Last modified: August 29, 2021

INTRODUCTION

RewardUp Inc. and our affiliates and subsidiaries (“Company” or “We” or“Our”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of the merchants who use our services (the “Merchants”) and end users who use and enjoy the rewards programs offered through our Website and/or mobile applications (the “End Users”) (the Merchants and the End Users shall hereinafter collectively be referred to as “you”).
• Describes the types of information we may collect from you or that you may provide when you visit the Website and/or mobile applications https://rewardup.com (our “Website and/or mobile applications”) or when you access our services through our mobile application or web application embedded by API into sites, payment devices, plug-ins or other software owned and managed by third parties (“ThirdParty Website and/or mobile applications”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

• On this Website and/or mobile applications;
• On our mobile and web applications
• Through Third Party Website and/or mobile applications; and
• In email, text, and other electronic messages.

The Website and/or mobile applications and/or mobile application may include links to Third Party Website and/or mobile applications, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a Third Party Website and/or mobile applications or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these Third Party Website and/or mobile applications, and we encourage you to read the privacy policy of every Website and/or mobile applications you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website and/or mobile applications or mobile applications. By accessing or using this Website and/or mobile applications and/or mobile applications, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Website and/or mobile applications and/or mobile applications after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. 

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information and any other identifier we may use to contact you (“personal information”). 
  We provide an opportunity for any user to unsubscribe from our services or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to support@rewardup.com.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website and/or mobile applications feature. 
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website and/or mobile applications, and usage details.
• Non-personal details about your Website and/or mobile applications interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website and/or mobile applications (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with youwhen you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 
• Automated technologies or interactions, as you navigate through our Website and/or mobile applications. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners or the Third Party Website and/or mobile applications in which our Widget is embedded.

Direct Collection of Information

The information we collect directly from you on or through our Website and/or mobile applications or Third Party Website and/or mobile applications may include:

• Information that you provide by filling in forms on our Website and/or mobile applications or Third Party Website and/or mobile applications. This includes, but is not limited to, information provided at the time of registering to use our Website and/or mobile applications or on Third Party Website and/or mobile applications, subscribing to our service, and/or requesting further services. We may also ask you for information when you report a problem with our Website and/or mobile applications or service.
• Records and copies of your correspondence (including email addresses and chat sessions), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and/or mobile applications or through Third Party Website and/or mobile applications. 

Merchants may also provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website and/or mobile applications, social media, or transmitted to End Users of the Website and/or mobile applications, or third parties (collectively, “Merchant Promotions”). Merchant Promotions are posted on and transmitted to others at Merchants’ own risk. We do not moderate the content of Merchant Promotions, so we cannot guarantee the content that will be viewed by the End User. Any concerns an End User may have about the content of a Merchant’s Promotion should be communicated directly to the Merchant. Additionally, we cannot control the actions of the End Users of the Website and/or mobile applications with whom the Merchants may choose to share Merchant Promotions. Therefore, we cannot and do not guarantee that unauthorized persons will not view Merchant Promotions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies

As you navigate through and interact with our Website and/or mobile applications, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website and/or mobile applications, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website and/or mobile applications.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and/or mobile applications and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website and/or mobile applications according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website and/or mobile applications.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website and/or mobile applications. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website and/or mobile applications. 
• Web Beacons. Pages of our Website and/or mobile applications and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website and/or mobile applications statistics (for example, recording the popularity of certain Website and/or mobile applications content and verifying system and server integrity). 

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website and/or mobile applications, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, payment systems, point of sale systems, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website and/or mobile applications. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Website and/or mobile applications and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. 

You can opt-out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada (https://youradchoices.ca/en/tools). You can also access these Website and/or mobile applications to learn more about online behavioural advertising and how to stop Website and/or mobile applications from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and/or mobile applications and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you about changes to our Website and/or mobile applications or any products or services we offer or provide though it.
• To improve our Website and/or mobile applications, products or services, marketing, or customer relationships and experiences.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails. 

