PRIVACY POLICY

image

This is the privacy policy (“Privacy Policy”) of XPayBack Pte Ltd and its subsidiaries, affiliates, brands, related and/or associated companies/brands, and jointly controlled entities (including all of their shareholders, directors, employees, suppliers, contractors, and/or permitted persons) collectively referred to as "XPayBack", “we”, “us” or “our”. Our commitment is to respect and protect your privacy online. This Privacy Policy explains how we collect, use, disclose, store, transfer, and/or process your personal data.

This Policy governs your use of the websites, products, apps, browser extensions, and services that we offer you, including the xpayback.com website (the “Website”), XPayBack, XPayBack App, XPayBack Loyalty Program, XPayBack browser extension, and any other products, including trial versions introduced from time to time in the future (the “Services”). This Policy does NOT apply to information we collect offline, you provide to, or that is collected by any third party (except as otherwise provided below).

We are committed to providing you with the best online shopping and cashback experience possible. Our Privacy Policy explains how we collect, use, disclose, and protect the Personal Information of our customers and users. It applies to all Personal Information collected by us on www.xpayback.com (the “Site”), the XPayBack mobile application, and any other websites or mobile applications that link to this Policy, as well as during any written, electronic, and oral communications (collectively, the “Services”). We collect Personal Information to help you place and receive orders and to improve the XPayBack’s service.

To process, administer, and/or manage your relationship with us, we will necessarily need to collect, use, disclose, store, transfer, and/or process your personal data. This Privacy Policy applies to personal data about you and/or individuals provided by you, possessed by us, or that we obtain about you, whether now or in the future. We will only process your personal data in accordance with the prevailing personal data protection and privacy laws of the countries we operate in and this Privacy Policy.

By accessing, browsing, downloading, and/or using our Platform and/or Service or by dealing with us, you acknowledge that you have read and understood this Privacy Policy and agree to us processing your personal data in accordance with the manner set out in this Privacy Policy, as may be amended from time to time.

We may modify this Privacy Policy at any time. We strongly recommend that you periodically review our Privacy Policy as posted on the App/Web.

Customers are advised to read and understand our Privacy Policy carefully, as by accessing the website/app, you agree to be bound by the terms and conditions of the Privacy Policy and consent to the collection, storage, and use of information relating to you as provided herein. If you do not agree with the terms and conditions of our Privacy Policy, including in relation to the manner of collection or use of your information, please do not use or access the website/app.

To use XPayBack's services, you must log in with your registered mobile number, username, email address, or Facebook account and password. By uploading or posting any content, you automatically grant XPayBack a royalty-free, perpetual, irrevocable, transferrable, worldwide license to use, modify, reproduce, adapt, publish, distribute, perform, transmit, and display the content in any form, media, mode of delivery or technology now known or later developed. This license also allows XPayBack to incorporate the content into other works and permit others to do the same, including XPayBack's co-brand partners, and to permit other users to access, reproduce, distribute, publicly display, prepare derivative works of, and publicly perform your content via the Services.

You must not upload any content that belongs to another person, is grossly harmful, harassing, blasphemous, defamatory, obscene, pornographic, paedophilic, libelous, invasive of another’s privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner, or harm minors in any way. You must not upload content that infringes any patent, trademark, copyright, or other proprietary rights or violates any law for the time being in force. You must also not deceive or mislead the reader/viewer about the origin of any information or contain any information that is grossly offensive or menacing in nature, impersonate another person, or contain software viruses or any other computer code, files, or programs that are designed to interrupt, destroy or limit the functionality of any computer resource.

You are solely responsible for safeguarding your login details, including your username and password, and XPayBack shall have no liability whatsoever. If you are under the age of majority as per the laws of your country of residence, you may not register for an account. XPayBack does not include any age-inappropriate content, and parents/adult guardians are required to monitor/regulate the content being viewed by their wards who have not attained the minimum age. Unless expressly stated, XPayBack does not promise to provide you with any support for the Services, and XPayBack reserves the right to charge fees for use of or access to the Services (and any associated support), in XPayBack’s sole discretion. XPayBack prohibits sending unsolicited emails or messages using the Services or engaging in commercial activity on non-commercial properties or apps without XPayBack's prior written consent. You may not engage in conduct or activity that is disruptive to the Services or the experience of other users.

We collect various types of information from you depending on how you use our Services, including Personal Information. Personal Information refers to information that relates to an identified or identifiable natural person. The following are the categories of Personal Information we may collect. Certain types of Personal Information may fall under more than one category.

