Last update: October 9, 2024
PRIVACY POLICY – SnapPoints
At SnapPoints Inc. (“SnapPoints”, “we” or “our”), we are committed to protecting the personal information we collect and use.
This privacy policy (this “Policy”) describes our practices regarding the collection, use, disclosure, retention and destruction of personal information in relation to our Services and when you visit our website [www.snappoints.com] (the “Website“). Our “Services” consist of the provision of an integrated solution that allows consumers (“Consumers”) to earn, view, manage and redeem reward points (“Reward Points”) from certain connected loyalty programs (“Loyalty Programs”) when completing transactions with enrolled merchants (“Merchants”).
The person listed below has been appointed to be in charge of the protection of personal information (the “Privacy Officer”). If you have any concerns about the collection, use, disclosure, retention or destruction of your personal information or wish to exercise your rights regarding your personal information, you may contact our Privacy Officer directly.
Name: Keisha Hyde Porchetta
Email: privacy@snappoints.com
Table of Contents
- WHAT IS THE SCOPE OF THIS POLICY?
- HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
- TYPES AND PURPOSES OF USE OF YOUR PERSONAL INFORMATION
- HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
- TO WHOM MAY WE COMMUNICATE YOUR PERSONAL INFORMATION?
- COOKIE NOTICE
- WHERE CAN YOUR PERSONAL INFORMATION BE COMMUNICATED OR STORED
- WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
- POLICY UPDATE
1. WHAT IS THE SCOPE OF THIS POLICY?
This Policy applies to personal information collected or used by SnapPoints in relation to our Services, with the exception of personal information collected in respect of our employees, former employees and applicants for employment with us, to which a separate policy applies (a copy of such policy can be obtained by contacting the Privacy Officer).
This Policy does not apply to the collection, use, disclosure or retention of your personal information by third parties, including Merchants or Loyalty Programs, through their websites. Although some links on our Website may allow you to access content made available by third parties, we are not responsible for their collection of such personal information. We encourage you to read such third-parties’ privacy notices or policies and to direct any complaints, questions or requests related to your personal information collected on such third parties’ websites directly to the relevant third party.
2. HOW AND WHEN DO WE COLLECT PERSONAL INFORMATION?
We collect personal information directly from you, or from other sources, such as Merchants. More specifically, we collect personal information as follows:
- When you are eligible to receive Reward Points from a Merchant, the Merchant may send certain personal information to SnapPoints.
- When you create an account on our web-based platform (the “Platform”), SnapPoints will have access to the personal information you enter to create your account.
3. TYPES AND PURPOSES OF USE OF YOUR PERSONAL INFORMATION
We only use your personal information as necessary to provide our Services, or as required by law. Where applicable, we will obtain your explicit consent regarding the use of your personal information; however, where permitted by law, we rely on the principles of legitimate interest, on implied consent or on specific exceptions provided by law, as applicable. In addition to the purposes listed below, we may use your personal information for security purposes, including to detect, prevent and investigate potential fraud.
Below are the types of personal information we use, the purposes of such use and the applicable retention periods.
| TYPES OF PERSONAL INFORMATION | EXAMPLES | PURPOSES OF USE | RETENTION PERIODS | |
| PERSONAL INFORMATION OF CONSUMERS COLLECTED WHILE TRANSACTING ON MERCHANT SITES | ||||
| Identity and contact information |
● First and last name ● Email address ● Phone number Email address of billing contact
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For identification or authentication purposes This information will be used to find your file and to ensure that your information is associated with your account when you wish to benefit from our Services. Your information may also be used in certain cases to authenticate you, for example, to ensure that you are the right person when you wish to access your file. |
During the term of our business relationship with you (as per applicable terms of use) (the “Business Relationship”) and for 3 years afterwards.
