Effective date: November 18th 2019.
Who are we?
REWARDS LABS is a company duly registered and operating under the Bulgarian legislation and registered with the Register of the Legal Entities and Non-Profitable Organizations Register at the Registry Agency with UIC 202584488 and registered address: Sofia, Bulgaria, 76 A James Bourchier Blvd., ground floor.
We can be contacted at the following email: firstname.lastname@example.org or at the following correspondence address: 76 A James Bourchier Str., ground floor, Sofia, Bulgaria,.
What do we at REWARDS LABS do?
REWARDS LABS operates REWARDS LABS Apps which allow Merchants to create and manage loyalty programs, rewards or point’s cash back programs. In order to provide Merchants with the services described, REWARDS LABS needs to process certain information regarding the personal data of the customers that are part of the loyalty programs operated by the specific Merchant.
REWARDS LABS does not collect or process any personal data, unless the Merchant has ensured the explicit consent of the data subject.
What type of personal data do we collect?
Personal Data means any information relating to an identified or identifiable individual (e.g. data subject). An identifiable individual is one who can be identified directly or indirectly by reference to an identifier such as name, identification number, telephone number or any other fact that is specific to the physical, psychological, genetic, mental, cultural or social identity.
REWARDS LABS collects the following types of physical identity personal data:
• name, surname, family name (optional);
• date of birth (optional in US);
• e-mail (optional);
• telephone number;
We do not collect and process personal data of persons below the age of 18.
Personal data processing. Grounds of the processing
Personal Data Processing is any form of collecting, storage, erasing, transfer, alteration, updating, destruction, etc. of these data.
REWARDS LABS processes the personal data in order to provide you with the opportunity to use the loyalty programs apps operated by it and to fulfill its contractual obligations.
REWARDS LABS processes personal data for marketing purposes once you have given your explicit, free and unambiguous consent. Upon your consent, REWARDS LABS may send you newsletters or other information materials regarding the activities, operated by REWARDS LABS, via e-mail or via SMS, depending on your decision. You may withdraw your consent at any time by sending us a notification in this respect either by replying with ‘STOP’ to the SMS we have sent you, or by sending an explicit written notification to the following email email@example.com.
REWARDS LABS processes personal data in order to fulfill its legal obligations, as well as when it is necessary to prevent the life or health of the individual whose data are processed.
REWARDS LABS may process personal data on the grounds of its legal (legitimate) interest, except for those cases where the safeguard of the interest of the individual, whose data are processed, prevails.
Processing purposes. Terms of the processing
REWARDS LABS collects and processes personal data of individuals for one of the following purposes:
• to provide you with REWARDS LABS services;
• to fulfill or observe its legal and/or contractual obligations;
• to send you information regarding REWARDS LABS’ services, campaigns, new products, as well as offers or advertisements.
In addition to everything stated, REWARDS LABS has a legitimate interest to process personal data, or otherwise it would not be able to provide you with its services.
How do we process personal data?
In order to provide you with REWARDS LABS’ services we need to process your telephone number and your date of birth. We cannot provide you with our services, if you do not consent to the processing of these data.
We do not collect and process data concerning your names, e-mail or other information, unless you have willingly provided us with them.
Before using any REWARDS LABS product, Merchant has to ensure confirmation and explicit consent by all its customers to participate in the loyalty program and confirmation and prior express written consent to receive any communication via REWARDS LABS Platform as required by the TCPA and other applicable laws. Merchant has to ensure explicit consent of all customers that their personal data, as submitted with the loyalty program, may be provided to REWARDS LABS and collected and processed by REWARDS LABS.
Merchants can contact their customers and send information regarding any loyalty program created by the latter through the REWARDS LABS Platform. If Merchants upload any personal data such as names, address or phone number, they must ensure that such data have been received with the proper opt-in consent, according to the applicable European/Federal or other legislation.
When you set up your rewards or loyalty program via REWARDS LABS Platform you may be asked to provide additional information related to your business which will be used to improve our Platform and Services and will not be shared with others, except on aggregated level by industry type etc. to other Merchants or third-party service providers.
We can disclose the name of your business on our website in section(s) related to merchant testimonials or case studies after your consent.
