OUR SERVICES: We build Rewards Programs including Employee Rewards, Business to Business, Channel Incentives, Wellness Programs, Consumer Programs, Rebate Programs and others. We refer to these collectively as “Rewards Programs.”
PARTICIPANTS: Any employee, customer, partner or other individual invited to join a Program Sponsor’s Rewards Program that we manage on their behalf is referred to as a “Participant” or “You.”
We respect your privacy and want to ensure you are aware of our practices as they pertain to your personal information that may be captured and stored in our Rewards Programs.
INFORMATION WE COLLECT
We may collect and store personal information about you to deliver and improve the Rewards Programs. This includes information provided to us by you, by a Program Sponsor or by other Participants that can uniquely identify you, such as:
If you make a purchase when using the Rewards Programs, a third-party payment processor may collect your payment card or bank account number, payment card expiration date, security code, and other payment details, as well as other personal information in order to complete your purchase.
We may collect and store data that is relevant to the operation of a Sponsor’s Rewards Program but not generated through the use of the Rewards Program such as purchases, toll records, health and wellness activities or other data type as required to support the operation of a Sponsor’s Rewards Program.
If you access the Rewards Programs on a mobile device and your mobile device’s settings allow it, we may collect information about your location. Please see the “Your Choices” section below for details on how to limit the location information we collect when you access and use the Rewards Programs on a mobile device.
We may conduct surveys at the request of and for the benefit of a Program Sponsor. We may also conduct surveys for marketing and data research purposes, where we analyze the answers in aggregate. We may request contact details if we need to verify or validate answers.
The information we collect may include, without limitation:
A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, is used to transmit information about actions of the user opening the page or email containing the beacon back to a web server. We, and our affiliates, may use web beacons throughout the Rewards Programs, including on websites, emails, advertisements on other websites, or our own advertisements. We may utilize web beacons to measure participant behavior, to help us improve the participant experience, and to manage website content.
HOW INFORMATION IS USED
We use the information we collect to manage our Program Sponsors’ Rewards Programs. We may contact you to provide customer support or to respond to your questions and comments. We may use the information to issue awards, process orders and send notifications in Rewards Programs. We also may contact you to send messages and other information on behalf of Program Sponsors, inquire about your interest in other Rewards Programs or special offers, to facilitate reward redemption, and to inform you about new products or other information relevant to a Sponsor’s Rewards Program. We may disclose your personal information to our contractors, service providers, suppliers and other third parties in order to provide the Rewards Programs to you. We expect our third-party service providers to use the information strictly for the purpose of processing your request or delivering products or Rewards Programs you have requested.
We use data collection tools to facilitate the Rewards Program requirements as specified by Program Sponsors and help provide you with a positive experience in the Rewards Programs. We use the data to analyze trends and statistics regarding your use of the Rewards Programs and transactions conducted on the Rewards Programs, to prevent fraud and unauthorized transactions, to meet the needs of Program Sponsors, to enforce our End User License Agreement, and other agreements, and to comply with applicable laws and industry standards.
We may disclose your personal information to: a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets, if the information is publicly available; if we believe it is necessary or appropriate to protect the rights, property, or safety of WHAPPS, users of our Rewards Programs, or others; or if required by any lawful request from public authorities, including national security and law enforcement agencies.
We do not share, sell, rent, or trade your personal information with third parties for their promotional purposes. We may disclose aggregated information about our participants, and other information that does not personally identify any specific participant, without restriction.
Any personal information collected about participants while engaging in the Rewards Programs may be processed in the United States or outside the United States by us or by parties acting on our behalf. If you provide your personal information to us through the Rewards Programs, you consent to the processing of your data in the United States and in other countries. The Rewards Programs are hosted in the United States. For more information about jurisdictional data transfer mechanisms, contact firstname.lastname@example.org.
Visit www.allaboutcookies.org for further information about disabling cookies. If you choose to decline cookies, the functionality of the Rewards Programs that depend on cookies may become unavailable.
If you receive an email from us about new products or Rewards Programs, you may notify us to remove you from our email list by clicking the “UNSUBSCRIBE” link at the bottom of the email or by sending an email with “UNSUBSCRIBE” in the subject line to email@example.com explaining your desire to no longer receive communications and providing the address (email and/or physical) to be removed.
If you do not want us to capture and use your location information, you may disable the location features of your mobile device or choose not to use our mobile applications.
ACCESS AND CORRECTION
If the information that we maintain about you in connection with a Rewards Program is inaccurate, or if you would like to update or review your information, please contact the Program Sponsor. They will make the changes directly or contact us to correct, amend, or delete information that is inaccurate. In any other case where you would like to review or update your information, please send a detailed request with the correct information to our Data Protection Officer at firstname.lastname@example.org.
