Last updated on: 9 July 2019
Welcome to rewardSnap (referred to in these Terms as "we", "us", "our", and "rewardSnap"). We are a company incorporated in Hong Kong, with a registered office at 27/F, 256 Hennessy Road, Wanchai, Hong Kong.
Our Policy applies to all visitors, users, and others who access the Service ("Users").
Information we may collect from you
We collect the following types of information.
Information you provide us directly:
Your username, password and e-mail address when you register for a rewardSnap account.
Profile information that you provide for your user profile (e.g., first and last name, picture, phone number). This information allows us to help you or others be "found" on rewardSnap.
User Content (e.g., photos, comments, and other materials) that you post to the Service.
Correspondence where you contact us;
Communications between you and rewardSnap. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
Cookies and similar technologies:
Log file information:
Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.
When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by rewardSnap.
A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.
Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other's APIs then, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature) if your photo is made public by you in accordance with your privacy settings.
HOW WE USE YOUR INFORMATION
help you efficiently access your information after you sign in
remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
provide personalized content and information to you and others
provide, improve, test, and monitor the effectiveness of our Service
develop and test new products and features
monitor metrics such as total number of visitors, traffic, and demographic patterns
diagnose or fix technology problems
automatically update the rewardSnap application on your device
rewardSnap or other Users may run contests, special offers or other events or activities ("Events") on the Service. If you do not want to participate in an Event, do not use the particular Metadata (i.e. hashtag or geotag) associated with that Event.
SHARING OF YOUR INFORMATION
We will not rent or sell your information to third parties outside rewardSnap (or the group of companies of which rewardSnap is a part) without your consent, except as noted in this Policy.
Parties with whom we may share your information:
We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that rewardSnap is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences). But these Affiliates will honor the choices you make about who can see your photos.
We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.
We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
Parties with whom you may choose to share your User Content:
Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. To change your privacy settings on the Service, please change your profile setting. Once you have shared User Content or made it public, that User Content may be re-shared by others.
Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users and subject to use under our rewardSnap API.
If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the rewardSnap API have copied or saved that information.
What happens in the event of a change of control:
Responding to legal requests and preventing harm:
We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
HOW WE STORE YOUR INFORMATION
Storage and Processing:
Your information collected through the Service may be stored and processed in Hong Kong or any other country in which rewardSnap, its Affiliates or Service Providers maintain facilities.
rewardSnap, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from the Hong Kong Special Administrative Region law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, rewardSnap cannot ensure the security of any information you transmit to rewardSnap or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and rewardSnap, at all times. Your privacy settings may also be affected by changes the social media services you connect to rewardSnap make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
YOUR CHOICES ABOUT YOUR INFORMATION
Your account information and profile/privacy settings:
Update your account at any time by logging in and changing your profile settings.
Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).
How long we keep your User Content:
Following termination or deactivation of your account, rewardSnap, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes.
rewardSnap does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [email protected]
OTHER WEB SITES AND SERVICES
DATA SECURITY AND RETENTION
We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We use a secure, encrypted connection (using a TLS protocol) on all pages where you access or transmit Personal Information. Although we use reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
RIGHTS APPLICABLE TO EU USERS
Legal basis for using your Personal Information
If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:
Performance of a contract. The use of your Personal Information may be necessary to perform the terms and conditions or other policies under which we provide our Services.
Legitimate interests. We may use your Personal Information for our legitimate interests to improve our Services, security purposes, and fraud prevention, and to share information with our affiliates for internal administration. In such circumstances it is for us to ensure that these interests are not overridden by your data protection interests or fundamental rights and freedoms. If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be for to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
Choices under EU law
If your Personal Information is subject to the protections offered by EU law, you may:
Access, correct, update or request deletion of your Personal Information, at any time by contacting us using the contact details provided under the "How to Contact Us" section below (in accordance with applicable data protection laws); We may charge a reasonable fee for any manifestly unfounded, excessive or repetitive requests;
Object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information for the legitimate interests that we have set out above. In certain circumstances we may not be able to stop using your personal information but, if that is the case, we will let you know and tell you why;
Withdraw your consent at any time if we have collected and process your Personal Information with your consent;
Opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you;
Complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including US and Canada) are available here.)
To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 10 below and we will respond within 30 days. Please note that if you are not subject to EU law, these rights do not apply to you.
HOW TO CONTACT US