We collect your purchase activity in specific REWARDS LABS Merchant. We will not share it with other merchants, however, it can be used by third party service providers on aggregated level or use it otherwise. They are obliged to provide maximum confidentiality and security when processing data and can use their personal information only if it is necessary for carrying out their activities. Please note that these third parties are responsible for the information which they collect. Please check their privacy policies where appropriate.
For what period do we store your personal data prior to destructing them?
The period for which we store your personal data depends on the grounds on which we collect them.
We store your personal data as long as you want to be provided with REWARDS LABS’ services. Once you are no longer part of the loyalty programs, rewards or point’s cash back programs, we will permanently delete your data, unless another legal ground for their storage exists.
We store your personal data for marketing purposes for a period of 3 years after termination of your relations with REWARDS LABS, unless you have withdrawn your consent by sending us an explicit notification in this respect, either via SMS or via email as stipulated herein above.
Keeping your data safe
REWARDS LABS has implemented all prescribed and appropriate technical and organizational security measures in order to prevent the accidental and unauthorized access, disclosure, alteration, loss, etc. of your data. These measures are periodically updated if such a need arises. Along with that, the access to your personal data is strictly limited to those individuals and legal entities specified in the present policy. REWARDS LABS requires that they also apply the appropriate technical and organizational measures in order for the equal level of data protection to be guaranteed.
REWARDS LABS has also adopted specific procedures which shall be applied in the event of potential personal data breach. Should the case be that, you will be immediately notified.
To whom may we disclose your personal data?
REWARDS LABS shall not disclose your personal data to third parties, unless you have provided your explicit consent in this respect.
In order to provide you with REWARD LABS’ services we may disclose your personal data to the following third parties:
• Employees, Agents and Affiliates of REWARDS LABS when it is necessary for the performance of their obligations;
• Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg, providing cloud services for storage of processed data;
• Clover App, operated by MarketPlace Merchant Solutions Limited, with registered number 539224, as provider of app market services and any further services, provided by the latter from time to time;
• Contracting parties of REWARDS LABS when it is necessary for the performance of contractual obligations, entering into agreements, etc.;
• Public Authorities - we may disclose your personal data upon request of competent public authorities in accordance with the applicable European and respective national legislation.
In all cases stated herein above the third parties have declared they provide an adequate level of data protection. That applies equally to entities in the scope of EU and EIA. Entities located outside the scope of EU and EIA guarantee for each specific case that an adequate level of data protection is provided in conformity with the provisions of the General Data Protection Regulation.
Transfer of personal data across borders
You should be aware that the data protection laws of other countries may not be the same as the data protection laws of your country of residence, thus in the event of transfers outside the EU or the EEA, REWARDS LABS strictly abides the rules provided for in Chapter V of the GDPR (Transfers of personal data to third countries or international organizations). REWARDS LABS transfers personal data only to countries where the European Commission has decided that the third country ensures an adequate level of protection. The European Commission has so far recognized Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland, Uruguay and the United States of America as providing adequate protection. Adequacy talks are ongoing with South Korea.
Should a necessity for data transfer in the absence of a decision of the European Commission arises, REWARDS LABS may transfer your personal data to a third country only if appropriate safeguards are provided in accordance with the requirements of Article 46 of the GDPR. REWARDS LABS may provide for such safeguards without requiring any specific authorization from a supervisory authority by implementing binding corporate rules in accordance with Article 47 of the GDPR; or on the grounds of: a contract approved by the European Commission, the consent of the individual whose personal data is concerned, other mechanisms or legal grounds that the European legislation provides.
By submitting your personal information to REWARDS LABS, you agree to the transfer, storage and processing of your personal information as described in this section. REWARDS LABS shall undertake all and any appropriate measures for the protection of the transferred personal data.
What rights do you have in respect of the personal data you have provided us with?
In compliance with the European data protection regulations, the data subject may exercise the following rights:
• Right of access to the personal data you have provided us with and right to receive a copy of these data – this includes the right to receive information regarding the processed personal data, the processing purposes, the third parties to whom REWARDS LABS discloses your data; whether certain data are compulsory to be provided or their provision is optional.
• Right of rectification – should you consider that the processed personal data are incorrect, you have the right to demand their rectification at any time; that includes the right to demand that REWARDS LABS inform any third party to whom these data are disclosed of this rectification
• Right of erasure (‘right to be forgotten’) – you may ask REWARDS LABS, respectively any third party to whom data are disclosed, to erase the processed data.
