Last Modified: 2/28/2020
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:
- Your name
- Your contact information
- Details about your relationship with the Program Sponsor
- Purchases and redemptions of catalog items you make using the Rewards Programs
- Content like posts, comments, photos, videos
- Other information that you create and submit or that other Participants create and submit about you
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:
- Information about the devices you use to access the Rewards Programs (like the IP address, device type, operating system, web browser type, and mobile network information)
- Anonymous information regarding your access to and use of the Rewards Programs, such as:
- Traffic data and logs, Actions taken when using the Rewards Programs (such as searches, likes, page views and navigation patterns), Dates and times of usage, Duration of use of the Rewards Programs (including whether you are a repeat or first-time participant)
- Demographic information, as well as data from voluntary, anonymous research surveys.
- Other information as required by a Program Sponsor
Website Usage Information
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)
Not Child Directed
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.
How We Respond to Do Not Track Signals
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.
EU-U.S. Privacy Shield
WHAPPS LLC complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. WHAPPS LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
Where there is transfer of personal data of EU individuals to third parties, we expect such third parties to restrict their access, use, and disclosure of such personal data in a manner consistent with our Privacy Shield obligations. If any such third party fails to comply, we may have liability to the extent we are responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should contact us at firstname.lastname@example.org.
We have further committed to cooperate with the panel established by the EU Data Protection Authorities (“DPAs”) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of an employment relationship. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of the EU DPAs are provided at no cost to you. You may also contact us to be directed to the relevant contacts.
If you have a privacy or data use concern that we have not addressed to your satisfaction, you may contact JAMS, our U.S.-based third-party dispute resolution provider. Visithttps://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint. The services of JAMs are provided at no cost to you.
As further explained in the Privacy Shield Principles, a binding arbitration option is available to you in order to address residual complaints not resolved by any other means. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
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.
Privacy Statement – California
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:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.hornellp.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts and other notices concerning our products or services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
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:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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 the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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:
- Calling us at 888-826-0783
- Visiting online-rewards.com/privacy
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:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
WHAPPS LLC (dba Online Rewards)
2435 North Central Expressway
Richardson, TX 75080