You will need to provide sufficient identifying information, including your name and address. We may request that you provide additional identifying information to confirm your identity and satisfy information security concerns. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances. Where warranted, we may charge a reasonable fee for access to personal information.
HOW INFORMATION IS RETAINED AND SECURED
We retain information as long as it is necessary and relevant for our operations. Additionally, we retain personal information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce the End User License Agreement, and perform other actions permitted by law.
We employ industry standard security practices designed to protect the security of personal information submitted through the Rewards Programs. We are not responsible for the acts of those who gain unauthorized access and we make no warranty that we will prevent unauthorized access to your private information. Additionally, the security of information transmitted through the Internet can never be fully guaranteed. We receive personal information via the Internet in encrypted format when possible. We are not responsible for interception or interruption of any communications through the Internet or for changes to or losses of data resulting from Internet transmission. We do not ensure the confidentiality, integrity, or availability of the information from a Rewards Program after it is accessed by the Program Sponsor to whom that portion of the Rewards Programs is dedicated, nor can we control how Program Sponsors will use your information.
You are responsible for maintaining the security of any password, user ID, or other form of authentication used to obtain access to protected or secure areas of the Rewards Programs. In order to protect you and your data, we may suspend your use or access to any of the Rewards Programs, without notice, pending an investigation, if any breach of security is suspected. Access to and use of protected and/or secure areas of any of the Rewards Programs is restricted to authorized users only. Unauthorized access to protected and/or secure areas is prohibited and may lead to criminal prosecution.
LINKED SERVICES (THIRD PARTY SERVICES)
We do not purposefully collect personally identifiable information about children under the age of 13. If you are under the age of 18 (but at least 13 years of age), you may only use the Rewards Programs under the supervision of a parent or legal guardian who agrees to be bound by the End User License Agreement. Children under the age of 13 may not use the Rewards Programs, and parents or legal guardians may not agree to the End User License Agreement on their behalf.
Some Program Sponsors may choose to configure the Rewards Programs to allow minor employees to post user-generated content through the Rewards Programs. In such cases, minors may modify and delete their user-generated content at any time with the same service used to create it. Users may also contact email@example.com for assistance with removing user-generated content. Removal of user-generated content does not ensure complete or comprehensive removal of that information from the Rewards Programs.
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) include a “Do Not Track” (DNT) or similar feature that signals to digital services that a participant does not want to have his/her online activity tracked. If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can prevent that digital service from collecting certain personal information about the participant. Not all browsers include a DNT option and DNT signals are not yet uniform. Therefore, we do not respond to DNT signals. Visit http://allaboutdnt.com for more information about DNT signals.
GDPR stands for the “General Data Protection Regulation,” and is effective as of May 25, 2018. GDPR replaces national privacy and security laws that previously existed within the EU with a single, comprehensive EU-wide law that governs the use, sharing, transfer and processing of any personal data that originates from the EU.
Our policy is to respect all laws that apply to our business and this includes GDPR. We also appreciate that Program Sponsors have requirements under GDPR that are directly impacted by their use of our Rewards Programs.
To ensure our compliance with GDPR, we have committed to:
Ensuring our Services are SOC2 certified, with annual certifications beginning in 2018. Ensuring the appropriate data transfer mechanisms are in place as required by GDPR when data is being transferred outside of the EU.
Assisting our clients, insofar as possible, to respond to data subject requests our clients may receive under the GDPR.
WHAPPS LLC complies with certain legal frameworks relating to the transfer of data from the European Economic Area and the United Kingdom to the United States. When WHAPPS LLC engages in such transfers, WHAPPS LLC relies on Standard Contractual Clauses as the legal mechanism to help ensure your rights and protections travel with your personal information. SCCs are contractual commitments between companies transferring personal data, binding them to protect the privacy and security of such data. WHAPPS LLC adopted SCCs so that the necessary data flows can be protected when transferred outside the EU and UK to countries which have not been deemed by the European Commission to adequately protect personal data, including protecting data transfers to the United States.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).|
|A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.|
|Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|D. Commercial information.|
|Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.|
|Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.|
|F. Internet or other similar network activity.|
|Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.|
|Physical location or movements.|
|H. Sensory data.|
|Audio, electronic, visual, thermal, olfactory, or similar information.|
|I. Professional or employment-related information.|
|Current or past job history or performance evaluations.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).|
|Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.|
|K. Inferences drawn from other personal information.|
|Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have not sold any personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
Deletion Request Rights
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:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
WHAPPS LLC (dba Online Rewards)
2435 North Central Expressway
Richardson, TX 75080