Integritetspolicy

1. WHAT IS A PRIVACY POLICY

1.1

The website, www.rewardpulse.eu (the “Site”) is operated by RewardPulse SAS, whose registered office is located at 5 Rue Volta, 75003 Paris, France (hereinafter “we”, “our”, “us”, “RewardPulse”). This Privacy Policy (“Policy”), along with the Website Terms of Use (“Terms”) and the Cookie Policy, sets out the basis on which any personal information or data we collect from users, or that you provide to us, will be processed by the Site. This Policy applies to the Site and to all services offered by RewardPulse through the Site. The information you provide will be retained by us as the data controller.

1.2

The following discloses our information gathering and dissemination practices for the Site. In order to fully understand your rights, we encourage you to read this Policy and consult our Terms. Each time you use the Site, you are bound by the then-current Policy, and you should review it each time you use the Site.

1.3

RewardPulse se réserve le droit de modifier la présente Politique à tout moment, en tout ou en partie, conformément à l'article 10.RewardPulse reserves the right to change this Policy at any time, in whole or in part, in accordance with section 10.

2. ACKNOWLEDGEMENT OF THIS POLICY

2.1

By using the Site, you acknowledge this Policy. If you do not agree with any part of the Policy, you must stop using the Site. We reserve the right to modify this Policy at any time in accordance with section 10.

3. ACCESS AND PERSONAL DATA REWARDPULSE COLLECTS FROM YOU

3.1

You may choose to provide us with the following personal data:

When you use the Site, we receive and collect certain personal information and data about you, called “Customer Personal Information.” The Customer Personal Information we receive and collect depends on what you do when you visit the Site. We may collect and process the following personal information about you:

• Information you provide when creating a customer account and during your subsequent use of the Site, our services, or experience products. This may include your first name, last name, phone number, and email address.
• If you choose to correspond with us via the Site, we will keep a record of that correspondence for as long as necessary to handle your request. Please see our section on data retention for more information on how long we keep this information.
• We may also ask you to complete surveys from time to time that we use for research purposes, although you do not have to respond to them and you can choose not to receive such surveys.

4. HOW AND WHY WE USE YOUR PERSONAL DATA

4.1

The following list details the legal basis (the “Legal Basis”) and reasons (“Purposes”) for which we process your Personal Data:

Legal Basis: Contract

(It is necessary to process this personal data to enter into and perform our contract with you regarding your use of the Site as set out in the Terms.)

Purposes:

1/ Access to the website

• To provide you with access to the Website and to enable you to use the Website.

2/ Execution of your orders and requests

• To provide you with the information, services and product experiences you request from us and to fulfill orders placed through the Website.
• To register, process and finalize your orders and/or reservations.
• To manage your customer account.
• To prevent fraudulent use of our services.

Legal Basis: Consent

Purpose : Marketing

• To provide you with information about RewardPulse services that may be of interest to you if you have consented to receive such marketing messages or are an existing customer.
• RewardPulse will provide you with information relating to third party experiences, products and/or services when you have consented to receive such marketing.

Legal Basis: Legitimate Interests

(Data is processed on this basis when we have a legitimate interest to process the data which does not impact your rights and freedoms. We will collect and process personal data for the purpose of improving and monitoring the effectiveness of the Website and to enhance your use of the Website. If you place an order on the Website, we will process your personal data to respond to any questions or requests you submit regarding the Website, and to send optional upgrades or reminders in relation to an experience product you have booked or in relation to other similar experience products.)

Purposes :

1/ Improve the functionality and efficiency of the website

• To provide, improve, test and monitor the effectiveness of the Website.
• To monitor metrics such as total visitor numbers, traffic data, and demographic patterns.
• To ensure that content from the Site is presented in the most effective manner for you and to enhance your use of the Site.

2/ Answer to questions and complaints

• To process and respond to any requests, inquiries and complaints you may submit to us via the Site or through our customer service.
• To respond to and process any requests you have made.
• To request your opinion on the Website and our services.

3/ Inform you of changes

• To inform you of changes made to the Site and/or our services.

4/ Postal Marketing

• To send you marketing information by post, provided you have not objected to this when your data was collected (please note that you can opt out of receiving this marketing information by contacting Info@RewardPulse.eu).

5/ Marketing and communication by email

• To offer prizes for sweepstakes or contests you have entered and won.
• To remind you of the expiration date of an experience product you have booked.
• To inform you of available upgrades for a booking you have made.
• To contact you sometime after booking an experience product, either to request feedback or to promote other experience products that may be of interest to you.
• Pour vous envoyer un questionnaire ou vous inviter à donner votre avis sur votre expérience avec RewardPulse ou le partenaire qui a fourni le produit d'expérience.

6/ Legal purposes

• Finally, in some cases, we may need to use your information to manage and resolve legal disputes, for regulatory investigations and compliance, to enforce the RewardPulse Online Booking Service Terms of Use, or to comply with lawful requests from law enforcement.

5. RECIPIENTS OF YOUR PERSONAL DATA

5.1

We will disclose your personal data to other members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries that provide certain aspects of the services and experience products provided through the Site.

5.2

We will only disclose your personal information to third parties outside our group of companies in the following circumstances:

Recipients: RewardPulse Experience Product Partners

Purposes :

• To confirm your registration.
• RewardPulse transfers the relevant details you provide to the partner providing your experience product, to enable them to deliver that experience product. This will include your first name, last name, and contact details, as well as any preferences you express.
• In the event of a booking dispute, we may provide the Partner with information about the booking process if necessary. This may include a copy of your booking confirmation as proof that a booking was actually made.
• Provide you with appropriate and effective support.
• To send you promotional or direct marketing materials (in circumstances where you have expressly consented to receive such materials from third party partners).
• Pour vérifier la validité de tout produit d'expérience RewardPulse réservé sur le Site.