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of RewardUp Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Rewardup Inc. about our customers and users is among the assets transferred.
• To those contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and/or mobile applications improvement and optimization) who need to know such personal information as a condition to performing their services on our behalf, and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To the extent you have obtained or redeemed a reward offered by a Merchant, added a Merchant as a membership to your account, made a purchase at or through a Merchant, or otherwise participated in any other activity sponsored or offered on behalf of the Merchant, we may provide your personal and transactional information to such Merchants (a) for the Merchant to redeem and validate your reward, send you customized offers, troubleshoot redemption, combat fraud and otherwise communicate with you; (b) as part of legal proceedings affecting the Company or the Merchant; or (c) to send you marketing information or otherwise facilitate a direct relationship between the Merchant and you.
• To any third parties for which our services are embedded by API into a Third Party Website and/or mobile applications (i.e., the delivery of data or usage statistics on a mobile application);
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use https://rewardup.com/terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website and/or mobile applications improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website and/or mobile applications or Third Party Website and/or mobile applications, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website and/or mobile applications may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies . 
• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to support@rewardup.com.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@rewardup.com.If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a purchase, product service experience, or other transactions.
  We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third-party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these Website and/or mobile applications to learn more about online behavioural advertising and how to stop Website and/or mobile applications from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use technological, procedural, physical, electronic, and administrative measures designed to (i) ensure the confidentiality, security, integrity and availability of your personal information; (ii) protect against any anticipated threats or hazards to the security and integrity of your personal information; and (iii) protect against any accidental loss and from unauthorized access, use, alteration, and disclosure. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website and/or mobile applications, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website and/or mobile applications. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website and/or mobile applications. 

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 

Without limiting the foregoing, we agree that we will permanently and securely delete any End Consumer data or Merchant data we have stored when a Merchant uninstalls or discontinues its use of our Website and/or mobile applications, and such Merchant or End User will be provided with a one hundred and eighty (180) days to obtain any such consumer data, Merchant data, or End User data, as applicable.

CHILDREN UNDER THE AGE OF 13

Our Website and/or mobile applications is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website and/or mobile applications. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website and/or mobile applications or on or through any of its features/register on the Website and/or mobile applications, make any purchases through the Website and/or mobile applications, use any of the interactive or public comment features of this Website and/or mobile applications, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@rewardup.com.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and/or mobile applications and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at support@rewardup.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account on our Website and/or mobile applications. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. While we can delete your personal information from our records and our Website and/or mobile applications, we cannot delete any of your personal information that has been sent to the Merchant. In order to have your personal information deleted from the Merchant’s records, please contact the Merchant directly with your deletion request.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• Information protected by solicitor-client privilege.
• Information that is part of a formal dispute resolution process.
• Information that is about another individual that would reveal their personal information or confidential commercial information.
• Information that is prohibitively expensive to provide.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@rewardup.com. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision. 

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website and/or mobile applications home page. 

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and/or mobile applications and this privacy policy to check for any changes.

FOR CALIFORNIA USERS

We do not sell your personal information and we comply with CCPA requirements; but RewardUp may use your personnel information in the following ways:

• We may use your information to update, secure, troubleshoot and provide support for our products. It also includes sharing data, when it is required to provide the service or carry out the transactions that you request.
• We may use your personal information to help authenticate you should you ever contact us for support.
• We may share information with companies including third party integration partners that provide support services to us (such as email or invoicing vendors) and that help us communicate to you on behalf of program owners. These companies may use information about you to perform their functions on our behalf.
• In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of our business assets, RewardUp may disclose personal information to those involved in the negotiation or transfer.
• We may contact you with special offers, promotions, and/or sales inquiries.
• We may also share aggregated or anonymized information that does not directly identify you.

DELETION REQUESTS 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service providers to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 
3. Debug products to identify and repair errors that impair existing intended functionality. 
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.). 
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. 
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 
8. Comply with a legal obligation. 
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request. 

To exercise your rights or to obtain more information, you may contact us: 

• By email at: support@rewardup.com
• By telephone at: (437) 290-5123

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at: 

RewardUp Inc.
Attn: Privacy Officer
1 Yonge St, #1801, Toronto, ON, M5E 1W7

support@rewardup.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.