USER PRIVACY POLICY – RWRD

The RWRD mobile application (“App”) is provided by RWRD Ltd. (‘we’,‘us’ or ‘our’). We are committed to protecting and respecting the privacy of users of the App (‘you’ or ‘your’). This privacy policy (‘Privacy Policy’) sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data.

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/. 

Information we may collect and process from you

We may collect and process the following information from you in accordance with data protection legislation in the UK:

Registration details including name & email

Information about your use of the app including redemptions and other information that you give us.

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 team@rwrd.co.uk.

Retention of your Personal Data

RWRD Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and will delete data when your profile is deleted. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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.

Security of Data

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.

Use of data

RWRD Ltd uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues

Cookies and similar technology

Our App and services use cookies or similar technology to collect information about your access to the App and services.

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. 

Functionality cookies

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:

Collecting statistical information about how our users use the App so that we can improve the App and services.

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.

Disclosure of Information

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:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Overpass Ltd
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

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 access personal data held about you.
  • to request us to make any changes to your personal data if it is inaccurate or incomplete.
  • to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances.
  • to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means.
  • to object to, or restrict, our processing of your personal data in certain circumstances.
  • to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you.
  • to lodge a complaint with a data protection supervisory body, which at present, is the Information Commissioner’s Office.

​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 team@rwrd.co.uk 

​Service Providers

​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.

Data

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;

GDPR

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”

Geolocation

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 .

In this privacy policy, unless the context requires a different interpretation:
a. the singular includes the plural and vice versa;
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
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;
f. the headings and subheadings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of RWRD Ltd. and Users with respect to our RWRD app. It does not extend to any websites that can be accessed via the App’s notifications.

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 Privacy Policy

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

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

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.

​Children’s Privacy

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 team@rwrd.co.uk. 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.

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Any changes we may make to this Privacy Policy will be notified and made available to you using the App, where appropriate. By continuing to use the App, you are accepting any changes made to this Privacy Policy. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

​Contact

All questions, comments and requests regarding this Privacy Policy should be addressed to team@rwrd.co.uk