At RewardMe, we take your privacy seriously.
Please read our general Privacy Policy, which describes how we treat your personal data and applies to all users no matter where users reside. If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this GDPR Privacy Notice, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. ALTERNATIVE DATA LIMITED (“RewardMe,” “we”, and “us) will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this GDPR Privacy Notice and our general Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this GDPR Privacy Notice or whether any of the following applies to you, please contact us at support@reward.me.
The “Categories of Personal Data We Collect” section set forth in our general Privacy Policy details the Personal Data that we collect from users. However, with respect to EU users subject to this GDPR Privacy Notice, we do not collect payment data listed in our general Privacy Policy.
The “Our Commercial or Business Purposes for Collecting Personal Data” section set forth in our general Privacy Policy explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
Examples of these legitimate interests include (as described in more detail above):
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. Specifically, if you elect to participate in our RewardMe Program and link your email account with the Services to earn the RewardMe Points, we will obtain your consent for linking your email account with the Services and collecting the following categories of Personal Data. During the email linking process, you’ll be prompted to authenticate that you’re the owner of such email account and provide consent for linking the Services to such email account, in which case the applicable email service provider has your permission to share the Linked Email Data with us.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
The “How We Share Your Personal Data” section set forth in our general Privacy Policy details how we share your Personal Data with third parties.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@reward.me. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
The RewardMe group has business processes, management structures and systems that cross borders. As such, we may share information about you within the Reward corporate group and transfer it to countries in the world where we operate our business in connection with the purposes identified above and in accordance with this GDPR Privacy Notice. The Services are hosted in the U.S. through our hosting service providers and operated through us and our service providers located in Hong Kong and the U.S. Please note that the laws in the U.S. and Hong Kong may differ from the laws where you reside, but we will handle your Personal Data in the manner described in this GDPR Privacy Notice.
RewardMe may, pursuant to the purposes listed above, transfer your Personal Data within the EU or Switzerland and to a different jurisdiction. We take the privacy and security of your Personal Data seriously and have adopted intra-group data processing agreement among our affiliates (“Intra-Group DPA”), which incorporates Controller to Controller Standard Contractual Clauses, available at http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32004D0915&from=EN (“C2C Model Clauses”). We undertake that the transfer of your Personal Data from Europe to the territories where your Personal Data is hosted and processed by us will follow the C2C Model Clauses to enable the lawful transfer of Personal Data pursuant to GDPR. Please contact the RewardMe Privacy Team at support@reward.me should you wish to examine the Intra-Group DPA.
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
If you are located in the European Union, you may use the following information to contact our Data Protection Officer and our European Union-Based Member Representative:
DP-Dock GmbH
Ballindamm 39
20095 Hamburg
Tel.: +49 (0) 40 99999 – 3430
Mob.: +49 (0) 172 918 22 22
E-Mail: mailtime@gdpr-rep.com