Rewards By GCOW Privacy Policy

This Privacy Notice outlines how GCOW, LLC (“Rewards By GCOW” or “we”) collects, uses, and shares information when you interact with our website, receive rewards or incentives, or redeem products through our platform. Our policies regarding the collection, use, and disclosure of information are described in this Privacy Policy. By using our site, you agree to our data collection, use, disclosure, and storage practices as outlined in this statement.

By accessing or using our Site, you acknowledge that you have read, understood, and agree to be bound to the terms of this Privacy Statement and our terms of use.

Rewards By GCOW provides reward, incentive, and other services to enterprise clients (our “Clients”), and we are typically a processor, not a controller, of personal information. Our Clients provide rewards, incentives, and other products offered through Rewards By GCOW platform to individuals for redemption (each a “Recipient”). If a Client discloses Personal Information of California consumers or households to us, we may be considered a “service provider” under California law. If you are located in the European Economic Area or the United Kingdom, we are a data processor of your personal data, and our Client is the data controller of such data under the EU General Data Protection Regulation and the UK General Protection Regulation.

We will only process and use your data in accordance with the documented instructions of our Client and strictly on their behalf, subject to our agreement and data processing addendum entered into with our Client. Our Client will be solely responsible for meeting any legal requirements applicable to data controllers or “covered businesses” (such as establishing a legal basis for processing and responding to data subject rights requests concerning the data our Client controls).

Rewards By GCOW works with financial institutions and may share certain information with them to facilitate the redemption of some awards, incentives, and other products. Due to the requirements of financial rules and regulations, including anti-money laundering laws, Rewards By GCOW may not be able to delete your information, even upon your request.

If you are visiting this Site on behalf of one of our Clients, please refer to the “Authorized Users” section below.

Rewards By GCOW collects data from both its Clients and the Recipients of its rewards, incentives, and other products. The information collected may include personal details such as name, address, email address, telephone number, mobile telephone number, geolocation information, login, or password.

When a Client creates a corporate account with Rewards By GCOW, we request certain information about the Client's business.

Clients who provide a reward, incentive, or other product may provide us with information about the Recipient such as name, email address, or phone number.

If you are a Recipient, we may receive information about you from our Client to notify you of the reward and customize its presentation. This information may include your name, email address, or phone number.

If a Client provides us with personal information about others, such as Recipients, or if someone provides us with your information, we will only use that information for the specific reason for which it was provided to us, such as adding it to the information we already hold about you if you agreed to share information with our Client when redeeming a prior reward.

The information we collect from and about you may be used for the following purposes:

• To send you requested product or service information, such as rewards and incentives.
• To facilitate the redemption of rewards, incentives, or other products.
• To respond to service requests from our Clients or from you.
• To address your questions and concerns.
• To improve our website content and functionality, and to enhance our marketing efforts.
• To conduct research and analysis.
• To display content based on your interests.
• To comply with applicable laws and respond to requests from public and government authorities.
• To enforce this Privacy Statement and protect our rights, privacy, safety, or property, as well as those of you and others.
• To develop new programs, products, or services.
• To protect the security and integrity of our business and the Services we provide.
• To follow the instructions of our Clients and as described to you when we collect your data.
• The information we collect may be shared with financial institutions that issue your rewards, incentives, or other products, such as your name and email address. We may also share this information with our Clients to facilitate and track the redemption of rewards, incentives, or other products.

We may disclose your personal information to our Service Providers if such disclosure enables them to perform business, professional, or technical support functions for us. We may also disclose your information if we believe in good faith that there has been a violation of this Privacy Statement, our Terms of Use, or the rights of any third party, or to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request. Additionally, we may disclose your information in response to the judicial process, provide information to law enforcement or regulatory agencies, or as required by law. Any disclosures made will be consistent with the instructions given to us by you at the time of data collection.