Identifiers: We may collect your name, phone number, cryptocurrency wallet address, IP address, email address, display name, social networking website user account names, or other addresses used to receive communications and information about the devices you use to access the Services. This includes unique identification numbers associated with your mobile device or through the application programming interface, mobile carrier, device processes, device type, model and manufacturer, mobile device operating system, brand and model, device name, and battery life (collectively, "Device Information").

Demographic information: We may collect your geographical location data, including GPS coordinates (e.g., latitude and/or longitude), city, and country.

Commercial information: This includes information that enables us to determine your lifestyle, interests, and activities, including purchasing tendencies and order history (such as the XPayBack vouchers you purchase and redeem), areas of interest, information collected through your interactions with social networks, information about persons for whom you have purchased XPayBack vouchers as gifts or who have bought XPayBack vouchers as gifts for you, and information about friends who refer you or whom you have referred. We may also collect and store information about the websites you view, even when you are not interacting with the XPayBack Browser Extension. This includes URLs of web pages visited, general information about the visited web page, product searches, product search results, information about products added to cart, confirmation page details, and other product information (collectively, "Passive Data").

Location information: This includes information related to your state/province, district, city, or neighborhood, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Service.

Sensory data: We may collect your picture.

Financial information: This includes information collected from you as needed to process payments for XPayBack vouchers or other products or services that you buy, or as provided by you to administer your participation in optional services and programs, such as your payment card number, expiration date, and a card verification number.

Internet and network activity information: This includes information about your browsing behavior, search history, and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons.

Inferences regarding preferences and other characteristics: This includes our assessment of the types of products or services you may have an interest in.

We may also collect information that does not generally identify you but may become associated with your account. We may use information that does not identify you for any permissible business purpose under applicable law.

Please note that we do not collect, transmit, store, or otherwise process any of your Personal Information through the Privacy Apps.

XPayBack's web extension/button only gathers information from shopping sites that are partnered with XPayBack. The extension does not collect browsing data from your search engine history, information from your emails, or data from websites that are not affiliated with XPayBack.

To enhance your shopping experience and ensure our products are functioning correctly, XPayBack's web extension/button gathers information on how users interact with our services on our partner merchants' sites. This information includes browser type, operating system, error logs, and event stamps. However, XPayBack's extension does not collect personally identifiable information such as names or email addresses, or sensitive data like credit card or bank details.

We assume that all personal data you provide is accurate and complete, and none of it is misleading or outdated. You must update us promptly if there are any changes to your personal data. Failure to maintain accurate, complete, and up-to-date information, including an expired or invalid payment method, may result in your inability to access and use the Platform and/or Service.

The term "personal data" refers to any information, whether true or not, that can identify an individual or that can be linked with other data to identify an individual, including data in our records that we may update from time to time. The type of data that XPayBack collects from you depends on the products, services, and promotions you use or subscribe to.

XPayBack collects personal data to enable our platforms and services to work correctly and to understand how they function on various devices and browsers. We may collect identity data, contact data, account data, transaction data, technical data, profile data, location data, usage data, marketing, and communication data. The data collected varies based on the purpose of collection, and we may process it by collecting, recording, altering, holding, storing, transferring, erasing, correcting, retrieving, destructing, aligning, combining, disclosing, and/or deleting it.

XPayBack collects Personal Data related to individuals in various ways, including when they provide their contact details after attending events, visiting or using their websites, submitting forms, signing up for alerts or newsletters, participating in competitions or surveys, submitting job applications, or when referred to them by business partners or third parties.

XPayBack may also collect Personal Data from individuals through various sources, including when they voluntarily provide information, such as when registering for an account, submitting forms, or participating in activities or surveys. They may also collect Personal Data automatically when individuals use their services, such as IP addresses and website activity. Additionally, XPayBack may receive Personal Data from third parties, such as brand partners, data analytics providers, and social media platforms.

XPayBack follows this Policy when using Personal Information provided by third parties, but they cannot control how third parties collect or use the information. Individuals should review third parties' privacy policies for more information about their information practices.

XPayBack takes the security of Personal Data seriously and has implemented strict measures to ensure its safekeeping. These measures include:

  1. Using a secure and encrypted 128-bit SSL connection on all web pages where Personal Data is transmitted.
  2. Storing Personal Data only on servers with proper security safeguards in place to prevent security breaches.
  3. Limiting access to Personal Data to authorized personnel only.
  4. Implementing strict verification processes to prevent unauthorized access to Personal Data.
  5. Securely destroying Personal Data when it is no longer needed for business or legal processes.

