Shopr Rewards:

Privacy Policy

Effective Date: September 15, 2024

PLEASE READ THIS PRIVACY POLICY CAREFULLY.

By accessing or using the Shopr Rewards mobile app and related services, you consent to the collection, use, sharing, and retention of your information as described in this Privacy Policy, including providing consent to receive communications from Shopr Rewards and the Shopr Rewards client who provided you access to the app through various channels (e.g., email, SMS, push notifications and calls via mobile phone or landline phone).

This Privacy Policy explains how Shopr Rewards LLC (“we”, “us”, “our”, “Company”) collects, uses, shares, and protects information in connection with the Company’s websites, mobile websites, mobile applications, browser applications, and any related services that link to this Privacy Policy (“Services”).

1. Collection of Information

We collect, process, and use your information when you:

• Register for our Services or sign in to an existing account

• Visit our websites

• Access our Services through mobile or browser applications

• Contact us for support

• Enter a contest, promotion, survey, or poll

We and our service providers automatically collect certain information about you through:

• Interaction with our Services

• Cookies and other tracking technologies

• Location-identifying technologies

• Monitoring and analyzing trends, usage, and activities

The types of information you may provide include:

• First and last name

• Email address

• Mailing address

• Phone number

• Payment information (e.g., payment account name, payment card details, billing address)

• The nature of the product or service requested or purchased

• IP address, unique device identifiers, device/session IDs, and information on your network or device

• Browsing, shopping, and purchase history

• Geolocation

• Click-stream data (the paths you take as you browse our Services)

2. Use of Information We Collect

We may use information about you in the following ways:

Manage Your Account

If you provide us with Personal Information, we may use it to:

• Process your registration and verify your contact information

• Manage your purchase transactions

• Track your shopping activity and deliver rewards or offers

• Send technical notices, updates, security alerts, and administrative messages

• Provide customer support and respond to inquiries

• Comply with legal and regulatory obligations in the jurisdictions where we operate

• Assess risk and prevent fraud

Improve Our Services

We analyze trends and usage to improve our Services and deliver a better experience. We may also use this information to tailor content, offers, and services that are more relevant to you.

Provide You Marketing Information

With your consent, we may send you newsletters, rewards, discounts, promotions, and general information about the Services. You may opt out of these communications at any time.

Administer Contests and Promotions

We may invite you to participate in contests, surveys, or promotions. If you choose to participate, your Personal Information may be used to determine eligibility or award prizes.

3. Sharing of Information

We may share the information we collect, including your Personal Information, under the following circumstances:

Service Providers and Business Partners

We do not sell your Personal Information. However, we may share it with third-party service providers and clients to facilitate the operation of our Services and deliver rewards, promotions, and offers to you. For example, we may partner with companies for support services, fraud prevention, analytics, and rewards fulfillment. All third-party partners are required to comply with appropriate security measures to protect your data.

Sharing with Clients

Your information may be shared with Shopr Rewards’ clients (such as retailers and brands) who use our platform to offer you rewards, promotions, and other services. These clients will use your information in accordance with this Privacy Policy and their own privacy policies. You may choose to limit the channels through which you receive communications (e.g., email, SMS) by adjusting your app settings.

Protection of Rights and Legal Purposes

We may share your information to the extent permitted by law (i) in response to legal processes; (ii) at the request of government authorities; (iii) to defend our policies or legal terms; or (iv) to protect the rights, property, or safety of the Company or others.

Business Transfers

In the event of a merger, sale, or other transfer of Company assets, your information may be shared with or transferred to the acquiring party.

4. Your Choices

You may choose not to provide certain information, but this may limit your ability to use some features of the Services.

Opt-Out of Marketing Communications

You can opt out of receiving promotional communications by:

• Following the unsubscribe instructions in emails

• Adjusting your settings in the mobile app

• Contacting us via Customer Support

Even if you opt out of marketing communications, you may still receive service-related messages, such as account notifications and order confirmations.

5. Data Security and Retention

We take reasonable measures to protect your information from loss, misuse, and unauthorized access. For example, we use secure, encrypted connections (TLS protocol) to transmit Personal Information. However, data transmission over the Internet is not completely secure, and we cannot guarantee the absolute security of your information.