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For contacting you As part of our business relationship with you, we may need to contact you from time to time to: (i) inform you of important changes applicable to our Services or changes to your account; (ii) inform you of changes to our Terms and Conditions of Use or Privacy Policy. |
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To meet our legal and regulatory obligations • Comply with the tax-related obligations or requests; • Defend ourselves in the event of legal claims or demands; or • Perform due diligence. |
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To send you advertising offers, promotions or any other communications In order to offer you more personalized Services, we may use your personal information to communicate offers likely to meet your needs, and promote related merchants based on your preferences. In order to adequately personalize these communications, we may analyze your personal information for profiling purposes. This allows us to avoid sending you communications that do not correspond to your expectations. We will only send you these communications if you have, where required by law, chosen to receive them, and that you may withdraw your consent at any time. |
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Commercial Information and Financial Information
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• Information on transaction with Merchant • Merchant’s customer order number
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To provide you with our Services It is necessary for us to process some of your personal information to determine your eligibility for our Services and Loyalty Programs, to track the Reward Points earned and redeemed as a result of your transactions, to advise you appropriately based on your needs, and to assist you in all your dealings. In achieving this purpose, it is possible that: • We may use certain tools to enable us to make decisions based exclusively on automated processing of your personal information; • We use advanced data analytics tools to develop descriptive and predictive models; and • We use artificial intelligence technologies. |
During our Business Relationship and for 3 years afterwards.
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To manage flow of information between Merchants, our solution and Loyalty Programs We also use your personal information to ensure a seamless interaction between the systems capturing and tracking the Reward Points earned during an online transaction on a Merchant site, our solution and the chosen Loyalty Programs to ensure that you are able to earn, and redeem your Reward Points in an efficient manner. |
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Information about your digital interactions
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● Email address ● Information about your devices ● Route and browsing history only relating to the Services and interaction with Merchants’ sites displaying our widgets
● IP address tracking ● Web beacons and email tracking (emails opened, clicked), SMS tracking |
To personalize your use of our services and to create internal statistics In order to offer you a more personalized service, we may use your personal information to communicate offers likely to meet your needs, and promote related merchants based on your preferences. In order to adequately personalize these communications, we may analyze your personal information for profiling purposes. This allows us to avoid sending you communications that do not correspond to your expectations. To learn more about our use of cookies, please see our Cookie Notice below. |
During our Business Relationship and for 3 years afterwards.
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| PERSONAL INFORMATION OF CONSUMERS COLLECTED THROUGH OUR WEBSITE AND PLATFORM | ||||
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Identity and contact information Loyalty Program information
Information about your communications with us |
● First and last name ● Email address ● History and report of our discussions with you ● Email exchanges ● Online chat ● Customer service telephone recordings ● Loyalty Program number or identification ● Favorite Loyalty Programs ● Transactions with Loyalty Programs through our Services
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For identification or authentication purposes When you register through our widget on a Merchant site, or our web-based application, we require certain information to identify you. This information will be used in particular to find your file and to ensure that your information is associated with your account when you wish to benefit from our and services. Your information may also be used in certain cases to authenticate you, for example, to ensure that you are the right person when you wish to access your file. |
During our Business Relationship and for 3 years afterwards.
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For contacting you As part of our business relationship with you, we may need to contact you from time to time to: (i) inform you of important changes applicable to our Services or changes to your account; (ii) inform you of changes to our Terms and Conditions of Use or Privacy Policy. |
During our Business Relationship and for 3 years afterwards.
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To meet our legal and regulatory obligations • Comply with the tax-related obligations; • Defend ourselves in the event of legal claims or demands; or • Perform due diligence. |
During our Business Relationship and for 3 years afterwards.
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To send you advertising offers, promotions or any other communications In order to offer you more personalized service, we may use your personal information to communicate offers likely to meet your needs, and promote related merchants based on your preferences. In order to adequately personalize these communications, we may analyze your personal information for profiling purposes. This allows us to avoid sending you communications that do not correspond to your expectations. Please note that we will only send you these communications if you have, where required by law, chosen to receive them, and that you may withdraw your consent at any time. |
During our Business Relationship and for 3 years afterwards.
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Information about your digital interactions
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● Email address ● Information about your devices ● Route and browsing history only relating to the Services and interaction with Merchants’ sites displaying our widgets ● Cookies collected and stored ● Duration of visits |
To personalize your use of our Services and to create internal statistics In order to offer you more personalized service, we may use your personal information to communicate offers likely to meet your needs, and promote related merchants based on your preferences. In order to adequately personalize these communications, we may analyze your personal information for profiling purposes. This allows us to know if you are active or engaged on our Website. It also allows us to store your favorite Loyalty Program(s) so that this/these option(s) are pre-selected when you visit other merchant sites. To learn more about our use of cookies, please see our Cookie Notice below. |
During our Business Relationship and for 3 years afterwards.
