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Rewardex (Proprietary) Limited (“NAME”, “we”, “our” or “us”) provides its customers and users (“User(s)” or “you”) with a mobile application platform enabling Users to capture and store digital images and information of Users loyalty and reward program/account cards, information of Users data accounts, receive updated balances of these loyalty and reward programs/accounts and data accounts, deposit funds into and withdraw funds from the Users in-app cash wallet to facilitate User initiated trades and transfers of the Users points, miles and data for cash, with other Users who are members/account holders within the same program or have accounts with the same program or data service provider (the “Services”). We respect your privacy. This Privacy Policy is intended to inform you of our collection, use, disclosure, retention, and protection of your personal information when using our Services.

 

Our Services includes our downloadable mobile application(s) (the “App”), website (the “Website”) and related information and additional services.

 

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use which this Privacy Policy is incorporated thereto by reference (together, the “Terms”).

By accessing or using our service you are accepting this Privacy Policy in its entirety.  If you disagree to any of the Terms, you may not access or use the Services. Please note: you are not obligated by law to provide us with any personal information. Please read this Privacy Policy carefully before accessing and using our Services.

 

 

1. INFORMATION WE COLLECT ABOUT YOU

Personal information

Personal information is individually identifiable information about a person, that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of private or sensitive nature. Under certain applicable laws it includes any information which involves an individual with a persistent identifier such as a name or an identification number etc.

Personal information does not include information that has been anonymized or aggregated so that it can no longer be used or to identify a specific natural person.

 

Collection of Personal Information

We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, or when you use or access our Services, register for an account with us, provide us with information run searches on our Services, update or add information to your account, or through correspondence you conduct with us.

 

More specifically, these categories:

 

Personal information we collect automatically when you use our Services– 

Information collected when installing the App

When you install the on your device, you will set up a user account associated with that device and create a User ID. This is a unique identifier which is necessary in order for us to provide you with our Services. After installation of the App, we will collect and use your information, including the

We receive your information when you access and use our Services, as follows: your IP address, information regarding your clicks, views and engagement with the Services and with advertisements we may display on the Service, information concerning your traffic to and from the Services, your referral URL, our communications with you, your historical searches on the Services, information about your use and your interaction with our Services, including the duration of such use; your in-app settings; and your in-app scores (“points”).

Personal information you give us when you use our Services–
Generally, this category refers to any information, data or content you actively and voluntarily provide to us through our Services.

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Account Information.

You have to set up a registered Account in order to use the Services. When setting your Account, you may actively share certain personal information with us, such as your name and surname, email address, mobile phone numbers, loyalty/reward card numbers, loyalty/reward account numbers and account passwords/PIN numbers, data account numbers and passwords/PIN numbers.

 

Additional Content you Choose to Share with us when using the Services

You may choose to upload to the Service User Material, such as images, text, reviews and report data gaps or errors, and other types of content which you actively choose to provide. We also collect your responses to surveys we may send you on our behalf or on behalf of our partners.

 

Personal information collected from other sources 

Third Parties

We may also collect personal information concerning you, from third parties who have represented to us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic credit check information, and information from credit bureaus, as allowed by applicable national laws.

 

2.WHO IS THE DATA CONTROLLER OF YOUR PERSONAL INFORMATION?

Rewardex are the data controllers of the Personal Information collected in connection with the use of Rewardex’s services.

 

3. HOW WE USE YOUR INFORMATION

Legal basis for use – We collect, process and use your information for the purposes described in this Privacy Policy based at least on one of the following legal grounds:

 

When Performing this Agreement: Following your acceptance of these Terms, we collect and process your personal information in order to provide you with the Service, to maintain and deliver our Services to the User; for example, we collect your name and surname, email address, mobile phone numbers, loyalty/reward card numbers, loyalty/reward account numbers and account passwords/PIN numbers, data account numbers and passwords/PIN numbers.

 

With your consent: We ask for your consent to process your information for additional specific purposes, such as additional loyalty/reward card numbers, loyalty/reward account numbers and account passwords/PIN numbers, data account numbers and passwords/PIN numbers not already captured to the App and your personal bank account details to enable our service providers to transfer funds that you may choose to withdraw from time to time, from your cash wallet within the App. You have the right to withdraw your consent at any time.

 

Legitimate interests: We process your information for our, and/or our third parties’ legitimate interests, while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services; protecting against harm to the rights, property or safety of our properties, our users or the public as required or permitted by law; for the development and enhancement of our Services; to develop new features for our Users; to personalize the Service in order to deliver better user experience; for enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Service.

 

Purpose of Use 

We may use information that we collect about you for the following purposes:

• to provide you with and to operate the Service, including for aggregation, statistical and research purposes and creation and use of aggregated anonymous data which is all necessary to maintain, develop and improve Rewardex’s services,

• in order to determine and ascertain User accounts; verify User identity; and enable users, if relevant, to transfer or receive payments, which may include calculation of the costs for the services,

• transaction information, to process the funds paid and/or received and Rewardex fees, resulting from the successful trading and transfer of your loyalty and reward point/miles and data, and to facilitate the withdrawal of funds from your cash wallet within the App.

