Privacy policy

REWARDIFY, INC.

PRIVACY POLICY

Last Updated: April, 2024

WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO. PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE MAKE TO THIS PRIVACY POLICY.

Rewardify, Inc. (“Rewardify”, or “we”) supplies this Privacy Policy to advise you of our policies and procedures involving the collection, use and disclosure of private information we receive from users of our sites (collectively, the “Site”) as well as from users of any of our programs, whether on third party sites or as an application for mobile devices (together, the “Program”). The term “Services”, as used in this Privacy Policy, contain both the Program and the Website. This Privacy Policy applies only to information which you supply to us (or allow third party websites to supply us) or that we gather through the Services. Rewardify Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the main access points to the Services. You are advised to consult this policy regularly for any changes.

You’re consenting to our Processing of your information as set forth in this Privacy Policy and amended by us through the use of our Services. “Processing” means using cookies or information by any means, including, but not restricted to, gathering, saving and deleting, using, combining and revealing information and transferring it to the United States and internationally.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE AND PLATFORM.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@REWARDIFY.COM.

Information Collection and Use: Personally Identifiable Information

You may supply personally identifiable information to us. Private Information includes, but isn’t restricted to, email and your name. We use your Private Information manage your questions and primarily to supply our Services.

If you select to buy any virtual goods within your use of the Services, to the extent available, we or our third party companies may collect information that is personal from one to allow your payment for such goods that are virtual.

In addition we gather other information which you supply in connection with your enrollment and/or use of the Services (e.g., without limit, birthday, sex, zip code (on its own), individual inclinations and specific information about your computer or mobile apparatus, such as operating system, software version and unique promotion identifier) (“Non-Identifying Info”). Specific Non-Identifying Information would be considered a component of your Personal Information if it were joined with other identifiers (as an example, joining your zip code with your street address) in a sense that empowers one to be identified. But the same bits of information are considered Non-Identifying Information when they’ve been taken alone or combined only with other non-identifying information (by way of example, your viewing preferences).

You may sign-up to use the Services directly via the Application or via certain third party social networking sites (each, a “Social Networking Site”). If you decide to create an account to use the Services via a Social Networking Site, we may extract the personal information you have provided to such Social Networking Site (such as your “real” name, email address and other information you make available via the Social Networking Site) from the account you have with such Social Networking Site and use that information to create your Rewardify account; the information we extract may depend on the privacy settings you have with the Social Networking Site.

If you choose to purchase any virtual goods as part of your use of the Services, to the extent available, we or our third party service providers may collect Personal Information from you to facilitate your payment for such virtual goods

We also collect other information that you provide in connection with your registration and/or use of the Services (e.g., without limitation, birthday, gender, zip code (on its own), individual preferences and certain information about your computer or mobile device, such as operating system, software version and unique advertising identifier) (“Non-Identifying Information”).

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences).

We also utilize Your Individual Information (in some instances, along with your Non-Identifying Information) to make contact with you with updates, advertising or promotional resources along with other information which may be of attention for you. Please follow the directions supplied in virtually any of the communications or revise your “user preferences” info should you choose anytime that you simply no further desire to obtain these communications from us. (View “Changing or Removing Info,” under.)

Log Data

WWhen you use the Services, whether as a registered user or a non-registered user, for example in accessing our Services through a Social Networking Site, (any of these, a “REWARDIFY 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 visited before you came to the Service, pages of the websites involved in the Service that you visit, the time spent on those pages, information you search for, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the Service’s technical administration, to increase the functionality and user-friendliness of our Services, and to better tailor the Services to our visitors’ needs. For example, some of this information is collected so that when you use our Services again, it will recognize you and serve advertisements and other information appropriate to your interests, as described in more detail below. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

Cookies

Like many websites, our Service uses “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 do not link the information we store in cookies to any Personal Information you submit while using our Services.

We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID and login password for future logins. Second, we utilize session ID cookies to enable certain features of the Services in order to better understand how you interact with the Services and to monitor aggregate usage by REWARDIFY Users and web traffic routing. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser.

We may participate in behavioral-based advertising services, meaning a third party may place a cookie on your browser, or use a web beacon, to collect information about your use of our application so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our application, or on other websites. 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. On mobile you can reset your settings by taking the following steps (for iOS:Opt out of interest-based ads in the App Store and Apple News and for Android: Block certain ads – Ads Help). If you do not accept cookies, however, you may not be able to use all portions of the application or all functionality of our Services.

Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.

Information Sharing and Disclosure

Aggregate Information and Non-Identifying Information; Advertisers. We may share aggregated information that does not contain Personal Information and we may disclose Non- Identifying Information and Log Data with third parties for other purposes, demographic profiling and industry analysis.

