Rewards Privacy Policy USA

Please note that Teya Rewards Ltd. was formerly known as Yoyo Wallet Limited. Teya Rewards Ltd. provides loyalty, rewards and payment services.

WHERE THE WORDS “WE”, “US” OR “OUR” ARE USED IN THIS DOCUMENT, THEY ARE ALL REFERENCES TO TEYA REWARDS LTD., A COMPANY INCORPORATED IN ENGLAND AND WALES (UNDER COMPANY REGISTRATION NUMBER 08515940) AND WHOSE REGISTERED OFFICE IS AT THIRD FLOOR, 20 OLD BAILEY, LONDON EC4M 7AN, UNITED KINGDOM. WE ARE AUTHORISED BY THE FINANCIAL CONDUCT AUTHORITY UNDER THE ELECTRONIC MONEY REGULATIONS 2011 (FIRM REF. 900645) FOR THE ISSUING OF ELECTRONIC MONEY. WE ARE ALSO REGISTERED AS A DATA CONTROLLER WITH THE UNITED KINGDOM INFORMATION COMMISSIONER’S OFFICE UNDER REGISTRATION NUMBER ZA019543. WE TREAT YOUR INFORMATION VERY CAREFULLY AND WE HAVE WRITTEN THIS DOCUMENT TO HELP YOU UNDERSTAND WHAT INFORMATION WE COLLECT, WHO HAS ACCESS TO IT AND FOR WHAT PURPOSES. IF YOU ARE IN THE PROCESS OF CREATING AN ACCOUNT WITH OR HAVE ALREADY DONE SO, YOU SHOULD READ THIS DOCUMENT IN CONNECTION WITH OUR AGREEMENT WITH YOU. THIS DOCUMENT IS NOT PART OF THE AGREEMENT AND IS NOT BINDING ON YOU (IT IS FOR INFORMATION ONLY).

You can ask us to stop processing your information at any time by emailing us at rewardshelp@teya.com (although, as some types of information processing and sharing are essential to the provision of our services or certain aspects of those services, if you do ask us to stop processing your information we may not be able to provide some of the services or continue to provide the services in the same way). You can also stop us processing your information by closing your account or by emailing rewardshelp@teya.com. However, even if you do ask us to stop, we may have other lawful grounds for processing your information (for example, to comply with our statutory or regulatory duties or the orders of a court).

This Privacy Notice applies to all personal data we process as a controller in respect of our users, customers and other business partners. It does not apply to the extent we process personal data in the role of a processor or service provider on behalf of our customers or partners.

We encourage you to read the remainder of this Privacy Notice to understand more about how we process your data.

HOW DO WE COLLECT INFORMATION ABOUT YOU?

We collect information about you when you use our website, register to open an account with us, use our apps or services, make transactions and when you contact us.

We might also receive information about you from someone else (for instance, from your bank or social media accounts or from your employer where you represent one of our customers or business partners). We will let you know if this happens and we are not already processing information about you.

WHAT INFORMATION DO WE COLLECT?

We may process the following types of information about you:

• Information to identify you. This might include your title, name, postcode, email address, mobile phone number, date of birth, your billing and shipping address and any other data you use to set up your account, to log-in or to use our services;

• Third party sourced data. Information that you grant us permission to collect, and public information, from third party apps or websites such as, but not limited to, banks (and other financial institutions) and social media sites;

• Information about how you use our apps or services. This might include how you interact with our apps and services, the goods or services purchased, the rewards and gifts you earn and redeem (and when and where you do so), the transaction ID, the price paid or discount given, the location and time of the transaction, rewards earned/ redeemed and the outcome of that transaction. It might also include information about campaigns and how you participate;

• Internal account attributes. These might include unique identifier numbers (UIDs), transaction status, if you have verified your phone number or email address and internal notes recording actions taken on your account;

• Your preferences. Information about your use of our apps and services including location or demographic data, language preferences, notification settings, opt-in/ opt-out from direct marketing and stated preferences;

• Network, hardware and website. Information that we obtain from your device or browser (such as IP address, operating system, version and device identifiers. This also includes the use of cookies (for more information on cookies, please see our policy on cookies);

• Payment information. Information about your payment instrument (e.g. payment debit/ credit card), which may include (the Bank Identification Number (BIN) and the last four digits of the card number, the card type, postcode, expiry date, country of issue, expiry date);

• Surveys, feedback and complaints. Information that you have opted to provide to us in response to customer research and satisfaction surveys, support functions or complaints;

• Professional details if you represent a customer or business partner. This might include your employer, job title, professional email address, contact number and copies of identity and proof of address.