• to personalize the Service and content provided to you, to customize your experience with the Services, to communicate with users about their loyalty and reward programs/accounts and data accounts, including updates of your loyalty an reward program/account and data balances and expiry dates;

• to develop, improve and customize the Service, the experience of other users and the offering available through the Service;

• to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints, and collect feedback in connection with our performance of the Services;

• to send you updates, notices, announcements, and additional information related to the Service;

• to be able to reply to User online queries in connection with performance of the Services;

• for customization and improvement of the Service’s accuracy and interface;

• Marketing: we may use the data we collect to market our services to our users. This includes sending users communications about Rewardex services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may also send communications to our users to provide promotional information and participation in the promotions, as well as information regarding offers, discounts and promotions related to our services and services of our collaboration partners. Although we may send users communications about Reardex partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

 

• to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation, such as reporting an abusive user or fulfilling tax regulation obligations with regard to promotions and which require the use of user data; andto use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.

 

4. TO WHOM WE SHARE PERSONAL INFORMATION

For the avoidance of doubt, Rewardex may share your personal information in manners additional to the below, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.

 

We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:

 

Third Party Services

Rewardex has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services, data and cyber security services, Payment Processors, fraud detection and prevention services, data analytics services, App analytics tools including session replay records for usability and functionality monitoring and analysis, services of measuring our Services attribution and effectivity of our publication and marketing efforts, e-mail distribution and monitoring services, and our business, legal and financial advisors (collectively, “Third Party Services“). Such Third Party Services may receive or otherwise have access to our Users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Rewardex, as the controller of the information collected from its Users in connection with the use of the Services, remains responsible any personal information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.

 

Rewardex may offer you the option to link Rewardex to third party services that may be useful to you, such as XX services. Rewardex will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and Rewardex is not responsible for the third party service’s use of data. You can disconnect Rewardex and the third party service at any time and Rewardex will cease sharing data with that service from the point of disconnection onwards.

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Governmental/Law Enforcement Agencies and Legal Requests or Duties

Pursuant to a legal request, such as a subpoena, search warrant or court order, we may disclose or otherwise allow access to your personal information, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.

Protecting Rights and Safety

If we believe in good faith that this will help protect the rights, property or personal safety of Rewardex, any of our Users, or any member of the general public we may share your personal information with others, with or without notice to you.

 

Rewardex Subsidiaries and Affiliated Companies

We may share personal information internally within our family of companies, for the purposes described in this Privacy Policy. In addition, should Rewardex or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal information may be shared with the parties involved in such event.

 

5. WHERE DO WE STORE USER’S PERSONAL INFORMATION

By accessing or using our services, you hereby accept the place of storage and the transfer of information as described below.

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Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in South Africa for the management of the Mobile Application platform and Ireland, and as necessary, in secured cloud storage, provided by our third party service provider.

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While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that we, our affiliates and our service providers that store or process your personal information on our behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

 

6. USE OF TRACKING TECHNOLOGIES

By accessing or using our Services, we or our authorized service providers may use tracking technologies to help provide you with a better, faster, and safer experience, and for advertising and marketing purposes.

 

7. SECURITY

We cannot guarantee that unauthorized access will never occur

We take great care in implementing and maintaining the security of Rewardex’s Service and its User’s personal information. Rewardex employs industry standard procedures and policies to ensure the safety of its Users’ personal information and prevent unauthorised access, disclosure and alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls.

 

8. COMMUNICATIONS FROM REWARDEX

Service Messages

We may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages. By accessing or using our services, you agree to be contacted in this manner.

 

Promotional and Surveys Messages

In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with any issues either on our own behalf or on behalf of our partners. We may contact you through e-mail,), push notifications, through the Services, or any other contact methods available to us, including with the help of our Third Party Services.

Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls, and similar forms of communication, with your prior written consent.

If you wish not to receive such promotional messages or calls, you may notify Rewardex at any time by e-mailing us at support@rewardex.com or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive.

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9. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

In certain circumstances, you may request that the processing of your data be restricted, in which case Rewardex will only keep it for the exercise or defense of claims.

We also remind you that, as a User, you may oppose the processing of your data for promotional or advertising purposes, at any time.

Likewise, you have the right to withdraw your consent at any time, in those cases in which it is necessary for the processing, without this affecting the legality of the processing based on the consent prior to its withdrawal.

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To exercise the rights regarding data protection, or revoke the consents given, the User may email support@rewardex.com, indicating “Data Protection” as a reference.

The User may file a complaint with their national data protection authority if the User has a concern about our privacy practices, including the way we handle personal information. In addition, the User can contact us at support@rewardex.com

 

10. HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION

We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or protect our legitimate interests.

Where we no longer need to process your personal information for the purposes set out in this Privacy Policy, or following your request to delete your Personal Information, we will delete or anonymize your personal information from our systems.

 

11. MINORS

To use our Services, you must be over the age of eighteen (18). Therefore, we do not knowingly collect personal information from minors under the age of eighteen (18) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Services.

 

12. CHANGES TO THE PRIVACY POLICY

The terms of this Privacy Policy will govern the use of the Service and any information collected therein. Rewardex reserves the right to change this Policy at any time, so we encourage you to re-visit this page frequently. In the event of any substantial change of this Policy, we will provide you with 7 days’ prior notice via any of the communication means available to us, or by posting notice of the change on the Site. After this 7-day notice period, all amendments to this Privacy Policy shall be deemed accepted and effective on both you and us. Except if and as stated otherwise, our most current Policy shall apply to all personal information described in such Policy.

 

13. CONTACT US

If you have any questions about this Privacy Policy or Rewardex’s privacy practices, please contact us at support@rewardex.com.

By using the Rewardex App, you represent that you are free to do so and that you will not knowingly provide Rewardex  with information that infringes upon third parties’ rights, including any intellectual property rights. You further acknowledge that notwithstanding anything herein to the contrary, any and all rights, including intellectual property rights in such information provided, shall belong exclusively to Rewardex, and we may use or refrain from using any such information at our sole discretion.