Effective Date: May 25, 2018
When you use our websites (including dubli.com, bsp-rewards.com, bsprewards.com, Ominto.com, dublivip.com), mobile applications, browser extensions or related services (collectively Cash Back Shopping Site or Sites), you trust us with your personal and non-personal information. This Policy applies to the personal and non-personal information you share with us through your activity on the Cash Back Shopping Site and it describes:
- What information we collect and how we collect it;
- How we use information we collect;
- How we share information we collect;
- How we store and secure information;
- How we transfer information we collect internationally; and
- How to access and control your information
Each time you use the Site or provide us with information, you represent that you are accepting the practices described in this Policy at that time and consent to our collection, use, disclosure and transfer of your information. Please review this Policy each time you use the Site as we may revise certain sections of this Policy, and any changes will be effective immediately upon being published unless we inform you otherwise, subject to clause 11 below.
You are not required to provide personal information that we request, but, if you chose not to do so, in many cases we will not be able to provide you with our services or respond to any inquiries you may have.
Type of Information we collect: The type of information we collect may be “personal” or “non-personal”. “Personal” information means any information relating to an identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We do not consider personal information to include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information from you and any devices (including mobile devices) you use when you: use our services, register for an account with us, provide us information on a web form, update or add information to your account, or when you otherwise correspond with us. We may also collect personal information from other sources, as described below.
Information we collect when you use our Cash Back shopping site may include:
- Basic subscriber information: e-mail address, given name (first name) and family name (last name), language, region, currency
- Information to process transactions: name, mailing address, phone number, email address and contact preferences
- Payment information: such as payment service provider, choice of payment method and basis, your PayPal ID or Paytm account number and associated transaction reference numbers/ IDs .
Information that is automatically transmitted:
- Transaction information: details related to your use of our Site, including information about purchases you make, your subscriptions and other related transaction details
- Usage and preference information: information about how you and site visitors interact with our Site, preferences expressed, and settings chosen
- Your geolocation
Information procured from other sources:
- Information from third parties (other websites, apps, service providers etc.): If you choose to link, create, or log in to your user account with an e-mail provider (e.g., Google), a payment provider (e.g., PayPal) or social media service (e.g., Facebook), we may collect your information from that site or app (e.g., content viewed by you, content liked by you, and information about the advertisements you have been shown or have clicked on, etc.). Those social media sites may give us automatic access to certain personal information retained by them about you.
- Transaction information: information about the purchases you make online on the merchant’s site.
Different ways in which we collect information: We collect information about you when you provide it to us through your interaction with our Cash Back Shopping Site, our employees, service partners and/ or use our other services. The primary sources of your information are:
Information you give us when you use our Cash Back Shopping Site:
- Sign-ups/ account registrations: when you register on the Cash Back Shopping Site or sign in to an existing account, create or modify your profile, set preferences or navigate through our website
- Website visits: when you visit our website(s)
- Applications: when you access our Cash Back Shopping Site through our mobile application and browser extension
- Third-parties: when you connect to our Services using third-party accounts, such as your email, social media, or payment account(s), or if you engage with a separate app or website that uses our API (or any third-party API we use), we may collect your personal information from that site or app.
- Support channel: Information you provide through our customer support channel
- Referral Program: when you choose to use our referral service to tell a friend about the Cash Back Shopping Site
Information that is collected automatically:
- Through location identifying technologies
- Transaction information: when you participate in our shopping or any promotional activities, we may monitor and analyze trends, usage and activities
- Cookie Technologies: through cookies we collect and store a user’s Site preferences, information for allowing Site log-ins and potential data to be used for advertising purposes
- Through tracking pixels and website tags that create and maintain unique identifiers.
The Controllers of the information will determine the purpose and means of any personal information that we collect and primarily rely on the following legitimate bases for processing such information:
Consent: applies when you have given consent to the processing of your personal information for one or more specific purposes such as:
- Consent for collection of personal information
- Consent against sharing of personal information with approved partners
- Consent for use of local cookie
- Performance of a contract: applies where the use of your personal information is necessary to perform the terms and conditions of a contract to which you are a party or any other policies which may be applicable to you as a user of our Cash Back Shopping Site.
- Legitimate interest: applies where we use your personal information for our legitimate interests such as to improve our Cash Back Shopping Site and related services, security purposes, fraud prevention, and to share information with our affiliates for internal administration.
The specific purposes for which we use the information we collect about you are listed below:
To improve our services and to communicate with you about the services: We use the personal information we collect to provide, maintain, and improve our services. We are always looking for ways to make our services smarter, faster, secure, integrated and useful to you. We use collective learnings about how you use our services, through analyzing your shopping trends, usage, activity patterns etc., primarily to identify areas for integration and improvement. Further, we allow you to store information pertaining to your favorite stores, visited stores/ out clicks and allow you to clip/ save coupons in your SaveMate® coupon book. Basis this information you store, we may also suggest actions for you to take. For example, we may suggest services and products that we think will help you get most of our services. We may also use this information to adapt Site content to be more likely to be of interest to you.
We also use your contact information to send transactional communications via email and within the services, including your purchase confirmations, reminders about your subscription expirations for paid memberships, responding to your questions and requests through customer support, and sending you technical notices, updates, security alerts, and administrative messages.
We further use information collected from cookies and other technologies, like tracking pixels, website tags, to improve your user experience and the overall quality of the Cash Back Shopping Site. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. Tracking technologies such as cookies are used to store data about the merchants you browse and shop with and other personal information. The data is required to allocate your Cash Back accordingly. The data stored in cookies allows you to avoid filling out forms at every site access. The cookies produced have a maximum expiration period of 90 days. Furthermore, you may use your browser program to manage or deactivate cookies produced on this page.
