For the purpose of data protection legislation in the UK, the data controller is RWRD Ltd., company registration no. 11501346, registered office Eden House, Reynolds Road, Beaconsfield, Bucks, HP9 2JL. Data is stored with Digital Ocean – see more at https://www.digitalocean.com/legal/privacy-policy/.
We may collect and process the following information from you in accordance with data protection legislation in the UK:
Registration details including name & email
Your information may be analysed to see how much you use the app, to understand your on app behaviour, and to send you information and offers for the products or services which we feel are most relevant to you. We may also use your information to generate aggregate data.
We are required to comply with certain legal and regulatory requirements, and may process your personal data for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject.
Note that if any of your personal details change during your use of the App, we request that you update them by accessing the relevant section of the App, or by contacting us at firstname.lastname@example.org.
RWRD Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
RWRD Ltd uses the collected data for various purposes:
Cookies are pieces of information that include a unique reference code that an app or a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to use our App and services and will last for longer.
We use the following categories of cookies on the App and in the provision of services to you, for the purposes set out below:
Essential session management cookies
These cookies are essential in order to enable you to use our App and use its features. Without these cookies, services you have asked for, cannot be provided to you. We use these cookies for ensuring you receive information relating to your use of the app.
These cookies allow our App to remember choices or selections you make around functionality features (such as your name or city) and provide enhanced, more personal features. We also use these cookies to remember changes you make to other parts of our App which you may be able to customise from time to time. The information we collect via these cookies may be anonymised and these cookies cannot track your browsing activity on other websites. We use these cookies for:
Customising elements of the promotional layout and/or content of the pages of the App for example by storing a location and/or country code and providing users with content relevant to their location and/or country.
Performance and measurement cookies
These cookies collect information about how visitors use our App and if they get error messages when using the App. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our App and services work. We use performance and measurement cookies in the following ways:
We employ Flurry analytics for the App. You can find more about Flurry analytics at https://www.flurry.com/
We employ Google analytics for the website, rwrdapp.com. You can find out more about Google analytics at https://analytics.google.com/analytics/
Some of the cookies used on our App are set by us and some are set by third parties who are delivering services on our behalf.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of our App or services.
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may disclose your personal information to third parties:
if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
As a result of us collecting and processing your information, you have the following legal rights:
To exercise any of your rights as set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at email@example.com
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Collectively all anonymised geolocation data collected by RWRD Ltd. via the “RWRD pp”. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws
Any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
The General Data Protection Regulation (EU) 2016/679;
Geo Targeted Engagement
Means a single instance of a Consumer receiving an electronic notification, typically on a handheld device, from either a Client or a Sub-Client, where such notification has been generated as a result of the use of the “App”
A Geofence or series of related Geofences defined and set utilising the “App”
User or you
Any third party that accesses the RWRD App and is not either (i) employed by RWRD Ltd. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to RWRD Ltd .
a. the singular includes the plural and vice versa;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. “including” is understood to mean “including without limitation”;
e. reference to any statutory provision includes any modification or amendment of it;
For purposes of the applicable Data Protection Laws, RWRD Ltd. is the “data controller”. This means that RWRD Ltd. determines the purposes for which, and the manner in which, location Data is processed
RWRD App has been developed and designed to ensure privacy with safeguards built into product structure, data collection and storage at point of design.
Once installed and prior to first use, the User is asked for their permission to allow location services
prior to RWRD Ltd. accessing or collecting location data and the User is able to disable location services at any time and the “App” will no longer provide notifications based on location.
We record the following data from a device with the RWRD App installed:
a. Installation Reference associated with a particular instance of a downloaded application;
b. geographic coordinates (longitude and latitude) associated with the triggered geofence
c. how the geofence was triggered i.e. on entry or exit
d. estimated accuracy with which the device is being located;
e. date and time the trigger was initiated;
f. make and model and operating system (and version) of the device;
8. Collected User Data is anonymised, encrypted and stored on secure servers
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact firstname.lastname@example.org. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.