• For some services we are unable to provide you with our services unless you provide us with your name, date of birth phone number, email address and transaction data, as we are required to process this in order to fulfil certain regulatory requirements or our contractual obligations under the user terms.

WHAT DO WE USE YOUR INFORMATION FOR?

We will only use your personal data when we are allowed to and only where:

• we need to perform the contract we are about to enter into or have entered into with you or the customer or business partner you represent;

• we have a legitimate interest in processing your personal data and your interests and fundamental rights do not override that interest;

• we need to comply with a legal or regulatory obligation; or

• you have given your consent.

We use your information:

to provide our services. This might include:

• enabling a Merchant to link Engage to their Facebook account to push campaign announcements directly to their Facebook page. We will do this because you have given us your consent or because we have a legitimate interest in this to develop our services;

• processing and managing an application for our services as well as how you access and use our apps and services. We have a legitimate interest in this to understand how users interact with our app or services and to comply with our regulatory obligations and to take steps to enter into a contract with you;

• processing transactions using our services (including for the purchase of goods or services or redemption of rewards). We will do this to perform the contract we have with you;

• communicating details regarding delivery, collection or pay at table. We will communicate with you as part of performing our contract with you;

• determining if you have certain payment or banking apps stored on your device which would enable you to utilise our “pay by bank app” feature. We have a legitimate interest in this so we can offer you our services;

• communicating with you about any prize draw, reward or offer programmes you participate in using our services. We have a legitimate interest in this to provide you with adequate support or information and to assess how users interact with our app or services. We may also communicate with you as part of performing our contract;

• enabling you to use social features, such as sending vouchers and other shareable items to other users. We have a legitimate interest in this so we can offer you our services;

• facilitating the negotiation of any merger, sale of company assets, financing, acquisition or divestiture of all or a portion of our business. We have a legitimate interest in this in order to conclude any of these transactions;

• recommending things we think you’ll like such as nearby merchant outlets (where you have switched on your location settings in the app and on your phone). We will do this because you have given us your consent to use your location data when you have switched on your location settings;

• recommend things we think you’ll like such as, merchants you like to shop with and the things you like to buy (for more information regarding our profiling activities, please see below). We will do this because you have given us your consent or because we have a legitimate interest in this to develop our services; and

• providing electronic receipts. We will do this as part of performing our contract with you; and

• communicating with you if you represent one of our customers or business partners. We will have a legitimate interest in this communication to establish our commercial relationship with the customer or business partner and as part of performing our contract with them.

to improve our services. This might include doing things like:

• measuring the performance of our app and services. We have a legitimate interest in this to develop our product and services and to promote our company, products and services;

• making sure you use the right version of the app for where you are (like prompting you to change the language or location settings). We have a legitimate interest in this to ensure that you benefit from all of our services;

• conducting statistical analysis about how you and other users of our services make use of those services. We have a legitimate interest to make improvements to our services or to develop new services;

• providing software updates so that they deliver improved features and functionality or fixing bugs. We have a legitimate interest in this and may also do this to ensure that we can continue to perform our contract with you;

• changing how we run our business, organise ourselves and deliver the services to you. We have a legitimate interest in this to develop and improve our product and services; and

• personalising parts of the apps and service to your tastes and preferences (for more information regarding profiling, please see below). We have a legitimate interest in this to develop our business and assess how users interact with our app or services;

• to communicate with you about marketing or promotional campaigns or to send you our insights (but, unless you represent a customer or business partner, only where you have told us you want to receive these communications and you have not told us to stop sending you messages). Should you opt in to receive marketing or promotional campaigns or insights from a business partner via our apps or services, you acknowledge that the business partner shall similarly communicate with you in this respect (only where you have explicitly consented to receiving these communications and you have not opted out). This might include:

• sending you Insights;

• sending you messages about sales, promotions or prize draws offered by us or one of our customers or business partners;

• personalising parts of the service to your tastes and preferences (please see below for more information on profiling); and

• creating personalised promotions based on your purchasing preferences and behaviour;

• getting in touch if we need to tell you about something, like a change to our policies or issues with our apps or services (service notices). In some cases, we will do this to perform the contract we have with you. Alternatively, we will have a legitimate interest in giving you these service notices;

• for business, regulatory and legal obligations, like:

• obtaining and maintaining insurance policies;

• dealing with any requests you make or content you submit;

• getting in touch if we need to tell you about something, like a change to our policies or issues with our apps or services;

• managing risk (for instance, by assessing payment and funding risks, identifying, preventing, detecting or tackling fraud, money laundering and other crime and carrying out regulatory checks); and

• complying with any court order or applicable law, regulation or governmental request (e.g. tax authorities) and to protect our rights or property, or the security or integrity of our business or services.