To market, promote and drive engagement with our Cash Back Shopping Site: We also use your personal information to send you promotional communications and provide you with customized offers such as more relevant emails, newsletters, deals, coupons and special Cash Back offers from online stores who we feature on the Site. For example, a customer who has made past purchases from a given online store might be more likely to receive offers from that store in subsequent promotional emails. All such information is sent to you only after we have your consent. You can manage and control these communications as per the choices available to you as described in Section 7 below.
For provision of customer support:When you contact us, we keep a record of your communication to help solve any issues you might be facing be it technical in nature or for example regarding your missing purchases.
To protect our legitimate business interests and comply with legal and regulatory provisions:Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with purposes which are a part of the normal business course of operations.
We may also use your information where you have given us consent to do so for a specific purpose not described above. While you have the right to provide us with your consent for the use of your specific information, you also have the right to manage your choice at any time (see Section 7 for further details).
We may share the information we collect, including your personal information, with Ominto Group Companies and third parties. This disclosure may be required for us to provide you access to our services, to comply with our legal obligations, to enforce our User Terms Agreement, to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our services. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose. For example:
Sharing of information with third-party service providers:We work with third-party service providers to provide application development, hosting, maintenance, backup, storage, payment processing, analysis and other services for us, which may require them to access or use information about you. A service provider accesses information about you, to the extent required, to perform services on our behalf. They do so under instructions from us and in line with our prevalent policies and procedures designed to protect your information. We do not sell your information to these third-party service providers. The third-parties with which we share your information primarily include:
- Affiliate networks
- Payment processors
- Online merchants
- Marketing companies and influencers
- Providers of marketing automation software
- Internet domain registrars/ web hosting partners
- Web performance and security partners
Our website may also include links to these third-party websites whose privacy practices may differ from those on our website. If you submit personal information to any linked websites, your information is governed by the privacy statements provided by the linked website. We encourage you to carefully read the privacy statement of any website you visit.
Further, we may share your information with our payment processor, Wirecard, for the purposes of processing your credit card payments. In this capacity, Wirecard acts as a controller and has a legitimate interest in processing your personal data and will decide on the method and means of this processing. Accordingly, information shared with Wirecard is subject to Wirecard’s privacy terms that can be accessed at https://www.wirecardbank.com/GDPR .
Legal purposes:We may also disclose your personal information when we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; or comply with a subpoena, or similar legal process where it is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or to any other third party with your prior consent to do so.
Business restructuring: We may share or transfer your information (including your personal information) in connection with, or during negotiations of any restructuring process with another company for say acquisition of all or a portion of our business, merger, sale of company assets, or financing. You will be notified via email and/or a prominent notice on our corporate website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
The security of your personal information is important to us. We work hard to ensure protection against the unauthorized access, use, alteration or destruction of your personal or financial information. We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We use a secure, encrypted connection (using a SSL protocol) on all pages where you access or transmit personal information. We do not store credit card information on the Cash Back Shopping Site.
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. If you have any questions about security on our Website, you can contact us at firstname.lastname@example.org
We will store and retain your personal information for as long as necessary to provide you the services you have requested, as long as your user account is active in our systems, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. After that time, we may anonymize and aggregate the data and retain it for analytical purposes. We may also retain your information to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.
You have the following rights concerning our processing of your personal information:
- The right to access: You have the right, at any time, to enquire about the personal information we store about you and to request deletion or suspension of your personal information. Please use our ticket system at https://support.dubli.com/.
- The right to have your information rectified or erased or place restrictions on processing your information: You may correct your account information at any time by logging into your online or in-app account. If we hold any information about you which is incorrect or if there are any changes to your details, please let us know so that we can keep our records accurate and up to date. Free users/ subscribers who do not have any pending or available Cash Back and wish to cancel their account, may do so themselves by navigating through the options available in the dashboard on our Site. VIP Rewards membership subscribers/ paid users who wish to cancel their account can do so by using our ticket system at https://support.dubli.com. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.
- The right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
- The right to data portability the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- The right to withdraw consent: where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions. If you wish to withdraw your consent you should select the settings in your dashboard which give you the option to withdraw or should contact us at: email@example.com (Please note that if you withdraw your consent to the use of your personal information for purposes set out in this Policy, we may not be able to provide you with access to all or parts of our Sites and services);
- The right to Opt-out: You may restrict our use of your personal information for any promotional communications. You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about services you have requested, or our ongoing business relations.
- The right to lodge a complaint with the supervisory authority responsible for data protection matters.
In order to provide services to you, we may need to transfer your personal information outside the EU (if you are based in EU) to countries that may not necessarily apply the same standards afforded under the European data protection legislation. However, we take steps to ensure that where your information is required to be transferred outside of the EU by us or our service providers and hosting providers, that appropriate measures and controls in place to protect that information in accordance with applicable data protection laws and regulations. For example, we may share information with our Ominto Group Companies or affiliates based outside the EU for the purposes envisaged by this Policy, and ensure that all Ominto Group Companies are subject to this Policy designed to protect data in accordance with EU data protection laws. By using our Sites, products or services or by interacting with us in the ways described in this Policy, you consent to the transfer of your information outside the EU in the circumstances set out in this Policy. If you do not want your information to be transferred outside the EU you should not use our website, applications or services, and should contact us at: firstname.lastname@example.org
We do not knowingly collect personal information from users below 18 years of age. If you believe that such a user has provided personal information to us, please contact us at email@example.com so that we can identify and delete that user's personal information.
This Policy is current as of the effective date set forth above. We reserve the right to change this Policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Policy we will notify you by revising the date at the top of this Policy and provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification to obtain your consent).