In particular, we may determine to share Non-Identifying Info (including the promotion identifier currently associated with your device) and Log Data and other aggregated information with advertisers. Such information may be used to send you advertisements for services and products that are applicable to your own interests.

For example, we may collect and share the advertisements identifier associated with your device (such as the Apple IDFA and Android Marketing ID) with advertisers. We use the Apple IDFA exclusively as allowed by Apple, and we use the Android Marketing ID only as allowed by Google. A marketing identifier is assigned, and default on your own mobile device turns on, advertisement tracking. You may limit the use of or reset your marketing apparatus ID using the privacy settings on your cellular device; in some situations, you may have to reset the operating system to reset the advertisements device ID. We do not connect any of your private information with your marketing device ID without your consent (which may be given by you in our terms of use for a Program). Service Providers. We may use third party companies and individuals to facilitate our services, to supply our services on our behalf, to perform services linked to our Services (e.g., without limitation, care services, database management, web analytics and advancement of the site features) or to help us in analyzing how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to divulge or utilize it for another purpose.

Protection of Rewardify and Others.

We may share personal information when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Rewardify, our products and services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Response to Subpoenas and Other Legal Requests.

We may share your information with courts, law enforcement agencies, or other government bodies when we have a

We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

REWARDIFY works with authorities and law enforcement officials and private parties to apply and comply with regulations.

Social Networking Sites.

We may share the information in your REWARDIFY account profile (including your Private Information) with the Social Networking Sites you have linked to your REWARDIFY account to provide you with enhanced services. These

We may share the information in your REWARDIFY account profile (including your Private Information) with the Social Networking Sites you have linked to your REWARDIFY account to provide you with enhanced services. These third parties have access to your own Private Information only for this goal (unless they’ve received your Personal Information independently of the REWARDIFY service) and are obligated not to divulge or utilize it for any other purpose. In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.

Please see the privacy policy of the website or app where a Rewardify ad is shown for more information about its privacy practices and privacy choices it may offer.

Business Transfers.

REWARDIFY may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting Your Information

By contacting us, all registered REWARDIFY users may review, update, correct or delete the Personal Information in their registration profile. If you completely delete all such information, your account may become deactivated. Please contact us if you would like us to delete your records in our system and if we do not have any legal obligation to retain the record, we will attempt to accommodate your request. See below for privacy contact information.

Security

REWARDIFY is concerned with safeguarding your information. We apply reasonable electronic, physical and administrative measures designed to help protect your information. No security, nevertheless, can eliminate the possibility we cannot guarantee your information will remain secure in all situations and your information may be accessed by an unauthorized third party.

We will make any lawfully required disclosures of any infraction of the security, confidentiality, or integrity of your unencrypted electronically stored “private information” (as defined in applicable state statutes on security breach notification) to you via email, mail, phone, or noticeable posting on our web site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to establish the extent of the breach and restore the reasonable integrity of the data system. We hold the right to select which approach we use to contact you about such an event.

International Transfer

YoYour information may be transferred to and maintained on computers found outside of your state, province, nation or other governmental authority where the privacy laws may not be as protective as those in your jurisdiction. In case you are located outside the United States and choose to supply us with information, REWARDIFY procedures it there and transfers Personal Information to the USA. Your agreement is represented by your consent to this Privacy Policy followed by your submission of such information to that transport.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

International Data Transfers

Rewardify is headquartered, incorporated in the United States, with servers based in the United States. Information wRewardify is headquartered, incorporated in the United States, with servers based in the United States. Information we collect from you will be processed in the United States. When we transfer EU subject’s personal information to third parties outside of the European Economic Area (EEA), we rely on the appropriate safeguards or specific derogations recognized under the EU data protections law, including the GDPR. The European Commission has adopted standard data protection clauses, which provide safeguards for Personal information transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal information from a country in the EEA to a country outside the EEA.

EU Data Subjects Privacy Rights

We are headquartered in the United States. Most of the operations are located in the United States. Your Personal Information, which you give to us during registration or use of our Website or Platform, may be accessed by or transferred to us in the United States. If you are visiting our Web site or registering for our Services from outside the United States, be aware that your Personal Information may be transferred to, stored, and processed in the United States. Our servers or our third-party hosting services partners are located in the United States. By using our site, you consent to any transfer of your Personal Information out of Europe, UK, or Switzerland for processing in the US or other countries.

• If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).
• Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request.
• In such situations, however, we will still respond to let you know of our decision.
• As used herein, “Personal Data” means any information that identifies you as an individual, such as name, address, email address, IP address, phone number, business address, business title, business email address, company, etc.

