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Reward Gateway (USA) Inc (“we”, “us” or “our”) is committed to upholding your
privacy and respect your rights under the Privacy Act 1974 and other applicable
laws.

This Privacy Notice ("Notice") describes how any personally identifiable
information (“PII”, “personal information”) we collect from you or from third
parties, including MRO Corp (the “administrator”) who we have entered into a
License Agreement with, about you on this website (the “portal”, “PROPS”) will
be processed by us.

In the event of a conflict between the terms of this Notice and the terms of the
License Agreement, the License Agreement shall prevail.


THE TYPE OF INFORMATION WE COLLECT FROM YOU AND HOW WE USE IT

We will collect various types of personal information from you when you use
PROPS, depending on the services which you use. Further details of how we use
your personal data are set out below.


BEFORE YOU REGISTER

The administrator has provided us with your information for an account to be
created.


WHEN YOU LOGIN

Each time you log in to PROPS, we automatically conduct checks against your
Internet Protocol (IP) address to ensure your security. This includes looking up
your IP address against a “proxy denylist” to check that someone is not using
your credentials and trying to hide their location. This proxy denylist is
operated by MaxMind, Inc. If your IP address appears on it, we will not allow
you to login.

We also look up the IP address in a static database we download from MaxMind
Inc. to check which country the IP is affiliated with. This helps us to further
protect your account against people who may have access to your credentials. If
we do spot a change, we will alert you and ask you to confirm your login in
order to verify your identity before continuing.

This information along with time and event data (such as successful or failed
logins) are also recorded in our database for audit purposes.

Depending on the services you use on PROPS, we may collect and process
additional PII about you, as set out below.


WHEN YOU SEND AN ECARD OR WHEN YOU MAKE A NOMINATION

If you ask us to send an eCard, you will need to provide us with the name of the
person you are sending the eCard to (“the recipient”). If the recipient has
already registered on PROPS, we will send the eCard on your behalf to their
registered email address.

If they have not already registered, you will also need to provide an email
address which we will send the eCard on your behalf to. The recipient will be
asked to confirm that they have read and understood this notice and agree to our
Terms & Conditions before being able to view your message.

You must have the consent of the recipient to give us their name and, if
applicable, email address and any personal information you disclose in your
message to them. This information will also be disclosed to the administrator
for the purposes of performance management.


WHEN YOU WRITE A BLOG OR COMMENT / REACT TO CONTENT

When you write a blog or comment / react to content on the site, we will collect
your name and any other personal information you choose to share via your blog
or comment. This information will be visible to us and other users of the portal
but will not be used for any other purpose.


WHEN YOU COMPLETE A SURVEY

If you complete a survey, all of the information that you provide will be
provided to the administrator. Please be aware that the administrator controls
the survey and what happens to the survey data, which may include using that
data for research purposes or making the survey responses public.

We recommend that you contact the administrator to understand how they will use
your survey responses. The administrator may decide to provide you with their
own separate privacy Notice governing the use of your survey data.


WHEN YOU CONTACT US

If you contact us for support purposes, we will require some information to
handle your query. The following data are saved in Zendesk to enable processing:
your name, email address, telephone number, and any other personal information
you provide to us for the purpose of dealing with your query.


WHEN YOU VISIT PROPS

When you visit PROPS we will automatically collect information about your visit,
such as the pages you viewed, offers or services you viewed or searched for,
length of visits to certain pages, the times and dates of these actions, details
of page response times and any download errors that occurred.

We will also collect data from the device and application that you use to access
our services, including your IP address (from which we may infer your geographic
location), login information and browser type.

If you arrive at our website from an external source (such as a link on another
website or in an email) we record information about that source.

We will use the above information in order to:

 * to administer PROPS and for internal operations, including troubleshooting,
   data analysis (including analysing the use of the various services available
   on PROPS and measuring their popularity and effectiveness), testing,
   research, statistical and survey purposes, and to comply with our legal
   obligations;
 * to improve PROPS to ensure that content is presented in the most effective
   manner for you and for your computer / device;
 * as part of our efforts to keep PROPS safe and secure to comply with our legal
   obligations;


OTHER INFORMATION AND USES

We will also collect the PII you provide when you use PROPS:

 * To notify you about changes (permanent or temporary) to our service.
 * To ensure that content from our website is presented in the most effective
   manner for you and your computer.
 * To administer our website and for internal operations, including
   troubleshooting, data analysis, testing, research and statistical purposes,
   and as part of our efforts to keep our website safe and secure.


