Privacy Policy
Effective Date: October 1, 2024
GrabPoints is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, and disclose personal information when you use our website at grabpoints.com (“Site”), related services (“Services”), and applications (“Applications”).
By using our Site, Services, or Applications, you consent to the collection, use, and sharing of your information as described in this Privacy Policy.
1. Non Personally Identifiable Information and Collection Of
We automatically collect IP addresses, website usage and application usage information from you when you visit our site or download Applications. When you download and use Applications, we may also collect your “unique device ID” or “UDID,” which is a number uniquely associated with your mobile device. This information is used to help us evaluate how end-users use our website and applications, and permits us to enhance those sites and applications. We may use non personally identifiable information about you in the following ways:
- To maintain, operate, provide and enhance our Site and Services
- To allow us to personalize the content and target the advertising that you and others see based on personal characteristics, usage patterns and/or preferences.
- To provide advertisers and other third parties with aggregate information about our user base and its usage patterns.
- We may combine the non personally identifiable information that we collect about you from your use of the Site and Services with other non personally identifiable information that you provide to us in connection with your use of GrabPoints products, services and websites.
- We use third-party network advertisers, to deliver ads to you on our behalf. These network advertisers may be supplied with or have access to your non personally identifiable information (such as IP address and UDID).
2. Personally Identifiable Information
We do not collect personally identifiable information unless you provide it to us, either by contacting us and providing us with such information, through registration of our Site or providing through demographic questions – which is completely voluntary. Site registration is a feature considered completely optional. We will use personally identifiable information for the purpose(s) described in this privacy policy. The uses of your Personally Identifiable Information may include the following:
We may disclose and use personally identifiable information to resolve disputes, troubleshoot problems, enforce our Terms of Service or other legal rights (for example, when necessary to protect our or a third party’s intellectual property or proprietary rights).
- Alert you to changes in our policies or agreements that may affect your use of our application and Website.
- Comply with legal requirements or process, or where necessary to prevent or investigate fraud, to protect the safety of an individual, subcontractors, vendors and other businesses that we employ to perform functions on our behalf. For example, we may employ third parties to send email campaigns or provide marketing assistance, or provide customer service. These entities have access to your information only for the purposes of performing the functions for which we have engaged them. If such entities have access to your personally identifiable information, their agreements with us require them to keep your information confidential.
- We may also share personally identifiable information with advertisers when you complete offers and surveys, so that we can easily provide offers to make the process seamless.
- We may use your email address and mobile number, respectively, to respond to an email/SMS inquiry you have made.
- To provide you with information, products or services that you request from us which we feel may interest you and where you have consented to be contacted for such purposes.
- To allow you to participate in interactive features of our service
- Demographic information and device ID information may be used to target advertisements, surveys, videos & offers to your account.
- To allow us to comply with our legal obligations where release of information relating to Members is required by law.
- Member Data may be disclosed in response to valid requests from public authorities, including to meet national security or law enforcement requirements.
- We may also disclose personally identifiable information to a successor acquirer or other related entity, in connection with a sale or transfer of some or all of our assets, or when we, in good faith, believe that the law requires us to do so.
- GrabPoints may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, and non-personally identifiable information on household members, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:
- Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
- Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
- Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
- Other uses as set forth in their privacy policy.
- If you are eligible for a client survey opportunity offered through a Third Party MR Company, the Third Party MR Company will provide your unique identification number and a survey link to us and we will invite you to participate in the client survey through notifications via your mobile device, notifications via desktop and emails. We will not share your name, email address, or phone number with the Third Party MR Companies unless noted. In connection with the sharing of your information with a Third Party MR Company, your information may be transferred and stored outside of your country of residence, including, without limitation, in the United States, and by agreeing to this privacy policy you are agreeing to the processing and exportation of your personal information as set forth in this Section. If you have any questions about this data sharing please contact [email protected] or you can opt-out by unsubscribing via the following URL: http://pb.grabpoints.com/unsubscribe. If you opt-out, it is the responsibility of us to inform the Third Party MR Companies. Please note that GrabPoints is solely responsible for managing all opt-out requests. Your participation in such survey opportunities does not entitle you to any benefits offered by, or membership with, the third-party market research Companies.