Recipients: RewardPulse Subcontractors and Service Providers

Purposes :

• To assist RewardPulse in providing the services and experience products offered on the Website.
• For logistics and IT service purposes.
• To send you customer satisfaction surveys or polls which will be anonymized for statistical purposes in order to improve your experience on the Site.

Recipients: Regulatory authorities, law enforcement agencies, public bodies and third-party companies

Purposes :

• To comply with any applicable legal obligation, court order, subpoena, search warrant or other legal or regulatory obligation or request to which RewardPulse is subject.
• To protect the rights, property, or safety of RewardPulse, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• To enforce or apply the Terms and other agreements or to investigate potential violations.

Recipients: Potential sellers or buyers of commercial assets

• To facilitate the acquisition of RewardPulse by a third party.
• To facilitate the acquisition of a substantial portion or substantially all of RewardPulse's assets by a third party

6. STORAGE AND TRANSFERS OF YOUR PERSONAL DATA

6.1

Your personal data may be stored and transferred within or outside the European Economic Area (“EEA”). We only transfer your personal data outside the EEA when the European Commission has decided that the third country in question ensures an adequate level of protection in accordance with EU data protection standards or that appropriate safeguards have been put in place to protect your personal data. If you would like to know more about the appropriate safeguards we have put in place to govern the transfer of your personal data, you can contact us at Info@RewardPulse.eu.

6.2

Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7. LINKS

7.1

The Site may contain links to other websites (“Linked Websites”). RewardPulse is not responsible for the privacy policies or practices on Linked Websites. This Policy governs only information collected on the Site. When accessing Linked Websites, you should read the privacy policy posted on the relevant Linked Website. The terms of our Policy do not apply to Linked Websites. Please review these policies before submitting any personal data to Linked Websites.

7.2

The Site contains links to other sites and resources provided by third parties for your convenience and information only. We accept no responsibility or liability in relation to any linked website, or any contract entered into in or through a linked website. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of linked websites.

8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

8.1

Generally, we expect to retain your personal data for a period of three years from the last date we were in contact with you, or when you enter into a contractual agreement with us, for three years after the end of the performance of our contract, or your termination as an employee of RewardPulse.

8.2

Please note that in certain circumstances we may retain your data for a longer period, for example, if we are dealing with an ongoing claim or if we believe in good faith that the law or a relevant regulator may reasonably in our opinion expect or require us to preserve your data, or where we have a legitimate interest in preserving your data, that legitimate interest does not conflict with your rights and freedoms.

9. YOUR RIGHTS AND HOW TO EXERCISE THEM

9.1

The list below sets out the rights you have to raise any concerns or questions about our processing of your personal data with us:

Right: Right of Access

You have the right to request that we correct any inaccurate personal data we hold about you.

Right: Right to Erasure

You have the right to request that we correct any inaccurate personal data we hold about you.

Right: Right to erasure

You have the right to ask us to erase your personal data when:

1. Vos données personnelles ne sont plus nécessaires au regard des finalités pour lesquelles elles ont été collectées ou traitées par nous ;
2. You withdraw your consent and there is no other legal basis for us to process your personal data;
3. You object to the processing and there are no overriding legitimate grounds for the processing;
4. Your personal data has been unlawfully processed; or
5. Your personal data must be erased in order to comply with a legal obligation.

We may not be able to comply with a request where we need your personal data for compliance with a legal obligation or in the context of legal proceedings or to exercise the right to freedom of expression and information.

Right: Right to restriction of processing

You have the right to ask us to restrict the processing of your personal data in the following situations:

• (1) when you contest the accuracy of your personal data;
• (2) where the processing is unlawful and you do not want us to erase your personal data;
• (3) when we no longer need your personal data for the purposes of the processing, but you require the data in connection with a legal claim; or
• (4) where you have objected to our processing of your personal data pending the verification whether our legitimate business interests override your interests, rights and freedoms or in connection with legal proceedings.

When you exercise this right, we may only store your personal data. We may not continue processing the data unless you consent to it or the processing is necessary for legal action or to protect the rights of another person or legal entity, or for reasons of important public interest. We will inform you before the processing restriction is lifted.

Right: Right to data portability

You can ask us to provide you with the personal data you have provided to us in a structured, commonly used and machine-readable format, and you can ask us to transmit your personal data directly to another data controller where technically feasible.

This right only exists in the following cases:

• (1) we process your personal data with your consent or where necessary to perform our contract with you; and
• (2) The processing is carried out by automated means.

Right: Right of opposition

You have the right to object at any time to the processing of your personal data where we process your personal data on the legal basis of pursuing our legitimate interests.

You have the right to object at any time to the processing of your personal data for direct marketing purposes.

9.2

You can exercise any of these rights by submitting a request to Info@RewardPulse.eu. You have the right to file a complaint with the French Data Protection Authority (CNIL) regarding the processing of your personal data. Full details on the procedure to follow are available in the complaints section of the CNIL website, and the contact details for filing a complaint are as follows:

French National Commission for Information Technology and Civil Liberties

3 Place de Fontenoy

TSA 80715

75334 PARIS CEDEX 07

FRANCE

https://cnil.fr/en/contact-us

10. CHANGES TO THIS POLICY

If we change this policy, in whole or in part, the changes will be posted on this page and, where appropriate, notified to you by email or when you use the Site. The new policy may be displayed on screen and you may be asked to read and accept it to continue using the Site.