WHAPPS PRIVACY POLICY

Last Modified: 8/23/2018

Definitions

WHAPPS LLC: We provide rewards program creation and maintenance services under the names Online Rewards, My Point Rewards, Catalog API, Applaud, RewardsOnDemand and My Milestone Award. As it pertains to this Privacy Policy, WHAPPS LLC and all subsidiaries will be referred to as "Our," "We" or "Us."

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."

OUR CLIENTS: We build, manage and maintain Rewards Programs for and on behalf of our Clients, who specify the requirements for each of their Rewards Programs. As it pertains to this Privacy Policy, our clients will be referred to as "Program Sponsors."

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."

Our Privacy Policy

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.

Our Privacy Policy outlines how we collect, store, use, disclose and protect your information and the choices you have regarding how we collect, store, use, disclose and protect your information.

In cases where the Program Sponsor has specified additional obligations with respect to collection and use of personal information in a Rewards Program and, if these obligations are more restrictive than those set forth in this Privacy Policy, we will comply with the more restrictive obligations.

By using our Rewards Programs, you accept the terms of this Privacy Policy and our End User License Agreement and consent to our collection, use, processing, disclosure, and retention of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR END USER LICENSE AGREEMENT, THEN PLEASE DO NOT USE ANY OF THE REWARDS PROGRAMS.

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. This Privacy Policy is incorporated into and referenced in the End User License Agreement with program sponsors and third party service providers as applicable.

INFORMATION WE COLLECT

Personal Information

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

Payment Information

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.

Transactional Information

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.

Location Information

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.

Experience Information

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.

Anonymous Information

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

When you use the Rewards Programs, we may collect some information by automated means, like cookies and web beacons. A "cookie" is a text file sent by a website to a participant’s computer or other Internet-connected device to uniquely identify the participant’s browser and/or to store information or settings in the browser. Some content or applications available through the Rewards Programs may employ the use of third-party cookies served by third parties. We do not collect personal information through our own, or third-party cookies. We use cookies to identify the fact that you are a repeat participant.

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 privacy@whapps.com.

YOUR CHOICES

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 privacy@whapps.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 privacy@whapps.com.

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)

Rewards Programs may link to third-party websites and services ("Third Party Services") with which we are not affiliated. A link to any Third Party web site does not represent our endorsement of any Third Party web site nor the quality or accuracy of information presented therein. If you visit a Third Party web site, you are subject to its privacy policy and practices and not this Privacy Policy. Please carefully review the legal and privacy policies and notices of all Third Party web sites you visit.

SPECIAL PROVISIONS

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 privacy@whapps.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

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov. Our participation in the Privacy Shield applies to all personal information that is subject to this Privacy Policy and is received from individuals who are resident in the European Union, European Economic Area, and Switzerland.

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 privacy@whapps.com.

We have further committed to cooperate with the panel established by the EU Data Protection Authorities ("DPAs") and the Swiss Federal Data Protection and Information Commissioner ("FDPIC") with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland 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 or the Swiss FDPIC for more information or to file a complaint. The services of the EU DPAs and the Swiss FDPIC 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. Visit https://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

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.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to update or change this Privacy Policy at any time. If we make a change that meaningfully reduces your rights, we will provide notice within the Rewards Programs. Your continued use of the Rewards Programs after any Privacy Policy is amended constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions. We encourage you to return to this Privacy Policy periodically to review any updates or changes.

CONTACT US

Written questions or comments regarding this Privacy Policy should be submitted to us at:

WHAPPS LLC (dba Online Rewards)
100 North Central Expressway
Suite 1120
Richardson, TX 75080