This Privacy Policy describes how we collect, use and disclose your personally identifiable information when you interact with the Services provided by RewardsPay, Inc. (“RewardsPay”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the RewardsPay Terms of Service.
Please note that your use of the Services on third party websites and services, and the information that you share during your use of such third party websites and services, may be subject to such third party’s privacy policy. RewardsPay is not responsible for any use by the third party of any information you provide to such third party, and we encourage you to read the third party’s privacy policy before providing any personally identifiable information. Please also note that the third party websites and services also may contain links to third party websites, many of which are related to the online shopping and rewards programs offered by the third party. RewardsPay is not responsible for the privacy practices of such third party websites and services.
Information Collection and Use
Upon interacting with the Services, you will have the option to register for an account and become a user of the Services. To register for an account, we will ask you to provide us with some personally identifiable information – information about you that can be used to contact or identify you, like your name and email address. When you use the Services, we will also collect information about the transactions you complete via the Services. We use your email address and transaction history mainly to develop, offer and deliver our Services, to respond to your inquiries, to fulfill legal and regulatory requirements, to conduct market research, project planning, troubleshooting, detecting and protecting against errors, fraud or other criminal activity, and to enforce our Terms of Service. We also use such information to contact you with RewardsPay newsletters, marketing or promotional materials and other information that may be of interest to you. The email address you provide to RewardsPay will be associated with all your RewardsPay transactions whether using your Rewards or any other form of payment offered through the Service. When your account is accessed using your email address all of your transactions whether transacted using your Rewards or any other form of payment offered through the Service will be visible in your account transaction history. You can request at any time to no longer receive such communications by contacting us. If you choose not to create an account, you will still be able to use the Services, but please note that you will not be able to use all of the features and benefits of the Services.
We may collect non-personally identifiable information, that is information that cannot identify a particular person such as a zip code or city or state of residence, without an association to a name or address, as well as information transmitted during routine internet communications, a user's Internet Service Provider, and a computer's operating system. We collect non-personally identifiable information and provide aggregated, non-personally identifiable information about RewardsPay Users (defined below) to third parties for audit, marketing research and other purposes. Since aggregated data is not associated with any particular person, these third parties will not have access to any personally identifiable information about you.
Like many online services, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins to the Services. Second, we utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by RewardsPay Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionality of the Services.
When you use the Services, whether as you have registered for an account or are a non-registered user just browsing (any of these, a RewardsPay User), our servers automatically record information that your browser sends whenever you visit a website (Log Data). This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser type or the webpage you were visiting before you used our Services, pages of our Services that you visit, the time spent on those pages, information you search for via our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to better tailor our Services to our visitors’ needs. We also use this information to verify that RewardsPay Users meet the criteria required to process their requests.
Invite a Friend
One of the features of our Services allows RewardsPay Users to invite friends via an email invitation to use the Services. RewardsPay also enables RewardsPay Users to import data from their contact lists from various email accounts that the RewardsPay User may have (such as Gmail, Windows Live, AOL, etc.). RewardsPay will not use the information submitted by the RewardsPay User for any purpose other than sending a one-time invitation to the friend as per the RewardsPay User's request.
Sharing of Personally Identifiable Information
Except in providing the Services, when we otherwise have your permission, or under the circumstances below, we do not share your Personal Information with nonaffiliated third parties.
Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include personally identifiable information and we may otherwise disclose non-identifying information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personally identifiable information.
Service Providers. We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services’ features) or to assist us in analyzing how our Services are used. These third parties have access to your personally identifiable information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Business Partners. We may also provide your personally identifiable information to the operators of the third party services and websites through which our Services may be accessed. We will share your personally identifiable information with such third parties for the limited purpose of enabling and completing transactions you enter into via the Services.
Compliance with Laws and Law Enforcement. RewardsPay cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of RewardsPay or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.
Business Transfers. RewardsPay may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
Changing or Deleting Your Information
You may review, update, correct or delete the information you provide us by contacting us. If you would like us to remove your information from our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the record.