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| PERSONAL INFORMATION OF MERCHANTS AND THEIR USERS | ||||
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User Account Information *Information related to businesses, including business contact information, is typically not characterized as personal information. However, in the event that it is considered personal information in certain jurisdictions, we will treat this information in the manner indicated in this table, and with the appropriate care.
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● First and last name ● Email address used to sign up on our Platform ● Phone Number ● Address ● Merchants billing information ● ● Statistics about your Merchant website
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For identification or authentication purposes Your information may also be used in certain cases to authenticate the merchant account, for example, to ensure that you are authorized by the merchant to access business accounts. |
During our Business Relationship and for 3 years afterwards.
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Communication As part of our business relationship with you, we may need to contact you from time to time to: (i) inform you of important changes applicable to our services or changes to your account; (ii) inform you of changes to our Terms and Conditions of Use or Privacy Policy. |
During our Business Relationship and for 3 years afterwards.
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To provide our Services When a merchant is subscribed to our program, it may be necessary for us to process certain personal information to create merchant user accounts, and to answer any questions you may have, to handle your complaints and to ensure that the merchant is able to properly benefit from our services. |
During our Business Relationship and for 3 years afterwards.
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| PERSONAL INFORMATION OF CONSUMERS COLLECTED WHEN PROVIDING WEBSITE IMPROVEMENT AND SUPPORT SERVICES | ||||
| Contact Information |
● First and last name; ● Email address ● Phone number |
Communication As part of our business relationship, we may need to contact you from time to time regarding our Website’s maintenance and support. |
During our Business Relationship and for 3 years afterwards.
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| Usage Information |
● Details re: access to our Website: o When you access our Website o What device is used to access the Website o Where you are located based on IP address o Which pages you visit and for how long |
Analytics and Security Compliance As part of our business relationship, we may track usage information for internal analytics purposes and for testing purposes to ensure the safety of our system and safeguard of the information uploaded thereon. |
During our Business Relationship and for 3 years afterwards.
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4. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We are committed to protecting personal information in our possession in accordance with industry standards. Accordingly, we have implemented physical, electronic and operational security measures which comply with the standard industry practices to protect your personal information against loss, theft, unauthorized access, disclosure and unauthorized use. Such security measures are proportionate to the sensitivity of the information.
Please note that the transmission of personal information over the Internet is never completely secure despite the security measures taken by SnapPoints. Although we take precautions to protect your personal information, we cannot guarantee the security of personal information transmitted over the Internet. You choose to transmit information through this channel at your own risk.
5. TO WHOM MAY WE COMMUNICATE YOUR PERSONAL INFORMATION?
Access to your personal information by our employees is limited to those of our employees who require access in order to perform their duties. Our employees are made aware of the need to protect personal information used by us, and we have implemented internal policies to ensure their protection.
We may also need to communicate some of your personal information externally. We require third parties to whom we disclose your personal information to respect the standards set by law and the security measures required to protect your personal information. We never sell your personal information, and will only disclose it where required by law or with your consent.
The following are categories of third-parties to whom we may transfer your personal information in order to provide you with the Services:
5.1 To Our Service Providers
We do business with service providers to whom we may communicate or give access to your personal information when necessary for the performance of the Services.
We put in place written contracts with our service providers in order to:
- Guarantee the confidentiality of your personal information.
- Ensure that the information is used only to perform specific services.
- Ensure that service providers do not retain any personal information when they no longer need it to perform their specific services.
- Ensure that service providers communicate with us immediately in the event of an actual or purported confidentiality incident.
Examples of service providers we may transfer your personal information to are:
- Computer and technical support services
- Communication and marketing firms
- Analytics services
- Law firms
- Cloud hosting service
- E-commerce intermediaries managing the interaction between our operating system, and Loyalty Programs
5.2 To Legal Entities Within Our Group
We may share some of your personal information with other legal entities within our group where necessary to comply with our legal and regulatory obligations and to provide you with our Services.
5.3 To Courts, Law Enforcement Authorities, Regulators, Governmental Officials or Prosecutors
5.4 We may disclose your personal information to comply with a search warrant, to respond to an investigative body, to comply with a court order, if we believe disclosure is necessary to comply with applicable laws, if required by law, to pursue a legal claim or to assert a defence.