Reward Holdings Limited is the controller and responsible for your personal data in this privacy policy. If you have any questions or concerns regarding this notice, or your use of the Reward Holdings Limited Sites and Features or our Services, please contact our Data Protection Officer at [email protected], or write to us via airmail to:
Reward Holdings Limited
Room 1203, 12/F, Tower 3
China Hong Kong City, 33 Canton Road
Tsimshatsui, Kowloon
00000, Hong Kong
Attention: Data Protection Officer
3. GrabPoints Marketing
GrabPoints cannot use the UDID to identify you personally, but it does enable us to collect information about the kind of mobile device you use, the operating system for your mobile device, the applications you download from GrabPoints third party providers, and when, how, and how often you use those applications. We use your UDID and information about the third party applications you download to report on the number of unique users who click through ads on the GrabPoints website & application, and the number of those users who download third party applications as a result of those ads.
We also use your UDID and the information associated with your UDID over time (e.g., the applications you download, when and how you use those applications, and any publisher-provided demographic data) to enhance our services and to select GrabPoints third party ads that are most likely to be of interest to you. We allow third-party companies to collect certain information when you visit our web site. These companies may utilize cookies, pixels or other technologies to collect and use both personally identifiable information (e.g., device ID, IP address, physical or electronic address) and non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to this and other web sites in order to provide advertisements about goods and services likely to be of greater interest to you.
4. Cookies
When you interact with the Reward Holdings Limited Sites and Features, we try to make that experience simple and meaningful. When you visit the our sites, a web server sends a cookie or other tracking Technologies to your computer or mobile device (as the case may be). Tracking Technologies may also be present in the Reward Holdings Limited sites and features, such as mobile app SDKs (software development kits, i.e., certain code that enables tracking). Cookies and other tracking technologies are small pieces of information which are associated with or issued to your computer or mobile device when you visit a website or access or use a mobile application and which store and sometimes track information. Some cookies we use may last only for the duration of your web or application session and expire when you close your browser or exit the Sites. Other cookies are used to remember you when you return to the Sites and will last for longer. The cookies and/or other Tracking Technologies we use collect a variety of relevant information, such as the type of internet browser or mobile device you use, device attributes, any website from which you have come to theSites, your IP address and/or the operating system of your computer or mobile device. We use cookies and/or other Tracking Technologies, such as tracking GIFs, web beacons, pixel codes and in-app IDs, either alone or in combination with each other, to create a unique device ID and to:
- remember that you have visited us before. Among other things, this means we can identify the number of unique visitors we receive and make sure we have enough capacity for the number of users that we get;
- where necessary or otherwise permitted, track whether you have opened an email that we have sent to you and your related actions (e.g., linking to the Sites from the email);
- customise elements of the promotional layout and/or content of the pages of the Sites;
- collect statistical information about how you use the Sites and Features (including how long you spend on the Sites) and where you have come to the Sites from, so that we can better understand and improve the Sites.
Some of the Tracking Technologies associated with the Sites are set by us, and some are set by third parties, such as companies that are delivering services or operating features on our behalf.
Please note, however, that by blocking or deleting cookies or other Tracking Technologies used on the Sites, you may not be able to take full advantage of the Sites and Features including the tracking of data required for Promotions and Rewards Programs. To exercise your data protection rights, please see Section 13 ("Your Rights") below. For additional information on how we process the information collected using cookies, please review this notice.
Strictly Necessary Cookies
These cookies are essential to enable you to navigate our Website and use its features, such as accessing secure areas. Without these cookies, we cannot provide the services you have requested.
Performance Cookies
These cookies are used to gather statistics on how visitors use our Website. This allows us to gain insight so that we may make improvements to its usability. We categorize the following as performance cookies:
- Referrer URL (internal page): used to store the URL of the previous page visited. Allows us to track how visitors navigate through our Website.
- Unregistered visitor cookie: a unique identifier given to each visitor to allow analysis on how unregistered visitors use our Website.
- Session management cookies: these cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window. Our session management cookies are created temporarily.
Functionality Cookies
These cookies are used to enhance your experience when you visit our Website such as by capturing your preferences so that they are remembered for subsequent visits to improve your experience.