No Adware
Other than ads that are on third party websites in which the Services accessible, RewardsPay does not place advertisements on the Services.
International Transfer
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, RewardsPay transfers personally identifiable information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Children
The Services are not directed to children. We do not knowingly collect personally identifiable information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us. If we become aware that a member is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.
Security
We take precautions — including technical, administrative and physical measures — to safeguard your information. We use technical safeguards such as firewalls and data encryption. Your account information including email address is located on a secured server behind a firewall. We authorize access to personally identifiable information, including email addresses, only for those employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We also enforce physical access controls to our buildings and files.
Changes
We reserve the right, in its sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. If we modify this Privacy Policy, we will notify you of such changes by posting them on the Services or providing you with notice of the modification. We will also indicate when such terms are effective below. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.
Personal data processing statutory notice
RewardsPay, Inc. (hereinafter "RewardsPay"), as data controller, in accordance with article 13 of the General Data Protection Regulation (EU) 2016/679 (hereinafter the "GDPR"), is providing the following information about the processing of the personal data which you, as the data subject, have provided us:
Purposes and legal basis of processing
In addition, the data which you have provided may also include some personal data defined by the Code and the GDPR as "special category data". Sensitive/special category data shall be processed according to the purposes shown further on and only with your consent.
The list of persons and entities to which your data have been disclosed is available at the company at the following addresses: [email protected] or RewardsPay’s headquarters at 1551 McCarthy Blvd., Suite 204 in Milpitas, CA 95035 U.S.A, to the attention of the Data Protection Officer.
Transfer of personal data outside the European Union
Your personal data may be transferred abroad to third-party companies belonging or outside the European Union for the purposes stated above.
Whenever data is transferred to States outside the European Union, said States shall guarantee an adequate level of protection, based on a specific decision of the European Commission or, alternatively, the recipient shall have a contractual obligation to protect data adopting an adequate and comparable level of protection to that provided under the GDPR.
Retention of personal data
Personal data shall be retained for a period of time not exceeding that necessary for the purposes for which they were collected and subsequently processed. Personal data shall be retained for the full duration of the contract which you have entered into and for a subsequent period:
Personal data collected and processed for profiling shall be retained for a maximum period of ten (10) years, at the end of which they shall be automatically deleted and rendered permanently anonymous.
Data Controller and Data Processors
The Data Controller can be reached at: [email protected] or RewardsPay’s headquarters at 1551 McCarthy Blvd., Suite 204 in Milpitas, CA 95035 U.S.A, to the attention of the Data Controller.
Data Protection Officer
The Data Protection Officer can be reached at: [email protected] or RewardsPay’s headquarters at 1551 McCarthy Blvd., Suite 204 in Milpitas, CA 95035 U.S.A, to the attention of the Data Protection Officer.
Data subject rights
At any time, in accordance with articles 15 to 22 of the GDPR, you are entitled, also in relation to profiling, to:
You may exercise these rights and/or obtain further information about personal data processing, by sending a notification:
Purposes and legal basis of processing
The personal data of a customer shall be processed for the following purposes:
Transfer of personal data outside the European Union
A customer’s personal data may be transferred to third-party companies in States outside the European Union, for the purposes stated above.
Whenever data is transferred to States outside the European Union, said States shall guarantee an adequate level of protection, based on a specific decision of the European Commission or, alternatively, the recipient shall have a contractual obligation to protect data adopting an adequate and comparable level of protection to that provided under the GDPR.
California users’ Privacy Rights
Californian users of RewardsPay have additional rights afforded to them under the California Consumer Privacy Act (CCPA).
For more details about the personal information RewardsPay has collected in the past year and details on how we use that information, please see section 1 "Information collection and use".RewardsPay does not “sell” (as defined in the CCPA) the personal information of RewardsPay users.
Making a request in relation to your personal information
The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):
California users may make a request by contacting us at [email protected]. We will authenticate your request using the email address associated with your RewardsPay account and if necessary, proof of residency.
Effective: January 1st, 2020
