WHAPPS PRIVACY POLICY

Last Modified: 4/5/2023

Definitions

WHAPPS LLC: We provide rewards program creation and maintenance services under the names Online Rewards, My Point Rewards, Catalog API, WorkProud, 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

This privacy policy uniquely refers to activities between Online Rewards and Nielsen and its clients, and does not pertain to privacy policy practices between Online Rewards and its other clients. 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 for the purposes described in this Privacy Policy. If you have questions about this privacy notice or our privacy practices, please contact our privacy department at NielsenRadioTVStudy@online-rewards.com.

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 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
• Payment information, we will only collect this information if you choose to have the value of your digital reward transferred to your PayPal Account. If you choose this option, we will collect [precise details] and will use this information for the purpose of making the transfer only.

Transactional Information

We may collect and store data that is relevant to the operation of a Sponsor’s Rewards Program including the reward option chosen.

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, 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)
• Other information as required by a Program Sponsor

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.

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.

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.

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 participating 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.

Privacy Statement – California

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Whapps LLC and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

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:

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 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. This would include any personal information used to claim or access a reward.

We will not sell your 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).

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.

Non-Discrimination

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.

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)
2435 North Central Expressway
Suite 1180
Richardson, TX 75080