(a.) EU Standard Contractual Clauses. On June 4, 2021, the EU promulgated a new set of SCCs (the “New SCCs”), which replaced the old SCCs which had been in place for over a decade. We now comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US and other countries for Processing, as defined in the GDPR. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and conditions in the new SCCs will govern.

(b.)The New SCCs.

• The New SCCs took effect on June 27, 2021.
• The Old SCCs may still be used for new data transfers in new contracts during a three-month transition period that ends on September 27, 2021.
• Existing data transfers contracts that rely on the Old SCCs can be used until December 27, 2022, by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs.
• As of now, we and our customers are using the New SCCs to transport Personal Data from the EU to other countries including the US for processing by us.
• You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such Personal Data.
• You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the New SCCs rules that apply to Data Importers.

(c.) Our GDPR Compliance Commitment.

• We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect to the transfer or your Personal Data for Processing outside the EU.
• As a Data Importer, a User may contact us as set forth in Subsection 9(d) below with respect to the Personal Data we store and process on you.
• We hereby notify you that we will be processing, as defined in the GDPR, the Personal Data of your Authorized Users (i.e., those individuals whom you have authorized to access our Platform and to use our Services) in the US, Canada, and Turkey for us to be able to provide the Services to you that we have agreed to do in our definitive service agreement between you and us.
• Upon request, we will provide you with a list of your Personal Data that we will process and a copy of the New SCCs under which we will transport your Personal Data for processing.
• We hereby warrant that, at the time of agreeing to the SCCs for the transport of your Personal Data, we have no reason to believe that the laws and practices applicable to us as a data processor and a data importer, including those of the US, Canada, and Turkey are not in line with the requirements of the New SCCs.
• If we cannot satisfy any request or dispute to your satisfaction, we will agree to arbitrate or litigate the dispute in the EU jurisdiction in which your reside.
• We will only transfer your Personal Data to a third country in accordance with documented instructions from you.
Your Personal Data will be transferred and stored in an encryption format.
• Only our employees, who have a need to access your Personal Data to enable us to meet our contractual and legal obligations to you, will be given access to your Personal Data.
• Such employees will be given a User Name and Password to access your Personal Data.
• We will keep an automated record of all persons who have accessed your Personal Data.

(d.) Rights of Data Subjects. To make any of the following requests, with respect to this Privacy Policy, our Terms or Use, and/or Personal Data, please contact us (i) via email at privacy@rewardify.com, or (ii) by writing to us at Rewardify, Inc., 548 Market St #42478, San Francisco California 94104-5401.

i. Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
ii. Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
iii. Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
iv. Erasure: You can request that we erase some or all of your Personal Information from our systems.
v. Restriction of Processing: You can ask us to restrict further processing of your Personal Information.
vi. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
vii. Withdrawal of Consent: If we are processing your Personal Information 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, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
viii. Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm to locate your Data Protection Authority in the EU. You may contact the UK’s Information Commissioner at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
ix. We will respond to your inquiry within thirty (30) days of the receipt.

EU Standard Contractual Clauses

We will also comply with the EU Standard Contractual Clauses with respect to the transfer of Personal Information from the EU to countries other than the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of Personal Information to processors established in third countries (Commission Decision 2010/87/EC).

(i) Obligations of the data importer (processors)

The data importer agrees and warrants:

to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
that it has implemented the technical and organizational security measures before processing the personal data transferred;
that it will promptly notify the data exporter about:
any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,
any accidental or unauthorized access, and
any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;

(ii) Obligations of the data exporter

The data exporter agrees and warrants:

that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;
that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter’s behalf and in accordance with the applicable data protection law and the Clauses;
that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
that it will ensure compliance with the security measures;
that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with the Clauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information; and
that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of the data subject as the data importer under the Clauses.

(iii) Liability

The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred above by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
If a data subject is not able to bring a claim for compensation in accordance with paragraph a against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to above, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity.

Additional Safeguards

We satisfy the essential equivalence standard during the transfer of personal information under Standard Contractual Clauses.
Our surveillance process constitutes necessary measures to safeguard EU’s national security, defence, public security, the prevention, investigation, detection and prosecution of criminal offenses or of breaches of ethics for the regulated professions, an important economic or financial interest of the European Union or the protection of the data subject or the rights and freedoms of others. Such surveillance is carried out during the transit period as well.

Canadian Data Subject Rights

This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website and uses our Services, who reside in Canada (“consumers” or “you”). We ensure with the Personal Information Protection and Electronics Document Act of 2000 (“PIPEDA”) and any terms defined in the PIPEDA have the same meaning when used in this Section.