This Privacy Notice describes how we may use the information we collect from you. Our use of your Personal Data includes the following:

  • Providing and Improving the Services – We use your Personal Data to operate, maintain, and improve the Service and related programs, features, and functionality. This includes fulfilling and processing your orders and cashback, tracking your transactions with our merchant partners, and providing additional products, services, and benefits.
  • Marketing the Services – We may use your Personal Data to provide interest-based ads, push notifications, and offers for products and services from us and our business partners. With your prior consent, we may also send you newsletters, rewards, discounts, promotion codes, events, and general information about the Services.
  • Administering the Services – We may use your Personal Data for any lawful business purpose in connection with administering the Services. This includes activating or deactivating services, administering promotional events and contests, and conducting corporate social responsibility projects.
  • Security and Compliance – We may access, use, and share your Personal Data for purposes of health, safety, and other matters in the public interest. This includes detecting and preventing fraud and other crimes, conducting internal audits, and meeting legal, regulatory, and other requirements.
  • Business Transfers – In the event of a sale or other transfer of our business, your Personal Data may be among the transferred assets.
  • Job Applications – We may use your Personal Data to process job applications, recruitment and selection, and processing and administering employment records.
  • Customer Service – We may use your Personal Data to respond to your requests and inquiries, provide directory assistance, and provide updates relating to our products, services, or policies.

We will not use your Personal Data for purposes other than what we have informed you, or which we are permitted or required under local law and regulations. We will retain your Personal Data for only as long as there is a business or legal need.

XPayBack offers a referral program that allows users to invite friends and family to sign up for our services. Occasionally, we provide promotional rewards to users for referring friends and family who sign up and place an order through their referral link. To help facilitate this process, we may request access to your mobile device's address book, which allows you to send referral emails or SMS messages to selected contacts. By sending a referral, you agree to XPayBack sending your public profile image to the contacts you select to receive a referral link. You also represent that you have obtained the necessary consent from your friends or family members to provide their name and email address to XPayBack for the referral program.

If you are referred to XPayBack through one of our referral programs or someone attempts to refer you, we may share your name, whether you have signed up for XPayBack, whether you are a new customer, and whether you have made a qualifying order with the person(s) who referred you.

We will not disclose your personal data to any third party without your consent, except in certain circumstances. For example, we may disclose some of your personal data to our subsidiaries, related or associated companies, business partners, vendors, agents, and service providers who work with us to deliver services you have subscribed to. This includes third-party service providers who provide operational services to XPayBack, such as telecommunications, information technology, payment processing, technical services, and market research, as well as professional advisers like auditors and lawyers. We may also disclose your personal data to relevant regulators, statutory boards or authorities, or law enforcement agencies as required by any laws, rules, guidelines, and regulations or schemes.

We may send you promotional emails from time to time to update you about the latest offers, rewards, deals, products, or services from XPayBack or our preferred partners. If you no longer wish to receive these emails, you can unsubscribe through the link provided in the email.

Finally, we may disclose your personal data to any other person reasonably requiring it in order for us to operate and maintain our business or carry out the activities set out in the Purposes or as instructed/authorized by you. However, we will never sell, rent, transfer, or disclose any of your personal data to any third party without your consent.

As a user of XPayBack, you have certain rights regarding your personal information. You can update your personal information whenever necessary. You can also request that XPayBack delete your personal information, although some exceptions may apply based on applicable law.

In compliance with prevailing personal data protection and privacy laws, you have the right to request access to, a copy of, or an update/correction of your personal data that we hold. However, we may charge a small fee as permitted by applicable law to cover the administration costs involved in processing your request. Please note that we reserve the right to rely on statutory exemptions and/or exceptions to collect, use, and disclose your personal data.

You also have the right to withdraw your previously given consent to us through written notice, subject to any applicable legal restrictions, contractual conditions, and a reasonable duration of time for the withdrawal to take effect. However, withdrawing your consent may have legal consequences, and depending on the extent of the withdrawal, we may not be able to continue our existing relationship with you or terminate any contract you have with us.

When you use our Services on the Platform, we place a persistent cookie on your computer. This cookie allows us to track your purchases with our participating retailers and award cashback, rewards, or points to you. Without enabling persistent cookies on your computer, you won't be able to earn cashback or points for your online shopping through our platform.

You have the option to enable or disable cookies by adjusting the settings in your browser. However, if cookies are disabled, you may not be able to use all the interactive features of our platform.

Third-party cookies may also be used on our Services to enhance your experience and help us tailor our Services to your needs. For instance, Google Analytics may collect your Personal Information using cookies on our behalf to analyze how you use our Services.

If you have any questions, complaints, or requests regarding your personal data, you can adjust the settings in your account or contact us at info@xpayback.com or through the communication channel on the Platform.

This Privacy Policy was last updated on April 19, 2023.