Effective date: February 1, 2021
At RewardMe, we take your privacy seriously.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|Category of Personal Data||Examples of Personal Data We Collect||Categories of Third Parties With Whom We Share this Personal Data|
|Account or Contact Data|
|Consumer Demographic Data|
|Other Identifying Information that You Voluntarily Choose to Provide|
We collect Personal Data about you from the following categories of sources:
Third Parties You Authorize
Our Service Providers
We do not serve advertisements on our Services, do not use any Personal Data in marketing or selling our Services, and do not engage in any tracking of an individual or a device for advertising, marketing, or retargeting purposes.
We use your Personal Data for the following commercial or business purposes:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Business Partners. These parties partner with us in offering various services. They include:
Parties You Authorize, Access or Authenticate
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
As described in Section 3.3 (Creating De-identified or Aggregated Data) above, we may create aggregated, de-identified or anonymized data from the Personal Data (e.g. Commercial Data and Consumer Demographic Data) we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our and their lawful business purposes, including to analyze, build and improve the Services and promote our business, to research and develop new products and services, generate analytics or reports, facilitate researches or studies, and gain consumer insights or other business intelligence, or for other legitimate business purposes.
Specifically, we share aggregated or de-identified data based on your Personal Data with Measurable AI, an enterprise-facing database and platform that provides alternative data (that doesn’t include any Personal Data) to enable its subscribers to use, review, analyze such data to gain consumer insights, industry developments, market trends, and other business intelligence. For example, we (through MailTime) scan and identify purchase receipts from Commercial Messages collected from your email account linked to the Services, aggregate such de-identified information with other de-identified information from our other users of the Services to create de-identified and/or aggregated data, which will become part of the database or data feeds we provide to Measurable AI.
We adopt the following measures designed to ensure that the shared data would not identify you as an individual person:
Opt-out: To the extent such sharing is deemed as “sale” under the CCPA, you have the right to opt-out from such sharing as further described in Section 8.4 below.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. 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. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
The California Consumer Protection Act gives California residents the right to stop the “sale” of their personal information through a mechanism called “Do Not Sell My Personal Information” button or hyperlink. In this section, we use the term ‘sell’ as it is defined in the CCPA.
While there are many positive impacts of this requirement, California’s definition of “sale” also captures the transfer of data between corporate affiliates (that is, companies that share common ownership) and other transfers that ordinarily may not be thought of as a “sale” in the traditional sense of the word. As described above, we create aggregated or de-identified information based on your Personal Data and then share such aggregated or de-identified data with our partners (including Measurable AI as described in Section 4.4 above), for which we receive monetary or other valuable consideration, which in turn enables us to provide you with Rewards Point rewards, offers, and other benefits that are a core mission of our Services. We’re committed to implement technical safeguards and business process designed to ensure that de-identified information based on your Personal Data cannot reasonably identify, relate to, describe, or be linked to you, and to prohibit re-identification of you based on such de-identified data. However, due to the many ambiguities and uncertainties regarding California’s definition of “sale” and de-identification requirements, we’re not sure whether such sharing of aggregated or de-identified data with our partners may still be deemed as “sale” under the CCPA. To the extent such sharing is deemed as “sale” under the CCPA, you have the right to opt-out from these sales as further described below.
We sell your Personal Data to the following categories of third parties:
For the avoidance of doubt, we never sell your Personal Data for advertising or retargeting purposes.
Over the past 12 months, we have sold the following categories of your Personal Data (after being de-identified in accordance with our standard process) to categories of third parties listed above:
You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
To our knowledge, we do not sell the Personal Data of minors under 16 years of age.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you. Please note that to the extent you opt-out we may be unable to offer you some of our Services which require such sharing. If you have further questions, you can contact us at email@example.com.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
The Service is hosted in Hong Kong and is intended for visitors located within Canada, Brazil, Indonesia, Israel, Malaysia, Mexico, Philippines, Singapore, Vietnam, Taiwan, Thailand, South Korea, Japan, the United Sates. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from Hong Kong law, then please note that you are transferring your personally identifiable information outside of those regions to Hong Kong for storage and processing, and by providing your personally identifiable information on the Service you consent to that transfer, storage, and processing.