5.5 To Other Third Parties
We may need to disclose your personal information to other third parties in certain specific circumstances, always within the limits permitted by law or after obtaining your consent, for example:
- As part of a business transaction (a merger, an acquisition by another enterprise, obtaining a loan or financing, for example); or
- in the event of insolvency or bankruptcy;
6. COOKIE NOTICE
We may use cookies on our Website. Cookies are essentially text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site or use an application. They can improve your experience while you navigate on our Website in different ways; namely, cookies can be used to remember your preference settings and track your use of our Services and operating system so that it can be improved to meet your needs.
The following is a list of the types of cookies we may use in the provision of our Services:
- Essential Cookies: These are necessary for the proper functioning of our web application used to offer our Services. They enable basic features like page navigation and access to secure areas.
- Analytical/Performance Cookies: These cookies help us analyze how visitors interact with our web application used to offer our Services. They provide information on areas such as the most visited pages, time spent on the site, and any error messages received, allowing us to improve our operating system’s performance.
- Functionality Cookies: These cookies remember your preferences, such as language or region, to enhance your user experience.
- Targeting/Advertising Cookies: These cookies are used on our Website to deliver content more relevant to you and your interests. They may also be used to measure the effectiveness of an advertising campaign.
You can set your cookie preferences by clicking the following link [www.snappoints.com/cookies]. Unless the cookie is necessary for the functionality of our Website, you can refuse or withdraw your consent to our cookies at any time even if you have previously consented. Please remember that if you do not consent to our essential cookies, parts of our Website will not work.
- Please note that we also use local storage of information (“Local Storage”) in your web browser for the following purposes: Streamline performance, such as storing the list of Loyalty Programs a user of the Website has linked his account to; and
- Save user preferences and login information.
Contrary to cookies, Local Storage data remains on the user’s browser and is not automatically sent to SnapPoints’ servers.
7. WHERE CAN YOUR PERSONAL INFORMATION BE COMMUNICATED OR STORED?
Our subcontractors, service providers and other third parties to whom we disclose your personal information may operate in different jurisdictions. In all cases, we ensure that your personal information is handled securely, and that a written agreement exists with any such third party ensuring that your personal information is stored in compliance with applicable laws and this Policy. We conduct privacy impact assessments when appropriate and where required by applicable laws. We will not disclose your personal information unless we are satisfied that it will be adequately protected.
8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION?
8.1 Access to your personal information
Subject to the exceptions provided by law, you have the right to request a copy of, or access to the personal information we hold about you. You may exercise your right of access by contacting our Privacy Officer. Access to your personal information is free of charge. However, if the request is excessive or unfounded, we may charge an administration fee for transcribing, reproducing, transmitting or requesting additional copies of your personal information. We will inform you of any such charges before processing your request;
We generally respond to all requests for access within 30 days of receipt of any such request. When we are unable to grant access, or if additional time is required to fulfill a request, we will notify you in writing.
8.2 Rectification of your personal information
If you consider that your personal information is inaccurate or incomplete, you may rectify it by contacting our Privacy Officer. It is your responsibility to inform us of any changes to your personal information so that we can ensure that your personal information is kept up to date.
8.3 Obtain information on the processing of your personal information
You have the right to obtain additional information relating to the processing of your personal information. If you cannot find the answer to your questions in the Policy, you can contact our Privacy Officer.
8.4 Withdraw your consent
When you give your consent for secondary purposes, in other words, purposes that are not essential to offer you our Services, you may withdraw it at any time, without any consequence, by contacting our Privacy Officer. However, if you refuse to provide us with personal information that is necessary for us to provide you with our Services or that is required by law, we may no longer be able to provide you with our Services. In this case, we may have to cancel our commitment to you. You will, however, be informed of the occurrence of such a situation.
8.5 Dissatisfaction with the management of your personal information
If you have any questions, concerns or dissatisfaction with this Policy or with the management of your personal information, you may contact our Privacy Officer.
9. POLICY UPDATE
This Policy takes effect on the date mentioned at the top of the page and replaces all previous versions. The history of previous versions of this Policy can be obtained by request to our Privacy Officer.
This Policy may be updated at our sole discretion based on changes in our practices and legislation on the protection of personal information. When this Policy is updated, the changes will be specifically brought to your attention and a notice will be available on the home page of our Website. When the changes are of a material nature or require your consent, we will notify you by email if we have your email address.