We retain your personal information for as long as necessary to provide you with the services of Shopr Rewards, fulfill contractual obligations, and comply with legal and regulatory requirements. The retention period for personal data depends on the following criteria:

• Active Accounts: For active users, we retain personal data for the duration of your use of our services and as long as necessary to maintain your account.

• Inactive Accounts: For accounts that are deemed inactive (i.e., no user activity for a period of 24 months), we will retain personal data for an additional 12 months to allow users to reactivate their account before secure deletion is initiated.

Upon reaching the retention period for inactive accounts or upon your request for deletion, we will securely delete your personal information from our systems. Data deletion is conducted using industry-standard procedures, such as secure file deletion and data destruction methods, to ensure that your personal information cannot be recovered or reconstructed. If data is required to be retained for legal or regulatory purposes, it will be anonymized where possible and securely archived.

Our data retention and deletion policies comply with applicable data protection regulations, including but not limited to the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). These regulations provide you with the right to access, correct, or delete your personal information, and we ensure that these rights are honored throughout the data lifecycle.

Retention of Anonymized Data

Once your personal information has been securely deleted in accordance with our retention policies, we may retain anonymized data for analytical purposes. This data has been stripped of all personally identifiable information (PII) and cannot be used to identify you. Anonymized data helps us to improve our services, monitor usage trends, and conduct business analysis without compromising your privacy.

Use of Anonymized Data for Analytics

We may use anonymized data for research, statistical analysis, and to improve our products and services. This data is used in aggregate form to identify trends and patterns, enabling us to better serve our users and enhance the Shopr Rewards platform. Anonymized data is not subject to deletion requests, as it no longer qualifies as personal data under data protection laws.

6. Incident Response and Data Breach Notification

Incident Response Plan

Shopr Rewards has implemented a comprehensive incident response plan designed to protect personal data in the event of a security breach. Our plan involves the following actions:

• Detection and Containment: We continuously monitor our systems for potential security threats or breaches. Upon detecting a security incident, we will take immediate action to contain and mitigate the impact of the breach, including isolating affected systems to prevent further access to Personally Identifiable Information (PII).

• Investigation and Risk Assessment: Once the breach is contained, we conduct a thorough investigation to determine the scope, root cause, and affected data. We assess the risks to your personal information and the potential impact on affected individuals.

Breach Notification

If a breach involving PII occurs, we are committed to notifying affected clients and individuals in a timely and transparent manner:

• Notification to Clients: Shopr Rewards will notify affected clients of any data breach impacting PII within 72 hours of becoming aware of the incident, unless otherwise required by law to provide earlier notification. The notification will include details of the breach, the nature of the compromised data, actions taken to address the breach, and recommended next steps.

• Communication with Data Subjects: In certain cases, we may also communicate directly with impacted individuals to inform them of the breach and provide guidance on how they can protect themselves from potential risks.

Ongoing Monitoring and Remediation

Following a breach, we continue to monitor the situation to prevent further incidents and will implement additional security measures as necessary to protect your personal data. Our incident response team will also provide updates on the progress of the investigation and remediation efforts.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Authenticate users

• Track preferences and user behavior

• Provide personalized experiences

You can control the use of cookies through your browser settings. However, disabling cookies may limit some functionalities of the Services.

8. Analytics and Targeting

We and our partners use cookies, pixels, and other technologies to collect data about your use of the Services. This data may be used for cross-device tracking and conversion measurement.

9. Third-Party Data and Social Features

Our Services may contain links to third-party websites. This Privacy Policy does not apply to those websites, and we are not responsible for their privacy practices.

We also offer social features (e.g., sharing content, signing in through social media). When you use these features, both Shopr Rewards and the third-party platform may have access to certain information about you.

10. Compliance with Privacy Laws

We comply with all applicable privacy laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). You have the right to:

• Access, correct, or delete your Personal Information

• Object to the processing of your data

• Request data portability

To exercise these rights, please contact us.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If changes are significant, we will notify you via email or by posting a notice on our Services.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

• Email: support@shoprrewards.com

• Phone: (321) 948-1319

• Address: 111 N Magnolia Ave, #1575, Orlando, FL 32801, USA