We may analyse the personal data we hold about you to recommend merchants and products that we think you might be interested in. We may also analyse the personal data in order to detect and prevent fraud and financial crime.

HOW DO WE PROTECT YOUR INFORMATION?

We hold personal data about you at our own premises and with the assistance of third party service providers. We use third party service providers to perform a number of functions on our behalf including to host our platform, to send messaging on our behalf, to provide support services to you (including to provide translations to and from the English language) and to process transactions for the purchase of goods and services and to process invoicing for or by our customers or business partners.

Your personal data may be processed outside the European Economic Area (EEA) by our staff or the staff of our service providers. This might be in Brazil, Mauritius, Singapore, South Africa or the USA. Where we do this, we will ensure that one of the following safeguards are in place:

• the European Commission has decided the relevant country ensures an adequate level of protection;

• we have agreed the Standard Contractual Clauses (SCC) with the recipient of the personal data. These SCC are approved by the European Commission as providing adequate protection for your personal data; or

• the recipient of the data has in place binding corporate rules approved by the European Commission as providing adequate protection for your personal data.

Whenever we share your personal data with third parties, we will take reasonable steps to ensure that your privacy rights continue to be protected under the applicable data protection legislation. By sharing your personal data with us and interacting with the services, you consent to the storing, processing and/or transfer described in this part of the Privacy Notice.

If data is transferred to a country where appropriate safeguards need to be put in place, we would be happy to provide information pertaining to such safeguards on request. You can contact us for this information by emailing rewardshelp@teya.com.

We take reasonable measures, including administrative, technical and physical safeguards, to protect your personal data from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction.

WHO DO WE SHARE YOUR PERSONAL DATA WITH AND WHY?

Transfers to other data controllers

• Customers and other business partners. Where you have registered using a version of our app branded for one of our customers or business partners, we may share information about you, your account and how you use the app and service with that customer or business partner. We might also share your information with a merchant to investigate and resolve support issues you experience or where you notify us of a complaint about a merchant or the goods or services you purchase from them.

• Linking accounts. Where you have linked your Teya account to another account you hold (like a bank account or social media account) we will share information with the operator of that account.

Where we do share your information in this way, the recipient will become a new data controller of your information and will contact you to let you know about this and how they use and protect your information.

The information we share might include:

• information that can be used to identify you (such as name, email address and phone number);

• information about how you use our apps or services;

• detailed transaction data (including about payments you make, refunds and chargebacks and loyalty and rewards you earn and redeem);

• your preferences (but only as they relate to that recipient); and

• where you have raised a support issue or notified us of a complaint about a merchant or the goods or services you purchase from them, the nature of the issue or complaint.

As a fraud prevention measure, we send your full name and postcode to payment service providers when you link a payment instrument to your account. We do this to ensure that your personal details match with the cardholder details and that you are the legitimate cardholder.

Where you make payments using our services, we share your data with a payment service provider (PSP) and they process your transactions. The PSP may share your information with third parties including regulators, your bank and the operators of the card schemes. Where the PSP shares your information with Mastercard, it will process your information under the Mastercard Binding Corporate Rules (as amended from time to time and currently available here: https://www.mastercard.co.uk/content/dam/mccom/global/documents/mastercard- bcrs-february-2017.pdf). You have the right to enforce these rules as a third party beneficiary.

Where you have placed orders via our services for delivery, collection or pay at table, we will share the details of your order with the merchant you have placed the order with. These details may include your first name, the details of your order, and your delivery address.

Unique Identifier Number. When you register with us, we create a UID linked to your account and transaction history. This may be sent to third parties who provide payment services to our customers or business partners to enable them and us to match incoming funds to you and the transactions you initiate. This may be sent to third parties who provide payment:

Social features. If you are in another Teya user’s mobile phone address book, they can see whether you use our apps or services when they select the intended recipients for vouchers or other shareable items. You can opt out of this feature and become “invisible” to other Teya users by changing your settings within the app you are using. If you send a voucher or other shareable item to another Teya user, they will see the first and last name you used when you signed up to a Teya account. We do not view, share, or store your address book contacts to enable this feature.

