GDPR Privacy Notice for EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services.

Where applicable, this GDPR Privacy Notice is intended to supplement, and not replace, the Company’s Privacy Policy at the “Privacy Policy”. If there are any conflicts between this GDPR Privacy Notice and the Company’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at support@reward.me.com.

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.

Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

  • Name
  • Profile picture
  • Phone number
  • Age / date of birth
  • Gender
  • Email address
  • Payment card
  • Credit Cards
  • Purchase/transaction history
  • Email data, for example, email metadata including sender’s name, recipient’s name, subject line, email time chop, email contents and email attachments
  • User content, for example, comments, posts, or other feedback you submit publically (which can include Personal Data if you include Personal Data in such content)
  • Information we receive from third party sources: Some third parties such as Gmail, Yahoo Mail, iCloud provide us with Personal Data about you, such as the following:
  • Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Google Gmail), the third party service will send us information about you, such as information from your email meta data, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
  • Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

  • IP address
  • Device identifiers
  • Location information (e.g. IP address, zip code)
  • System log data
  • Usage information
  • Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.)

How Do We Use Your Personal Data?

We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

  • Provide services, such as to parse your emails and deliver emails in conversational view
  • Send email push notifications, and show email sender’s and receiver’s names
  • Provide support and assistance for the Services
  • Communicate with you about the Services
  • Contact you about Service announcements, updates or offers
  • Meet contract or legal obligations
  • Respond to user inquiries
  • Fulfill user requests
  • Comply with our legal or contractual obligations
  • Resolve disputes
  • Enforce our Terms of Use

We also process Personal Data to create aggregated and anonymized consumer insights reports (“Consumer Insight Reports”), so as to develop analytics and profiling for business intelligence. We never disclose aggregated or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

  • Email address

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

  • Email address
  • Email meta data
  • User content
  • IP address
  • Device identifiers
  • Location information
  • System log data
  • Examples of these legitimate interests include:
  • Operation and improvement of our business, products and services
  • Provision and marketing of our products and services
  • Provision of customer support and responding to customer requests

Consent: In some cases (including the following cases), we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

  • Development of the Consumer Insights Reports
  • Provision of the email parsing and conversion of emails into conversational view, in order to provide our products and services to you.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data?

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Use. These parties include:

  • Fraud prevention service providers
  • Hosting service providers
  • Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
  • Social media services (if you interact with them through your use of the Services)
  • Third party business partners who you access through the Services
  • Other parties authorized by you

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
  • Protect us, our business or our users, for example to enforce our Terms of Use, prevent spam or other unwanted communications and investigate or protect against fraud
  • Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

Last, we share Personal Data with our affiliates or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use?

We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. For example, All Personal Data is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption. All Personal Data is stored on Benchling is hosted on Amazon Web Services (AWS) and Microsoft Azure, which undergo various third-party independent audits on a regular basis, covering compliance controls for its data centers, infrastructure, and operations. This includes SOC 2 certification and ISO 27001 certification.

Personal Data of Children:

As noted in the Terms of Use we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at support@reward.me.

What Rights Do You Have Regarding Your Personal Data?

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email support@reward.me. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by sending us an email at support@reward.me.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by sending us an email at support@reward.me.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data:

The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. as set forth herein.

Company is committed to the Principles of the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. These Principles are (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Company’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. For more information about the Privacy Shield Program, please visit www.privacyshield.gov.

Please contact us at support@reward.me with any questions or concerns relating to the Privacy Shield. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means.

What If You Have Questions Regarding Your Personal Data?

If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:

Name: AlternativeData.com

Physical address: 118 Wai Yip Street, Kwun Tong, Hong Kong

Email address for contact: support@reward.me

Designated representative and contact information

DP-Dock GmbH

Ballindamm 39

20095 Hamburg

Tel.: +49 (0) 40 99999 – 3430

Mob.: +49 (0) 172 918 22 22

Data Protection Officer and contact information

Yixuan Sheng, support@reward.me