we use include firewalls, data encryption, physical access controls, and information access authorization controls. Although we take measures to secure your information, we cannot guarantee the security of your information storage, nor can we guarantee that information you supply will not be intercepted while being transmitted over the internet.
17. How We Use Information We Collect
Our primary purpose in collecting, holding, using, and disclosing your information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We use this information to:
- Operate and provide our Services;
- Activate and maintain REI Grove+ membership benefits, including third-party platform benefits;
- Improve our internal operations, systems, products, and Services;
- Provide customer support including sending confirmations, technical notices, updates, security alerts, and administrative messages;
- Understand your preferences to enhance your experience using our Services;
- Analyze, improve, and manage our Services and operations;
- Resolve problems and disputes, and engage in other legal and security matters;
- Protect against fraudulent, unauthorized, or illegal activity;
- Enforce our Terms of Use and any other applicable agreements and policies;
- Send you communications we think will be of interest to you, including information about our services, products, promotions, and events; and
Verify your identity and prevent impersonation, spam, or other unauthorized or illegal activity.
18. How We Share Information We Collect
We share the information we collect about you as described in this Privacy Policy, or as described at the time of collection or sharing, as follows:
- With third-party service providers and vendors who need access to such information to carry out work on our behalf, including Brevo for email and SMS communications, and third-party benefit providers such as Ledgre for activating REI Grove+ membership benefits;
- With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services;
- With Innago LLC subsidiaries and affiliated entities that provide services or conduct data processing on our behalf;
- In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or court order;
- With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our Terms of Use or policies, or to protect the rights, property, or safety of REI Grove, our users, or others;
- In connection with, or during negotiations of, any merger, sale of company assets, consolidation, restructuring, financing, or acquisition of all or a portion of our business; and
In an aggregated and/or de-identified form which cannot reasonably be used to identify you.
19. Analytic Services Provided By Others
We may allow third-party analytics providers such as Google Analytics and Heap to collect information about your use of our Site and Services in order to understand usage, measure performance, troubleshoot issues, and improve the Services. These providers may use cookies, SDKs, and similar technologies to collect device and usage information, subject to your cookie choices. We do not use these providers to serve cross-site targeted advertising based on your activity across other businesses’ websites or services. Our use of advertising and remarketing cookies, where active, is described in Section 5 and is subject to the opt-out rights described in Section 27. We configure and contract with these analytics providers to act as our service providers, and we restrict them from using this information of their own purposes except permitted for service providers under applicable laws.
20. Links to Third-Party Websites
Our Services may contain links to websites operated by third parties. Links from our Services are not an endorsement by us of such third parties or their websites, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, or content of such third parties. If you visit a third-party website linked from our Services, we encourage you to read that site’s privacy policy and terms before providing any personal information.
21. Marketing Communications and Text Messages
Marketing Emails: We may use the email address you provide to send you marketing and promotional communications about REI Grove and REI Grove+ membership, including where you begin but do not complete a registration or sign-up process. You can opt out of marketing emails at any time by using the unsubscribe link in the email. We may still send you non-marketing messages, such as service-related, transactional, security, or account-related communications.
Text Messages: If you choose to opt in by providing your phone number and affirmatively consenting at signup, we may send you both promotional or marketing text messages and transactional text messages. Message and data rates may apply. Message frequency varies. You can opt out of marketing text messages at any time by replying STOP or get assistance by replying HELP.
22. International Privacy Practices
In order to provide our products and services to you, we may send and store your personal information outside of the country where you reside or are located, including to the United States. If you reside or are located outside of the United States, your personal information may be transferred to countries that may not provide the same level of protection for your personal information. By accessing and using our Services, users who reside in countries outside of the United States agree and consent to the transfer to, and processing of, personal information on servers located outside of the country where they reside.
23. EU/EEA/UK Privacy Rights
This section applies solely to users located in the European Union, European Economic Area, or United Kingdom. Under the GDPR (or UK GDPR if you are located in the United Kingdom), you have certain rights in relation to Personal Information we hold about you. You may exercise any of the following rights by contacting us using the information in the Contact section below.
Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information.
Right of Correction or Completion. If personal information we hold about you is not accurate, out of date, or incomplete, you have the right to have it corrected or completed.
Right of Erasure or Deletion. In certain circumstances, you have the right to request that personal information we hold about you is deleted.
Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information, including use for direct marketing purposes.
Right to Data Portability. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable, and commonly used format.
Right to Withdrawal of Consent. If you have given consent to process and share your Personal Information, you have the right to withdraw that consent at any time.
Right to Complain. If you’re based in the EU, you can file a complaint with the supervisory authority in your Member State.
24. Sharing Information With Law Enforcement
REI Grove is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If we receive a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency. We may disclose user account information to law enforcement without a subpoena, court order, or search warrant in response to a valid emergency when we believe doing so is necessary to prevent death or serious physical harm.
25. Account Information
You may correct your account information at any time by logging into your account at reigrove.com. If you wish us to delete your account, please email us at help@reigrove.com. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes.
26. Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least one (1) year and may retain it for as long as needed for our business and legal purposes, unless a longer retention period is required by law. The criteria we use to determine retention periods include the nature and sensitivity of the information, the purposes for which we process it, the length of time reasonably necessary for those purposes, and applicable legal, accounting, or reporting requirements.
27. California U.S. State Privacy Rights
This section describes the privacy rights available under U.S. state privacy laws, including the California Consumer Privacy Act as amended (the “CCPA”) and the comprehensive privacy laws of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. We extend the rights in this section to all users in the United States, regardless of your state of residence.
Information We Collect
We collect information that identifies, directly or indirectly, a particular person or device. Categories of personal information we have collected about California residents include:
Identifiers: name, email address, phone number (if provided), IP address, and other similar identifiers.
Internet or other network activity: browsing history, search history, and information on your interaction with our website, application, or advertisements.
Commercial information: records of services purchased, obtained, or considered.
Professional or employment-related information where provided voluntarily.
Approximate geolocation: general location derived from our IP address, as described in Section 9.
Inference: preference and usage profiles drawn from the information above to improve and personalize the Services.
Sensitive personal information: account log-in credentials (your email address or username in combination with your password). We use this information only to authenticate and secure your account.
How We Collect, Use, Disclose, and Retain This Information
We collect the categories above from the sources described in Sections 1 through 9, use them for the purposes described in Sections 10 through 17, disclose them to the categories of recipients described in Sections 12 and 18, and retain them as described in Section 26. In the preceding twelve (12) months, we have disclosed each of the categories listed above to service providers for the business purposes described in Section 18. Except as described in Section 5 with respect to advertising and remarketing cookies, we do not sell personal information for monetary consideration, and we do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.
28. Contact Us
If you have any questions or would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below:
REI Grove (operated by Innago LLC)
Attn: Data Protection Officer
1216 Central Parkway, Cincinnati, Ohio 45202