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SoLoyal Privacy Policy

Welcome to SoLoyal- an application that manages your loyalty memberships at your favorite retailers (the “App” or “Service”). The Service is owned and operated by SoLoyal Ltd. (“we”, “us”, “our”, “SoLoyal”, the “Company”),

This Privacy Policy (the “Policy”) explains the privacy practices for our Service and for information collected via our Service and website (https://www.soloyal.co) (the “Website”). It also describes the rights and options available to you with respect to your information. 

This Policy is incorporated to the Service’s Terms of Service (https://www.soloyal.co/terms) and constitutes an integral part of them.

PERSONAL DATA WE COLLECT

IN GENERAL TERMS

We collect the following information from visitors of our Website and users of our Service. This is also the information we have collected in the past 12 months.

Categories of Personal Information

Specific Types of Personal Information Collected

Identifiers

Name, email address, telephone number, address information, and any information you provide when enrolling in a new loyalty program.

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Information you provide when enrolling in a new loyalty program.

Commercial information

Bank statements (if you choose to provide it to us)

Geolocation data

Your location (if you choose to provide it to us)

Internet or other electronic network activity information

Your browser type, operating system, IP address, domain name, number of times you visited the Website and Service, dates you visited the website and Service, date and time of an online request, the time required to download information you requested, error codes generated while your browser is in contact with our website and Service and the amount of time you spent viewing the website.

IN MORE DETAIL

 

Registration. The Service is available to registered users only. Upon registering to the Service, you will be required to provide us with your email address. You may also register via your Facebook or Google accounts, in which case we will collect your Facebook or Google credentials. You may also choose to share with us your credit card transactions and/or location data. You do not have to share this information in order to use the Service; however, if you choose not to share this information, certain features of the Service will not be available to you. We refer to this data as “Registration Information”.

Loyalty Program Information. When you enroll in a new loyalty program you will be asked to provide information as required by the retailer’s loyalty program. We will then store your username and password to the loyalty program you enrolled in order to track your benefits and rewards from such program and to easily enroll you in new programs in the future. We refer to this data as “Loyalty Program Information”

Inquiry Information. When using our Website, you can submit an inquiry through our online contact form. When contacting us, you will be asked to provide information such as your name, email address, and the subject of your inquiry. We refer to this entire data as “Inquiry Information”.

When you are using the Service and Website, we will record and collect certain information in relation with your use of the Service and your interaction with our App and Website, including IP address (and the general location corresponding to the address). We refer to this entire information as “Analytical Information”.

HOW WE USE PERSONAL DATA

IN GENERAL TERMS

The following are the business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided above. More details about the business or commercial purposes are provided below.

Categories of Personal Information

Business or commercial purposes pursuant to the CCPA

Specific purposes

Identifiers

Information that identifies, relates to, describes, or is capable of being associated with, a particular individual

Providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments

Financial information

Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, providing analytic services, or providing similar services on behalf of the business or service provider.

Geolocation data

To provide the Service to you;

To verify your identity:

To communicate with you;

To improve our Services and prevent fraud.

Internet or other electronic network activity information

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, prosecuting those responsible for that activity

Undertaking internal research for technological development and demonstration

Undertaking activities to verify or maintain the quality of the service and to improve, upgrade or enhance the service

Debugging to identify and repair errors

Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, providing analytic services, or providing similar services on behalf of the business or service provider.

IN MORE DETAIL

We use Registration and Loyalty Program Information to verify your identity, and enable you to access the Service, to operate it and provide you its features and functionality. We also use it to facilitate our internal managerial, archival, administrative and audit activities. Providing us with the Registration Information is necessary also to help us prevent users’ fraudulent and unlawful uses of the Service.

We also use your Registration and Loyalty Program Information to enable you to use the Service, and to provide you with its core purpose, features, and functionality. We use your credit card transactions Information to analyze your transactions and provide you with recommendations for loyalty programs that we feel you might like to  join. We use your location information to offer you to enroll in loyalty programs based on your location. We use your Loyalty Program Information to track your benefits and rewards and to easily enroll you to new loyalty programs.

We use your Registration and Inquiry Information to provide you customer support and handle your inquiries effectively.