Other uses. We may share your information with third parties, including law enforcement agencies for any of the following:

• to fulfil our obligations under our contract with you (or the customer or business partner you represent), or as required by applicable law or payment scheme rules;

• to assess financial and insurance risks, risk of fraud, sector risk and credit risk;

• in relation to any breach of, or to enforce, our contact with you (or the customer or business partner you represent);

• to recover debt or in relation to your insolvency;

• to develop products, services and our systems;

• to detect, investigate and prevent fraud or other crime;

• to respond to requests from courts, law enforcement agencies and other governmental or regulatory authorities or agencies; and

• to protect our rights, privacy and property, and that of our business partners.

We may also share your information with:

• our service providers. Service providers help us with things like payment processing, website hosting, database hosting, data analysis, information technology and related infrastructure, customer services, email delivery and anti-fraud services. These third parties are authorised to use your information only as necessary to provide their services to us and we take appropriate steps to ensure that third parties protect your information; and

• third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We shall endeavour to ensure such third parties are bound by confidentiality obligations in relation to such information.

HOW LONG DO WE PROCESS YOUR INFORMATION FOR?

In most cases we will process your information only for as long as required to provide the services or until you close your account or ask us to stop processing your information.

You can ask us to stop processing your information or change the way in which we use it by:

• changing the settings in our app or services (to effect changes to things like your location settings, language settings, notification settings, access to your contacts list); or

• otherwise, by:

• emailing rewardshelp@teya.com; or

• writing to us at Customer Support (Data Protection), Teya Rewards LTD., Third Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN.

There are some exceptions to this, however. We may have other lawful grounds for processing your information (for example, to comply with our statutory or regulatory duties or the orders of a court). For example, we might be required to retain your personal data for a longer period (usually up to six years after you close your account or tell us to stop but this may vary depending on the territory in which you use the service) in order to comply with applicable law, tax obligations or regulatory requirements and for the establishment, exercise and defence of legal claims. This might apply to information about the transactions you make, when and where you make transactions and the information we hold about you for fraud and other crime prevention purposes. If we do retain your information in this way, we will cease other forms of processing and we will continue to keep your information secure.

YOUR RIGHTS

You can request a copy of the personal data we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out. For further information, please contact us by emailing rewardshelp@teya.com with the subject “Data subject access request”.

You can correct, restrict, object to our use of or ask us to delete your personal data at any time by emailing rewardshelp@teya.com  with the subject “Data subject change request”. If the processing is based on the legal grounds of consent or fulfilment of contract, you have the right to portability. This means that you can receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and have the right to transfer this data to another data controller.

You have an absolute right to object to the processing of your personal data for direct marketing. You also have the right to recall your prior given consent. The withdrawal of your consent does not affect the lawfulness of the processing based on the consent before its withdrawal and we may continue processing your personal data based on other legal grounds.

If you have any questions about this document or in relation to how we use your personal data, please contact us by:

• emailing rewardshelp@teya.com; or

• writing to us at Customer Support (Data Protection), Teya Rewards Ltd., Third Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN.

COMPLAINTS

If you wish to make a complaint about how we process your information, please contact us by:

• emailing rewardshelp@teya.com; or

• writing to us at Customer Support (Data Protection), Teya Rewards Ltd., Third Floor, 20 Old Bailey, London, United Kingdom, EC4M 7AN.

The Information Commissioner’s Office regulates data protection and privacy matters in the UK and you have the right to make a complaint to the Information Commissioner’s Office at any time about the way that we use your information. You can find more details at ico.org.uk however we should appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office.

UPDATING OUR PRIVACY NOTICE

We may update this Privacy Notice from time to time. When we do so, we will post the new version on our website and we will inform you about ask you to accept the new version when you next use our app.

COOKIES

You can set your browser (and some mobile device settings) to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of our app and our services may become inaccessible or not function properly. For more information about the cookies we use, please see our policy on cookies.