• Right of withdrawal of the consent- where the data processing is based on the grounds of your consent, you may withdraw your consent at any time in which case we will no longer process your personal data; you may withdraw your consent at any time by sending us a notification in this respect either by replying with ‘STOP’ to the SMS we have sent you, or by sending an explicit written notification to the following email: firstname.lastname@example.org.
• Right of restriction of the processing of personal data;
• Right of objection – you may object to the processing, if there is a legal ground for the objection, as well as to the discloser of the data to third parties for marketing purposes; you have the right to be informed for the initial discloser of your data to third parties that will process your data for the purposes of the direct marketing, as well as to object to such processing.
• Right not to be subject of automated decision making – you may object to being subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;
• Right of portability – in the event that your data are processed automatically, you have the right to receive your data structured and in a widely used, machine-readable and interoperable format; that applies whenever the data processing is based on the consent of the data subject or whenever the processing presupposes the fulfilment of a contractual obligation; this right cannot be exercised whenever the personal data are processed on another ground.
You may exercise any of the above listed rights at any time of the data processing by sending us notification to the following e-mail: email@example.com.
Cookies and Google Analytics Policy
We collect additional information via cookies and the browser you are using, this information will be used to assess how REWARDS LABS Merchants use our REWARDS LABS Platform.
A “Cookie” is a small amount of data, sent to your computer or mobile phone browser from a website’s system.
The information which we receive through “cookies” is specific for your PC and includes the IP address, date and time when your browser loaded our site, which pages on our website have been seen, etc.
REWARDS LABS uses “cookies” to learn more about the way you interact with our site and help us improve your experience while using it.
If you wish to delete or reject “cookies” you may change your browser’s settings. It is important to note that if you change your settings and block certain “cookies” you may not be able to take full advantage of all of the website’s features.
REWARDS LABS uses Google Analytics services for performing and processing detailed statistics regarding visitors of this website, their behavior and visits on the website. Through Google Analytics REWARDS LABS shall collect and process information regarding the visitor’s browser, operational system and device with which the visitor visits the site only for REWARDS LABS’s purpose only. The collected information will be linked with and processed together with the merchant information.
We use other third-party analytics services to help understand your usage of REWARDS LABS products and REWARDS LABS services. In particular, we provide limited amount of your information such as your email address and sign-up date to such third-party analytics services and utilize them to collect data for analytics purposes when you visit REWARDSLABS website or use REWARDS LABS products. As part of our service agreements, such services collect publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your experience. If you would like to opt out of having this information collected by or submitted to such services, please contact us at firstname.lastname@example.org,
REWARDS LABS guarantees that when using Google Analytics REWARDS LABS shall process the collected information for each visitor in the terms of strict confidentiality and shall not provide any information, allowing Google to personally identify the visitor as an individual through any personal data for the respective individual.
We use the information we collect:
• To provide you the services either directly or through third party service providers.
• We may share certain data on aggregated level for marketing purposes etc., which does not include any personal information.
• In addition, REWARDS LABS may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with REWARDS LABS’s rights or property, other Website or Application users or anyone else that could be harmed by such activities.
• Deleting your information. Upon user’s request, REWARDS LABS will delete any personal data regarding the respective user. In such case, your account at REWARDS LABS will be terminated. Bulgarian applicable laws and regulations may require that we store questions or submissions for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.
• Altering Information. REWARDS LABS may alter, modify or delete any information you submit to the Website or through the Application if it believes, in its sole discretion, it is necessary or desirable to do so.
• Request to stop receiving emails from us. Periodically, REWARDS LABS may send you emails to alert you to various opportunities or offers available at the REWARDS LABS Website or within the Application. If you do not wish to receive any of these offers, please send an e-mail to email@example.com to remove yourself from our mailing list.
Do Not Track Notice - REWARDS LABS does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, Chrome, Firefox, Safari, Opera and Internet Explorer browsers allow you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked.
Security – the information you provide is stored with the necessary security measures and preventions, according to the European and Bulgarian legislation. REWARDS LABS makes all reasonable efforts to prevent any unauthorized access or disclosure of personal data.
Links – the website may contain links which are owned by affiliated partners or third parties, we are unable to control them and how they use the information you may provide through them. We are not liable and cannot be held responsible for any images, text, content, etc. of such third parties’ websites.