These cookies allow a site to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal features. For instance, our site may be able to provide you with local information by storing a cookie for the region in which you are currently located. In most cases we will not be able to track individuals by name. However, cookies may associate registered users with their names.These cookies cannot track your browsing activity on other websites. They do not gather any information about you that could be used for online advertising on other websites or remember where you have been on the internet outside our Website.
We categorize the following as functionality cookies:
- Registered visitor cookie - a unique identifier given to each registered user to our Website, or each user who voluntarily provides Personal Data on our Website to request information from us, used to serve them content and offers based on their profiles. Also used for analysis and marketing purposes (see also Strictly necessary cookies above).
Targeting Cookies
These cookies are used for web analytics and intelligence about our Website. They are used to deliver online advertisements on third party websites that are more relevant to you and your interests. They are also used to limit the number of times you see such advertisements as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. We may use information collected from our cookies to identify user behavior and to serve content and information on products and services based on your profile.
5. Links to Other Content and Third Party Applications
We frequently make content or services from other websites available to you from links located without our Sites. These other websites are not subject to this Privacy Policy, and we have no control over how such websites may use the personal information collected on those sites. Similarly, the Applications you download from our Site are owned by third parties and we have no control over what information is collected or used by such third parties as a result of your use of such Applications. We recommend that you review the privacy policy and end user terms associated with each of these third party websites and Applications to determine their respective information collection, use and disclosure practices. Of course, you understand that we are not in any way responsible for the privacy practices or the content of third party websites, services or Applications. Notwithstanding any other provision, we partner with third parties that collect information across various channels, including offline and online, for purposes of delivering more relevant advertising to you. Our partners may place or recognize a cookie on your computer, device, or directly in our emails/communications, and we may share personal information with them if you have submitted such information to us, such as your name, postal address, email address, or device ID. Our partners may link the personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices. To opt-out of the use of your mobile device ID for targeted advertising, please see http://www.aboutads.info/appchoices.
6. Children’s Privacy
Our website is not directed at children under the age of 16 and we do not knowingly collect personally identifiable information from children under the age of 16.
7. Security
The personally identifiable information we collect about you (if any) is stored in limited access servers. The security of your personal information is important to us, and we maintain industry standard safeguards to protect the security of these servers and your personally identifiable information. However, no method of transmission or electronic storage is 100% secure. Therefore, we cannot guarantee the security of such information or be responsible for any damage that results from a breach in security. We maintain many security measures in order to attempt to protect against the loss, misuse and alteration of the Personal Identifiable Information within our control. We maintain security measures in place in order to attempt to protect against the loss, misuse and alteration of the Personal Information under our control. Please be advised, however, that the Internet and other various networking communication media are not entirely secure, and your information may therefore be subject to interception or loss which is beyond our reasonable control. While we strive to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you transmit to us, and any transmission is done at your own risk. Accordingly, we assume no responsibility or liability for disclosure of your Personal Information or other information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control.
8. Data Retention and Purpose Limitation
Subject to applicable law, we retain your personal data in a form that identifies or is capable of identifying you only for as long as it serves a purpose that is compatible with the purposes for which the personal data was collected or subsequently authorized by you in accordance with the reasons listed under “Personally Identifiable Information.”
9. Right to Withdraw Consent
You have the right to withdraw your consent at any time or to access and request that we rectify or remove your personal data from our system(s). You may exercise this right by submitting a written request to the contact information provided in section (12).
10. Transfer to the U.S. or other countries
Your information may be stored and processed in the United States, however it is possible some of the data processing may occur outside of the United states by companies or individuals in contract with us. By using our sites and services, you consent to the the transfer of your personal data to any server used by the company or its service providers. Please be aware that data protetections laws in the United States and other countries may differ substantially from the laws and procedures of your country of residence. If you are located in a country outside of our server location and submit personal information to us, you are consenting to the transfer, processing, stortage and use of that information as provided in this Privacy Policy.
11. Changes to this Privacy Policy
When we make any material change to this Privacy Policy, we will inform you by posting a notice on the homepage of this site that the policy has been updated and by changing the date on this page noting when the policy was last updated. Continued use of the GrabPoints platform is used as your consent.
