LAST UPDATED: July 2025
This Privacy Policy explains how re:Members LLC (“re:Members”, “Company,” “we,” “our,” or “us”) collects, uses, discloses, and protects your personal information when you use our websites (e.g., www.remembers.com), applications, attend events, interact with us online or offline, or otherwise use our services (“Services”).
This Policy applies globally to all personal data processed by re:Members, including that of users, clients, and business partners. We act primarily as a data processor on behalf of clients (data controllers) and in limited cases as a data controller (e.g., for internal HR, legal compliance, or marketing).
Although we contract directly with U.S.-based clients, we may process personal information of individuals from the EU, UK, Switzerland, and Canada on behalf of those clients in our role as a data processor. Such processing is conducted in compliance with applicable data protection frameworks, including the DPF, GDPR, FADP, and PIPEDA.
We comply with all applicable privacy laws, including:
We may collect the following categories of personal information:
We collect personal data in the following ways:
We only process personal information when we have a lawful basis, such as consent, contract necessity, legal obligation, or legitimate interests. Uses include:
For residents of the EU, UK, or Switzerland, when we act as a data controller or where applicable, we rely on the following legal bases:
We do not sell personal information or share it for cross-context behavioral advertising as defined under the California Privacy Rights Act (CPRA). We disclose personal information only as permitted by applicable data protection laws, and only for lawful, specific, and legitimate purposes. Disclosures may include:
We ensure that any such disclosures are limited to the minimum necessary, and that appropriate contractual, organizational, and technical safeguards are in place to protect personal information in line with international data protection laws, including the GDPR, UK GDPR, Swiss FADP, Canada’s PIPEDA, and relevant U.S. state and federal laws (e.g., CPRA, GLBA).
In compliance with the Data Privacy Framework (DPF) Principles, we may transfer personal data to third-party service providers (agents) to perform tasks on our behalf, such as cloud hosting or analytics. These providers are contractually obligated to process such information only for authorized purposes and in accordance with applicable privacy laws and DPF Principles.
We remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with those Principles, unless we can prove that we are not responsible for the event, giving rise to the damage.
While we do not currently transfer personal information to third parties acting as independent controllers, if such transfers occur in the future, we will comply with the DPF Notice and Choice Principles and ensure adequate protections through appropriate contracts and safeguards.
re:Members complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, as certified by the U.S. Department of Commerce. If there’s any conflict between this policy and the DPF Principles, the Principles govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/
We may transfer personal information to countries outside your jurisdiction, including the United States, where data protection laws may differ. Where required, we implement appropriate safeguards to ensure your data remains protected, including:
Where applicable, we conduct Transfer Impact Assessments (TIAs) and require that recipients provide an equivalent level of protection. While we may process data in countries with different laws, we do not rely solely on consent unless legally appropriate.
By using our services, you acknowledge that your data may be transferred internationally, subject to these safeguards.
Depending on your jurisdiction, your rights may include:
To exercise your rights, contact: privacysupport@billhighway.com. We may need to verify your identity. Appeals may be submitted to JAMS if you’re unsatisfied with the response.
Under the Data Privacy Framework (DPF), you may opt out of:
Under the California Privacy Rights Act (CPRA), California residents may limit the use and disclosure of sensitive personal information to uses necessary to provide our services or as otherwise permitted by law.
To exercise these rights, contact us by email, phone, or mail (see Section 15).
We retain data based on:
Retention periods vary based on data type, processing purpose, and risk.
We implement technical and organizational security controls, including:
We align with PCI DSS and industry standards. No system is perfectly secure; we notify individuals of breaches as required by law.
We do not currently use automated decision-making or profiling with legal or significant effects. If this changes, we will notify users and update this Policy.
Our Services are not intended for children under 13 (or 16 in some jurisdictions). We do not knowingly collect data from minors. If we discover or are notified of such data, we will delete it promptly.
We may revise this Policy periodically. We will update the “Effective Date” and, where appropriate, notify users directly.
re:Members LLC
5435 Corporate Drive
Suite 300
Troy, MI 48098
Email: privacysupport@billhighway.com
Phone: 1.866.245.5499
If you believe your privacy rights under the DPF were violated, please contact us first. If unresolved, you may contact JAMS . Binding arbitration may be available under specific conditions as described by the U.S. Department of Commerce: https://www.dataprivacyframework.gov.
re:Members is subject to the enforcement powers of the U.S. Federal Trade Commission. We commit to resolving DPF-related complaints and to cooperate with JAMS in dispute resolution.
We reaffirm our adherence to the DPF Principles and maintain our certification with the U.S. Department of Commerce.
As required under the DPF Principles, re:Members acknowledges that it remains responsible and liable for the processing of personal information it receives under the DPF and subsequently transfers to a third party acting as an agent on its behalf. This liability applies if the agent processes such information in a manner inconsistent with the DPF Principles, unless re:Members can demonstrate it was not responsible for the event giving rise to the damage.
For most services, re:Members processes data on behalf of clients (controllers) and follows their instructions under:
In limited scenarios (e.g., internal HR, legal compliance, or marketing), we independently determine the purposes of processing and uphold all rights in this policy.
re:Members complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. re:Members has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. re:Members has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.
re:Members is responsible for and has liability in connection with onward transfers, specifically, where we transfer personal data from the UK, EEA, or Switzerland received in the United States pursuant to the DPF to other countries.
In compliance with the EU-U.S. DPF Principles, we commit to resolve complaints about our collection or use of personal information. Residents of the UK, EEA or Switzerland with inquiries or complaints regarding our Privacy Policy and DPF commitment may contact us using the information below.
We have further committed to refer unresolved privacy complaints under the EU-U.S. DPF Principles to JAMS, a non-profit alternative dispute resolution provider located in the U.S. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit JAMS for more information and to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, and as a last resort, it may be possible for you to invoke binding arbitration for complaints regarding DFP compliance not resolved by any other mechanisms.
The United States Federal Trade Commission (FTC) has jurisdiction over our compliance with the DPF. The FTC has the authority to investigate and enforce re:Members’ compliance with the DPF program.
To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data privacy framework website.