INTERACTION WITH CHILDREN ONLINE

We do not knowingly collect personal information on children. The content of our
website and the products and services available are not intended for, or
directed to, children. If you are under 13 years of age, then please do not use
or access our website at any time or in any manner.


INFORMATION WE RECEIVE FROM OTHER SOURCES

We will combine information we receive from other sources (as set out in this
Notice) with information you give to us. We will use this information and the
combined information for the purposes set out in this Notice (depending upon the
services you access).


CHANGE OF PURPOSE

We will only use your personal information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose and permitted
under applicable laws. If we need to use your personal information for an
unrelated purpose, we will notify you and we will explain the legal basis which
allows us to do so.


DISCLOSURES OF YOUR INFORMATION

We use service providers to help us to provide the website, such as data storage
providers, marketing email providers, analysis providers and benefit providers:

 * Amazon Web Services EMEA SARL, a cloud hosting provider;
 * Emailcenter UK, a transactional and bulk email gateway;
 * Google Inc., a web analytics tool;
 * FullStory Inc., an analytics service provider;
 * Heap, Inc., an analytics service provider;
 * New Relic Inc., a performance measurement tool;
 * Twilio Inc., a SMS / text-messaging gateway;
 * Formstack, LLC, a configurable data-capture provider;
 * Zendesk Inc., a customer support platform;
 * Atlassian Pty Ltd., a ticketing system for our internal teams;
 * Mailgun Technologies Inc., a transactional and bulk email gateway;
 * WalkMe, Inc., Contextual help, support and assistance for administrators.

We also share your personal information with:


THE ADMINISTRATOR

Because the administrator pays us to operate PROPS for you, they’ll want to know
how the website is performing. Except as set out elsewhere in this Notice, we
will only share information with the administrator on an aggregated and
anonymous basis about how often you’ve used the website and what services you
used.


OUR INTERNAL TEAMS

We also use information about you on an aggregated and anonymized basis for
internal management purposes. This type of information includes, for example,
the number of activities you complete. However, you can’t be identified from
this information.


MEMBERS OF OUR GROUP

We share personal information with members of our group for the purposes of
providing the benefits to you and managing our business: RG Engagement Group
Ltd, Reward Gateway Pty Ltd, Reward Gateway (USA) Inc, Reward Gateway (UK) Ltd
Branch, International Benefits Holdings Ltd., Asperity Employee Benefits Group
Ltd


OTHER PARTIES

We will also disclose your personal information to third parties:

 * in the event that we sell or buy any business or assets, in which case we
   will disclose your personal information to the prospective seller or buyer of
   such business or assets;
 * if we or substantially all of our assets are acquired by a third party, in
   which case PII held by us about our customers will be one of the transferred
   assets; and/or
 * if we are under a duty to disclose or share your personal information in
   order to comply with any legal obligation, or in order to enforce or apply
   our Terms and Conditions and other agreements; or to protect the rights,
   property, or safety of us, our users, customers and providers. This will
   include sharing your personal information as part of a legal or official
   investigation if we have evidence or reason to suspect that purchases on your
   account could be fraudulent.


TRANSFERS OF YOUR INFORMATION

Your information, including PII, may be transferred to — and maintained on —
computers located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ than those from your
jurisdiction.

We will take all steps reasonably necessary to ensure that your data is treated
securely and in accordance with this notice, and applicable law, and no transfer
of your personal information will take place to an organization or a country
unless there are adequate controls in place including the security of your data
and other personal information.

We remain fully accountable for these transfers.


YOUR CHOICES


CALIFORNIA PRIVACY RIGHTS

Under California law you are entitled to certain rights and disclosures. Please
read our California Privacy Policy for more information.


RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA)

If you are located in the EEA, applicable EU and Member State data protection
laws provide certain rights to you. These include the rights to:

 * Request details about the personal data that we process, and obtain a copy of
   the data that we hold about you;
 * Correct or update your personal data;
 * Port personal data that has been provided by you, in machine readable format,
   to another supplier
 * Erase the data that we hold about you in some cases;
 * Restrict processing in some cases;
 * Object to processing based on grounds relating to the individual’s particular
   situation, where the processing is based on legitimate interest;

These rights are not absolute and are subject to various conditions under
applicable data protection and privacy legislation and the laws and regulations
to which we are subject.

We will only collect personal information from you where we need the personal
information to enter into a contract or perform a contract with you (e.g. to
provide you with a service), where the processing is in our legitimate interests
when your interests and fundamental rights do not override those interests,
where we have your consent, or where we have a legal obligation to collect and
process personal information.

Where the provision of data is necessary to enter into a contract with us or for
us to perform a contract with you and you choose not to provide the information
we will not be able to provide our services to you.

You have the right to object to the processing of your personal information
where we are relying on a legitimate interest (or those of a third party), which
is not overridden by your data protection interests or fundamental rights and
freedoms. In particular we process your personal data to pursue the following
legitimate interests:

 * To prevent fraud on our platform;
 * To provide reporting and analytics;
 * To provide troubleshooting, technical support, or to answer questions;
 * To trial new features or additional services; and
 * To help improve our services, applications, and websites.

Where we rely on your consent to process your personal data, you may decline to
give your consent, or withdraw your consent for that specific processing at any
time.

In some cases, we may also have a legal obligation to collect personal
information from you.

If you have questions about the legal basis on which we collect and use your
personal information or if you wish to assert your rights, please contact us
using the contact details provided under the “Contact Us” section below.

You will not have to pay a fee to access your personal information (or to
exercise any of the other rights above). However, we may charge a reasonable fee
if your request for access is manifestly unfounded or excessive. Alternatively,
we may refuse to comply with the request in such circumstances.

We or the administrator may need to request specific information from you to
help us confirm your identity and ensure your right to access the information
(or to exercise any of your other rights). This is a measure to ensure that
personal information is not disclosed to any person who has no right to receive
it.

Please know that you also have the right to submit a complaint concerning our
processing of your personal data to the appropriate supervisory authority.


RESOLVING YOUR PRIVACY CONCERNS AND COMPLAINTS

If you have a question or complaint about how your personal information is being
handled by us, our affiliates or contracted service providers, please contact us
using the contact details provided below.

Please note that as the administrator may store other information from your use
of this service, you should also contact them directly if you would like to
exercise your rights in relation to the data held by them.


UPDATING YOUR INFORMATION

It is important that the personal information we hold about you is accurate and
current. Please keep your records on PROPS up-to-date. If you wish to update or
amend your personally identifiable information or data you may do so by making
the change within your account once logged in or by contacting our Helpdesk. We
will respond to your request within 5 working days.


STORAGE OF YOUR INFORMATION

Unless we need to keep your data for legal purposes, we will only retain your
personal information for 60 days after the administrator lets us know you no
longer have a relationship with them or they decide to use a different service.

The legal purposes for which we may need to retain your data for include:

 * retaining payment records for one year to comply with PCI DSS regulations;
 * retaining backups for up-to 180 days after deprovisioning; and
 * retaining your order history for two years from the date of your order in
   case of a dispute.

We may also retain anonymized data about you for longer periods for integrity
and financial reporting purposes.

Recordings of calls are retained for 40 days and chat transcripts are retained
for 90 days.

We take the security and confidentiality of your personal information very
seriously. We will use strict procedures and security features to aim at
preventing unauthorized access, such as implementing ISO 27001 standards, access
controls, penetration testing, the use of encryption and hashing and robust
physical security controls.


CHANGES TO THIS NOTICE

Any changes we make to our Notice in the future will be posted on this page and,
where appropriate, notified to you by email. Please check back frequently to see
any updates or changes to our Notice.


CONTACTING US

If you have any queries, comments or requests regarding this Notice, or you
would like to exercise any of your rights set out above, or contact our Data
Protection Team, you can contact us in the following ways:

 * by email at privacy-requests@rewardgateway.net or;
 * by post at Reward Gateway (USA) Inc., 141 Tremont Street, Boston, MA 02111.

 * Home
 * Privacy
 * California Privacy Act
 * Cookie Policy
 * Terms & Conditions
 * Accessibility
 * Help
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