Definition of Personal Information. Any information about an identifiable individual. Whatever may be the physical form or characteristics of a particular regime for “business contact information” (name, position, title, address, professional phone number, etc.)

Right to Access Personal Information. You can request to access your personal information we hold about you. We will first confirm whether you have requested such information, explain how we have used your information, provide a list of names with whom your information has been shared and provide a copy of your information in an accessible format and make alternative formats available if requested.

Right to Correction/Limited Right to Deletion. You can request us to correct or delete your information IF you demonstrate that the personal information we hold on you is inaccurate. We will delete or correct your information within thirty (30) calendar days. When we delete/correct your personal information we will inform the third parties with whom we have shared your information.

Right to be Forgotten. Your information will be kept with us for as long as it is required for the fulfillment of the purposes of Rewardify platform. Unless we otherwise give you notice, we will retain your Information on the Rewardify Platform on your behalf until such times as you or we terminate your User Account.

Data Breach Notification. We will send a notification to you as soon as feasible regarding the information of any breach that creates a “real risk of significant harm” to you. We keep a record of every data breach and, on request, provide the Office of the Privacy Commissioner with access to the record.

Canadian Privacy Officer. We have appointed a Canadian Privacy and Data Protection Officer, [Name] [Email ID], to make sure the privacy rights of our Canadian users are protected in compliance with PIPEDA.

Two Factor Authentication
You may enable two-factor authentication on your account to help ensure that only you can access your account. If you do, in addition to entering your password to log in to your account to access the Rewardify Platform, we will send a code to your mobile number, which you will need to enter. This added security prevents anyone else from accessing your Rewardify account unless they have access to your login information.

Contact Information. You may contact us (i) at [Email ID], or (ii) by writing to us at Privacy Officer, at [Address] to (i) make a Personal Information Request, (ii) correct or delete your personal information, (iii) discuss our Privacy Policy and/or anything that has to do with it. We will respond within thirty (30) calendar days of receiving such a request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

Policy Regarding Children

Rewardify is committed to complying with the laws protecting the privacy of children, including the United States’ Children’s Online Privacy Protection Act (COPPA) Our Services are not directed to children under 16. We do not intentionally collect personally identifiable information from children under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their permission, he or she should contact us at privacy@Rewardify.com. If we become aware a child under age 16 has provided Private Information to us, we’ll delete such information from our files. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE OR PLATFORM.

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to REWARDIFY. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, please visit the Federal Trade Commission’s website.

Links to Other Sites

Our Services may provide links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or clicking on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise any control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Marketing and Advertising Practices

We may reach out to you in different ways, for example, to tell you about new features, games, or sweepstakes on the App we think you’d be interested in, or to show you how to use a particular feature we think you may enjoy. However, you can also let us know that you’d rather not hear from us with this type of communication.

Promotional Offers from Rewardify

We may use any of the categories of personal information we collect to make decisions about what we think you may desire or need as our customer. We will only make these marketing decisions if you agree to receive email marketing from us. In all cases, we allow you to opt-out of receiving marketing communications Promotional Offers from Rewardify

We may use any of the categories of personal information we collect to make decisions about what we think you may desire or need as our customer. We will only make these marketing decisions if you agree to receive email marketing from us. In all cases, we allow you to opt-out of receiving marketing communications from us.

Interest Based Advertising.

Rewardify uses advertising to help fund our services and we utilize numerous advertising technology platforms to help deliver relevant advertising to you. Rewardify and our technology service providers may collect, receive, or use your personal data in connection with our use of the platform in order to provide interest-based advertising to you. In such cases the advertiser is acting as a controller of the data for its own purposes.

Most of the third-party advertising and data companies we work with subscribe to the DAA Principles and/or are members of the Network Advertising Initiative (“NAI”). To learn more about the information collection practices of NAI members and your related opt-out choices, please visit the NAI’s website here. For more on EU online choices, please visit the EU online choices website here. You can opt out of interest-based advertising from Google by visiting the About Google Ads page or opt out of the DoubleClick cookie by installing the DoubleClick opt out extension. For information about how Google uses data from DoubleClick for Publishers, click here.

Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertisers include the following:

• AdColony: https://www.adcolony.com/privacy-policy/
• AdMob: https://policies.google.com/privacy
• Amazon: https://developer.amazon.com/docs/mobile-ads/mb-faq.html
• AppLovin: https://www.applovin.com/privacy/
• Facebook: https://www.facebook.com/about/basics/advertising
• Fyber: https://www.fyber.com/privacy-policy/
• HyprMX: https://www.hyprmx.com/pp
• InMobi: https://www.inmobi.com/privacy-policy
• IronSource:https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/ Smaato: • https://www.smaato.com/privacy/
• Unity: https://unity3d.com/legal/cookie-policy#cookies
• Verizon: https://www.verizon.com/about/privacy/about-our-ads
• Vungle: http://vungle.com/privacy
• Soomla: https://soomla.com/privacy-policy/
• Tap Research: https://www.tapresearch.com/legal/privacy-policy-en

Mobile App Advertising and Tracking.

Rewardify, our authorized service providers and/or other third-party partners (listed above) involved in the delivery of advertising you receive through our App may collect information about your mobile device, including your mobile device’s advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. Rewardify and our partners use this information to enable interest-based advertising you receive through our Services and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device’s advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions. Visit the privacy settings for your mobile device for more information.

In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser. Please see the privacy policy of the website or app where a Rewardify ad is shown for more information about its privacy practices and privacy choices it may offer.

CCPA

This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website or Platform, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section.

(a.) Right to Request Personal Information. Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period.

We require such Personal Information to be able to provide to you our Services.

Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.

(a.) Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.

(b.) Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.

(c.) Non-Discrimination Right. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
1. (i) Deny you goods or services.
1. (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
1. (iii) Provide you a different level or quality of goods or services.
1. (iv) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

(d.) Financial Incentives. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

(e.) Contact Information. You may contact us at privacy@rewardify.com, to (i) make a Personal Information Request, (ii) lodge a complaint about our use or storage of your Personal Information, (iii) ask us to delete such Personal Information, and/or (iv) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.

(f.) Under 16. We will not sell your Personal Information if you are under the age of 16 unless we have the consent of your parent or your guardian nor will we sell it if you ask us not to do so.

(g.) Opt Out Right. Upon your request, we will stop selling your Personal Information (sometimes called your Opt Out Right). You may send the request to Opt Out to privacy@rewardify.com.

California Privacy Rights (Under California Civil Code Section 1798.83)

California residents have the right to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed certain types of personal information (if any) for their direct marketing purposes in the prior calendar year. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct California residents have the right to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed certain types of personal information (if any) for their direct marketing purposes in the prior calendar year. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes. You can read these instructions above in the “Marketing and Advertising Practices” section of our Privacy Policy. Or, if you are a California resident and prefer that we send you a separate response, please email your request to privacy@rewardify.com. At this time, our Website does not respond to browser “Do Not Track” signals.

CAN-SPAM ACT OF 2003

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

(a.) not use false or misleading subjects or email addresses;
(b.) identify the email message as an advertisement in some reasonable way;
(c.) include the physical address of Rewardify, Inc., which is 548 Market St #42478, San Francisco California 94104-5401;
(d.) monitor third-party email marketing services for compliance, if one is used;
(e.) honor opt-out/unsubscribe requests quickly; and
(f.) give an “opt-out” or “unsubscribe” option.

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@rewardify.com and we will promptly remove you from all future marketing correspondences.

Copyright Infringement/DMCA Notice

If you believe that any content on our Website or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

(a.) Your physical or electronic signature;
(b.) Identification of the copyrighted work(s) that you claim to have been infringed;
(c.) Identification of the material on our Website or Platform that you claim is infringing and that you request us to remove;
(d.) Sufficient information to permit us to locate such material;
(e.) Your address, telephone number, and email address;
(f.) A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
(g.) A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

Rewardify’s Copyright Agent to receive DMCA Takedown Notices is Deb Smith, at privacy@rewardify.com and at Rewardify, Attn: DMCA Notice, 548 Market St #42478, San Francisco California 94104-5401. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Rewardify in connection with the written notification and allegation of copyright infringement.

Anti-Bribery Compliance

Rewardify represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”). Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Rewardify, or (B) the obtaining or retention of business by Rewardify. Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Supplier Personnel.

Changes to our Privacy Policy

By using this website and/or Rewardify Apps, you agree to the terms and conditions contained in this Privacy Policy and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this website. You agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California. You also agree to arbitrate such disputes in California, and to abide by any limitation on damages contained in any agreement we may have with you.

This Policy is expected to change from time to time. We reserve the right to amend this Privacy Policy at any time and provide notice to you by posting the amended Privacy Policy on the website. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of these Services.

Contact Us

If you have any questions or wish to register a complaint in relation to this Privacy Policy or the manner in which your personal information is used by us, please contact us by any of the following means:

Rewardify, Inc.
548 Market St #42478
San Francisco
California 94104-5401

Attn: Privacy Department

Or:
privacy@rewardify.com