12. GDPR & UK GDPR Rights
At GrabPoints.com, we are committed to protecting your privacy and ensuring that your personal data is handled in compliance with both the EU General Data Protection Regulation (GDPR) and the UK General Data Protection Regulation (UK GDPR). This section outlines how we collect, process, and safeguard your data whether you are a resident of the European Union (EU) or the United Kingdom (UK).
a. International Data Transfers
We may transfer your personal data outside the European Economic Area (EEA) and the UK in the course of providing our services. This includes transfers to countries that do not have the same data protection laws as your country of residence. When transferring personal data:
- For EU users, we comply with GDPR by ensuring that any data transfers to non-EU countries are subject to appropriate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions.
- For UK users, we ensure that international data transfers comply with UK GDPR by applying similar safeguards, including Standard Contractual Clauses (SCCs) or transfers to countries with adequacy regulations recognized by the UK government.
Whether you are an EU or UK resident, you have the following rights regarding your personal data:
- Right of Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request correction of inaccurate or incomplete data.
- Right to Erasure: You can request deletion of your personal data where applicable.
- Right to Restrict Processing: You can ask us to limit the use of your data.
- Right to Data Portability: You can request your personal data in a structured, commonly used, and machine-readable format.
- Right to Object: You can object to the processing of your data, including for direct marketing (via opt-out).
- Right not to be Subject to Automated Decision-Making: You can object to decisions made by automated processes if they significantly affect you. Considering that some of your data is crucial to the site, we recommend requesting erasure of your account if you wish not to restrict processing.
13. US State Laws
If you are a resident of California, Colorado, Connecticut, Florida, Oregon, Montana, Nevada, Utah or Virginia, you have a right to opt out of the sale or sharing of, or certain targeting using, your personal information ("PI"), and limit certain uses of your sensitive personal information ("SPI"), as those concepts are defined in the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act, Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, the Florida Digital Bill of Rights, the Oregon Consumer Privacy Act, the Montana Consumer Data Privacy Act, Nevada's Senate Bill 220, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, and any applicable privacy regulations. This Notice is to provide you with information regarding these opt-out rights. All terms not defined in this Notice are as defined in the CPRA and/or other applicable state privacy laws and regulations.
- Your Rights Under U.S. State Laws
Depending on your state of residence, you may have the following rights concerning your personal information:- Right to Know: You can request to know the categories of personal information we collect, the purposes for which we use it, and any third parties we share it with.
- Right to Access: You can request a copy of the personal information we have collected about you over the past 12 months.
- Right to Delete: You can request that we delete your personal information, subject to certain exceptions (e.g., for legal compliance or legitimate business interests).
- Right to Correct: You can request corrections to any inaccurate personal information we have about you.
- Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of your privacy rights.
To exercise these rights, please contact us at [email protected]
- Categories of Personal Information We Collect
- Identifiers (e.g., name, personal information required for surveys, email address, IP address)
- Commercial information (e.g., records of rewards, credits of offers/surveys)
We do not collect sensitive personal information unless explicitly provided by you. - How We Use Your Information
We may use your personal information for the following purposes:- To provide our services and manage your account.
- To personalize your experience on our website.
- To comply with legal obligations.
- To improve our website functionality and develop new features.
- Sharing of Personal Information
We may share your personal information with:- Service Providers: Companies that help us run our business (e.g., payment processors, cloud storage).
- Third Parties: With your consent or as required by law
- We do not "sell" your personal information as defined by the CCPA or other state laws. However, under some state laws, certain activities (like targeted advertising) may be considered a "sale." You can opt-out of such practices if applicable.
- Opting Out of Targeted Advertising and Selling
- If you are a resident of a state with privacy laws that consider certain data uses (such as targeted advertising) as "selling," you can opt-out of these practices:
- Do Not Sell My Information: Unsubscribe
- Please note that even if you opt-out, we may still use personal information for other purposes, such as fraud prevention or legal compliance.
- Notice to California Residents
- If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). In particular:
- Right to Access Specific Information: California residents can request additional details about the categories and specific pieces of personal information we collect
- Right to Limit Use of Sensitive Information: If applicable, you can limit the use of certain sensitive information.
14. Questions or Contact
If you have questions about this Privacy Policy, please reach out to us using our help desk.
If you would like to reach out regarding privacy concerns or would like to contact the Data Protection Officer, please email [email protected].