Our Data Retention Policy

WHERE THE WORDS “WE”, “US” OR “OUR” ARE USED IN THIS DOCUMENT, THEY ARE ALL REFERENCES TO TEYA REWARDS LTD., A COMPANY INCORPORATED IN ENGLAND AND WALES (UNDER COMPANY REGISTRATION NUMBER 08515940) AND WHOSE REGISTERED OFFICE IS AT THIRD FLOOR, OLD BAILEY, LONDON EC4M 7AN, UNITED KINGDOM. WE ARE AUTHORISED BY THE FINANCIAL CONDUCT AUTHORITY UNDER THE ELECTRONIC MONEY REGULATIONS 2011 (FIRM REF. 900645) FOR THE ISSUING OF ELECTRONIC MONEY. WE ARE ALSO REGISTERED AS A DATA CONTROLLER WITH THE UNITED KINGDOM INFORMATION COMMISSIONER’S OFFICE UNDER REGISTRATION NUMBER ZA019543. WE TREAT YOUR INFORMATION VERY CAREFULLY AND WE HAVE WRITTEN THIS DOCUMENT TO HELP YOU UNDERSTAND WHAT INFORMATION WE COLLECT, WHO HAS ACCESS TO IT AND FOR WHAT PURPOSES. IF YOU ARE IN THE PROCESS OF CREATING AN ACCOUNT WITH OR HAVE ALREADY DONE SO, YOU SHOULD READ THIS DOCUMENT IN CONNECTION WITH OUR AGREEMENT WITH YOU. THIS DOCUMENT IS NOT PART OF THE AGREEMENT AND IS NOT BINDING ON YOU (IT IS FOR INFORMATION ONLY).

Please note that upon closure of your account we are required to cease processing your data other than where data retention is required by law. Following the retention periods outlined below, your data will be deleted permanently and irrevocably.

This policy sets the required retention periods for specified categories of personal data described in the Privacy Policy.

HOW LONG DO WE RETAIN YOUR PERSONAL INFORMATION?

Being a regulated company, we are required by law to retain your personal data for up to five years after you close your account.

WHY DO WE RETAIN YOUR PERSONAL INFORMATION?

In line with Article 6 of the GDPR, we will retain this data for following reasons:

• Fraud prevention under Article 6(1)(c) of the GDPR. As set out in Teya Rewards’s privacy notice, Teya will retain your data to comply with statutory and regulatory obligations; this includes Anti-Money Laundering and fraud prevention legislation and regulations.

• Retention of identification information for “Know Your Customer” purposes under Article 6(1)(c) of the GDPR. As an FCA-regulated company, Teya is subject to the Money Laundering Regulations 2017 (“MLR 2017”), which require Teya to retain records of the following for at least 5 years following the termination of a business relations (regulation 40):

a copy of any documents and information obtained to satisfy the Customer Due Diligence requirements set out in regulations 28, 29 and 33 to 37 of the MLR 2017. This includes information allowing Teya to identify you, such as your name and contact details, and any further information obtained to verify your identity; and

sufficient supporting records in respect of a transaction, whether or not the transaction is an occasional transaction, which is subject of customer due diligence measures or ongoing monitoring to allow the transaction to be reconstructed (transactions, in this instance, include a user linking their payment card to the Teya Rewards app); and

fraud prevention under Article 6(1)(f) of the GDPR. Notwithstanding our legal obligations to retain your data under Article 6(1)(c) of the GDPR, Teya has a legitimate interest to retain your data for fraud prevention purposes, which it does as described above.

RIGHT TO ERASURE

GDPR Article 17(1) provides grounds on which a company would delete data.

Under Article 17(3) of the GDPR, each of the lawful purposes listed above overrides the right to erasure under Article 17(1) of the GDPR.

In addition to this, Teya has an ongoing legitimate interest in retaining your data for the following purposes based on the reasonable expectations established through our privacy notice:

• Improvements to Teya’s products and services: In this respect we process personal data only on a pseudo-anonymised basis. Information that could be used to identify you (such as name and mobile phone number) are not processed but statistical level data (such as download information and user numbers) will be processed.

• Risk management and obtaining insurance: In this respect we process personal data only on a pseudo-anonymised basis. Information that could be used to identify you (such as name and mobile phone number) are not processed but statistical level data (such as download information and user numbers) will be processed.

• Retention of information gained over the course the contract to allow Teya to establish, exercise and defend legal claims. On account registration, you entered into a contract with Teya under Teya’s user terms and, whilst there is no suggestion that either of us has a claim against the other, the possibility remains. Teya has a legitimate interest in retaining your personal data in the event we need to establish, exercise or defend claims.

Should you wish to discuss any matter pertaining to our Privacy Policy or Data Retention Policy please feel free to send an email to rewardshelp@teya.com.

If you wish to contact the ICO to discuss matters further, you can do so on this page.

Please refer also to our Cookie Policy which explains the use of cookies on our website.