We may use your Inquiry, Registration and Loyalty Program Information to send you marketing messages relating to the Service. Where required by applicable law, we will obtain your consent to receive such communications from us. You may revoke your consent or opt-out of receiving such communications at any time by contacting us via our online contact form available at https://www.soloyal.co/contact or via the Unsubscribe link enclosed in any marketing communication you will receive from us.

We use Analytical Information to understand how users interact with the Service so that we can further improve, develop and enhance it. We also use Analytical Information to adjust the Service and our email communications to users’ preferences. We will use Analytical Information to understand the market in which we operate in and for managerial reporting and business planning. When we process Analytical Information, we will not be able to identify the person who uses the Service – hence, the user will stay anonymous and unidentifiable.

WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent. These are also the categories of third parties with whom we have disclosed personal information in the preceding 12 months.

We will handle your personal information with the assistance of our service providers and marketing consultants, who help us with the internal operations of our App and Website and our marketing efforts. These companies are authorized to use your personal information only as necessary to provide these services to us and not for their own promotional purposes.

We will share your information with the relevant authorities if we are obligated to so by law.

We may share your information with the relevant authorities and with third parties (such as legal counsels and advisors), if necessary to defend SoLoyal from legal claims or if you have breached the Terms of Service (https://www.soloyal.co/terms), this Policy or any other agreement you have with us, for the purpose of handling of the violation or breach.

If the operation of the Service or Website is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration.

We do not sell your personal information and have not done so in the preceding 12 months.

COOKIES

Cookies and log files may be used on our App and Website to enhance User experience. A cookie is a small text file written to an individual’s hard drive that contains the user ID. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browser to refuse cookies, or to alert them when cookies are being sent. If they do so, note that some parts of the App and Website may not function properly. By using our App or Website, you acknowledge and consent to the use of cookies on your device.

We use cookies for a number of purposes, as briefly explained below:

Necessary. Cookies that are strictly necessary for the functioning of the App. The App cannot operate properly without these cookies. You can set your device to block or alert you about these cookies, but some parts of the App may not function properly.

Localization. Cookies that help us direct user traffic to the appropriate local version of our App.

Statistics. Analytics cookies that help us understand how you and other users interact with our App by collecting data that does not directly identify you.

INTERNATIONAL DATA TRANSFER

The Service, by its nature as an online service, may store and process information and content in various locations throughout the globe, including through cloud services. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you provide your express and unambiguous consent to such cross-border transfer.

Information we collect from you will generally be processed in the U.S. If we transfer information to other jurisdictions outside the U.S., we will do so using adequate safeguards determined by applicable data protection laws.

SECURITY AND DATA RETENTION

We retain personal data for the duration needed to support our ordinary business activities operating the Service and Website and interacting with users. Thereafter, we will continue to retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our Terms of Service, this Policy and other agreements we have with our users.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

YOUR RIGHTS AS A CALIFORNIA RESIDENT UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

You have the right to know: the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting personal information; the categories of third parties with whom we share personal information, if any; the specific pieces of personal information we have collected about you.

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

    • Delete your personal information from our records; and
    • Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

    • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
    • Debug to identify and repair errors that impair existing intended functionality;
    • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
    • Comply with the California Electronic Communications Privacy Act;
    • 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
    • Comply with an existing legal obligation; or
    • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

    • Deny goods or services to you;
    • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
    • Provide a different level or quality of goods or services to you; or
    • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

If you would like to exercise any of your CCPA rights as described in this Privacy Policy, please:

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.

MINORS

The Service is not intended for minors under the age of 18. We do not knowingly or intentionally collect information about minors under the age of 18. IF YOU ARE UNDER THE AGE OF 18 YOU MAY NOT USE THE SERVICE.

CHANGES TO THIS PRIVACY POLICY

From time to time, we may change this Policy, in which case we will inform you of the updated Policy through the Service’s interface or via the email address you provided us. The latest version of the Policy will always be accessible through the Service.

CONTACT US

Should you have any inquiries, complaints or suggestions, you may contact us at [email protected] We will do our best to resolve your issue in a timely manner.

Last Update: 5 February, 2020.