Privacy Policy

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in https://rewardy.io/pp and it is important that you read that information.

Before installation of this App or use of our Services through our App or Website, please indicate your consent to our processing of your personal data as described in the privacy policy.

How you can withdraw consent

If you change your mind after you signed in to our App, you may withdraw consent by contacting us at support@rewardy.io. This will not affect the lawfulness of any processing carried out before you withdrew your consent.

Introduction

This policy (together with our Terms and Conditions as set out at https://rewardy.io/tos (Terms) applies to your use of:

• The Rewardy app on the iOS or Android platforms, or our Website at https://rewardy.io (collectively referred to as the App).
• Any of the services accessible through the App (Services). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

[IMPORTANT INFORMATION AND WHO WE ARE]

[THE DATA WE COLLECT ABOUT YOU]

[HOW IS YOUR PERSONAL DATA COLLECTED?]

[HOW WE USE YOUR PERSONAL DATA]

[DISCLOSURES OF YOUR PERSONAL DATA]

[INTERNATIONAL TRANSFERS]

[DATA SECURITY]

[DATA RETENTION]

[YOUR LEGAL RIGHTS]

[GLOSSARY]

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]

Important Information and Who We Are

Rewardy is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this policy).

We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

• Full name of legal entity: Rewardy
• Data privacy manager’s email address: support@rewardy.io

You have the right to make a complaint at any time to the Swedish regulator for data protection issues.

Changes to the privacy policy and your duty to inform us of changes

It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto our Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

This website uses Pollfish web plugin. Pollfish is an on-line survey platform, through which, anyone may conduct surveys. Pollfish collaborates with Developers of applications for smartphones and website owners in order to have access to users of such applications/websites and address survey questionnaires to them. This website uses and enables Pollfish cookies. When a user connects to this website, Pollfish detects whether the user is eligible for a survey. Data collected by Pollfish will be associated with your answers to the questionnaires whenever Pollfish sents such questionnaires to eligible users. For a full list of data received by Pollfish through this website, please read carefully Pollfish respondent terms located at https://www.pollfish.com/terms/respondent By using this website you accept this privacy policy document and you hereby give your explicit consent for the placement of a Pollfish cookie in your system and the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by using the Pollfish “opt out section” available on Pollfish website or by disabling “third party cookies” from your browser’s settings. We once more invite you to check the Pollfish respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works.

Playtime (adjoe) is a third party feature that is integrated with our app. Playtime allows users to earn in-app currency by playing third-party games and collects devices' application usage from users. The processing of the data is necessary to recommend, via system messages, the installation of the app available in Playtime that matches users' interests and calculates the bonuses acquired as a result of users' use of the corresponding apps. For more information, please refer to Playtime (adjoe) Data Privacy.

The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.
• Contact Data.
• Financial Data.
• Transaction Data.
• Device Data.
• Content Data.
• Profile Data.
• Usage Data.
• Marketing and Communications Data.
• Location Data.

We explain these categories of data here below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How Is Your Personal Data Collected?

We will collect and process the following data about you:

• Information you give us. This is information you consent to giving us about you by filling in forms on the App, by logging in on twitch from our App, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, enter a competition, promotion or survey and when you report a problem. If you contact us, we will keep a record of that correspondence.
• Information we collect about you and your device. Each time you visit or use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy https://rewardy.io/cookie for further details.
• Location Data. We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
• Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Identity, Contact, Financial, Device, Transaction, Device and Location Data from your twitch account.
  • Device Data from the following parties:
    • analytics providers such as Google;
    • advertising networks such as Google AdMob; and
    • other providers such as Fyber.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  • Identity and Contact Data from data brokers or aggregators; and
  • Identity and Contact Data from publicly available sources.
• Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the App, the distribution platform (Appstore) or Services and to remember your preferences. This helps us to provide you with a good experience when you use the App and also allows us to improve the App. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How We Use Your Personal Data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

• Where you have consented before the processing.
• Where we need to perform a contract we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

We will only send you direct marketing communications by email if we have your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	Identity Contact Financial Device	Your consent
To process in-App purchases and deliver Services including managing payments and collecting money owed to us	Identity Contact Financial Transaction Device Marketing and Communications Location	Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you including notifying you of changes to the App or any Services	Identity Contact Financial Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To enable you to participate in a prize draw, competition or complete a survey	Identity Contact Device Profile Marketing and Communications	Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	Identity Contact Device	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	Identity Contact Device Content Profile Usage Marketing and Communications Location	Consent Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of Your Personal Data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties such with which we collaborate with for the purposes of providing you with the gift cards or offers.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our . Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International Transfers

Many of our external third parties are based outside of Sweden so their processing of your personal data will involve a transfer of data outside Sweden.

Whenever we transfer your personal data out of Sweden, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved by Sweden which give personal data the same protection it has in Sweden.

Data Security

All information you provide to us is stored on secure servers in the United States. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data Retention

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (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.

In the event that you do not use the App for a period of 90 days then we will treat the account as expired and your personal data may be deleted.

Your Legal Rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us via email.

Glossary

1.1 Lawful Basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

1.2 Third Parties

1.3 Internal Third Parties

Persons in the company who provide [IT and system administration services and undertake leadership reporting].

1.4 External Third Parties

Service providers who provide IT and system administration services.

Professional adviser including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

1.5 Your Legal Rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Description of Categories of Personal Data

• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, Country, email address and telephone numbers.
• Financial Data: bank account and payment card details.
• Transaction Data: includes details about payments to and from you and details of in-App purchases.
• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
• Content Data: includes information stored on your Device, including friends' lists, login information, photos, videos or other digital content, check-ins and persons you follow.
• Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses and your twitch profile data including your twitch username, email, twitchId, a list of who you follow, first login date (registration), device information, geolocation and IP address.
• Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise [and the resources that you access.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data: includes your current location disclosed by GPS technology.