RewardsPay Privacy Policy

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:

  • for spending SAS EuroBonus points at participating merchant sites including but not limited to Boozt, Smartbox and Storytel

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.

  1. Purpose regarding contractual performance. Your personal data shall be processed for the purpose of performing obligations arising out of the contract for the purchase, for allowing RewardsPay to deliver the purchase in an optimal manner and, specifically, for:
    1. responding to your requests;
    2. notification of information regarding the purchase (e.g. changes to redemption instructions, terms and conditions, etc.);
  2. Legal and safety purposes. Your personal data shall also be processed for the following purposes:
    1. legal, regulatory, domestic and EU compliance and that arising out of orders issued by authorities within the scope of their legal authority;
    2. establishing, exercising and/or defending a RewardsPay legal claim before the courts;
  3. Business and statistics-related purposes. Your personal data shall also be processed for purposes relating or relevant to RewardsPay business operations
    1. RewardsPay in-house staff, appointed as data processing agents and/or data processor;
    2. to the persons or companies providing services or advisory or consulting services to RewardsPay for protecting its claims (e.g. chartered accountants, lawyers, tax consultants, auditors and consultants within auditing or due diligence operations, etc.);
    3. persons and entities that are authorized to access your data, both recognized by law and secondary legislation

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:

  • within the periods established under prevailing legislation;
  • within the periods established under legislation, including secondary legislation, which require data to be kept (for example tax returns);
  • within the period necessary for protecting the rights of the data controller in the event of any disputes arising concerning performance;

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:

  1. access your personal data;
  2. request your personal data to be corrected;
  3. revoke, at any time, consent to the use and disclosure of your personal data;
  4. request your personal data to be deleted;
  5. receive the personal data concerning you in a structured, commonly used and machine-readable format, as well as the right to send your data to another data controller;
  6. oppose the processing of personal data concerning you for marketing or profiling purposes;
  7. obtain restriction on the processing of personal data;
  8. lodge a complaint with a supervisory authority;
  9. receive a notification whenever there is a personal data breach;
  10. request information about:
    • the purposes of processing;
    • the categories of personal data;
    • the recipients or categories of recipients to whom personal data have been or will be disclosed, specifically, whenever data have been sent to recipients in third countries or international organizations and the existence of adequate guarantees;
    • the period personal data shall be retained;
    • whenever data have not been collected from the data subject, all information regarding their origin.

You may exercise these rights and/or obtain further information about personal data processing, by sending a notification:

  • via e-mail to: [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.

Purposes and legal basis of processing

The personal data of a customer shall be processed for the following purposes:

  1. Purposes regarding the Program, for managing a customer’s participation in the RewardsPay Program and, specifically, for:
    • fulfilling the transaction
    • customer support purposes for said transaction
  2. Statistical purposes, in anonymous and aggregate form.

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):

  1. Request to access the personal information RewardsPay has about you; and
  2. Request that RewardsPay delete all of your personal information.

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

 
Unsupported Browser Detected
We are sorry, but the browser version you are using is not supported by RewardsPay.com because it does not meet the latest security standards of the payment card industry, so some features of the site may not be functional. Please use one of the links below to upgrade your browser to the latest version.
Cookies help us deliver our services. By using our services, you agree to our use of cookies. Learn more