In the event of a merger, acquisition, or sale of all or a portion of our assets, we will notify you via email and/or a prominent notice on our website of any change in ownership or use of your personal information, as well as any choices you may have regarding your personal information. We do not sell your personal information to third parties, but we may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In the event of a bankruptcy or reorganization proceeding, such information may be considered our asset and may be sold or transferred to third parties. We will use reasonable efforts to ensure that any transferee of your personal information uses it in a manner consistent with this Privacy Statement.

If you do not wish for us to disclose your personal information as described above, please contact us at [email protected]

We automatically collect certain information about your computer, such as your IP address, browser type, referring/exit pages, and operating system, in accordance with the standard practices of most websites. When you interact with our website, we also automatically collect information about your use of our Services, such as page views, traffic to and from our Services, referral URL, ad data, your IP address, and device identifiers. This information may include your search activity, the websites you visit, the emails you open, and your browsing activities across other websites.

We use various technologies, such as cookies, web beacons, pixel tags, log files, and other similar tools, to automatically collect certain information when you use our Services or interact with our emails. This information may include non-personal information, such as your mobile device identifier or MAC address, browser type, operating system, device model software version, IP address, mobile or ISP carrier information, and the domain name from which you accessed the Services. We also collect information about your use of the Services, such as the date and time you access the Services, the areas or pages of the Services that you visit, the amount of time you spend using the Services, the number of times you return, and other usage data.

You can adjust your browser or operating system settings to limit this tracking or decline cookies, but doing so may prevent you from using certain features on the Services or taking full advantage of our offerings. To learn more about managing your tracking settings or cookie preferences, consult the “Help” menu of your browser or operating system. For more information on cookies or other tracking technologies, and to exercise your choices about not having this information used by certain Service Providers, please click here. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Site, as well as information collected offline or from third-party sources, such as Clients, to tailor our communications to you and improve our Services.

If you do not want us to share your personal information as described in this Privacy Statement, please contact us at [email protected]

We may engage third-party service providers to perform functions related to the Site or to help us provide services to our Clients. These service providers may have access to your personal information as needed to perform their functions, but they may not use or share your personal information for any other purpose. These companies are authorized to use your personal information only as necessary to provide these services to us and/or to support the services we provide to our Clients.

If you are a California resident, California Civil Code Section §1798.83 gives you the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]

If you are a resident of the EEA or the UK, we collect and use your personal data or information with your consent, as provided by our Client, in performance of a contract with our Client, or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. You may contact our Client at any time to withdraw your consent to our collection and use of your personal data and to exercise the following rights:

• Access your personal data or information
• Delete, or request deletion of, your personal data or information
• Object to or restrict processing of your personal information
• Request portability of your personal information
• Lodge a complaint with your local data protection authority
• Object to automated decision-making
• Update your personal data or information

If you withdraw your consent for us to process your personal information, we will not use your information going forward. However, withdrawing your consent will not affect any processing that was done before you withdraw your consent, nor will it affect any processing that is done using lawful grounds other than consent.

If you are visiting our site to redeem an award, please review and familiarize yourself with our Client's privacy policies and procedures before using our site. If you have questions about information collection and use, please contact the Client who provided you with a reward or incentive.

Legal Requirements: We may disclose your Personal Data if required to do so by law or in good faith belief that such action is necessary to comply with legal obligations, protect and defend our rights or property, act in urgent circumstances to protect the personal safety of users or the public, or protect against legal liability.

Children: We do not knowingly collect any personal information from children under the age of thirteen.

Links to Other Websites: This Privacy Statement applies only to our Services and not to other websites or applications, including those of our Clients, that may link to or from our Services. We are not responsible for the practices of those sites or applications.

Data Security: We have taken physical, administrative, and technical steps to protect the information we collect from you. However, we cannot guarantee the security of your personal information transmitted to our site.

Data Storage and Retention: Your personal information is stored on our Service Providers' servers in the United States. We will retain your personal information for as long as it is needed to provide you with the Services or to fulfill any legal or contractual obligations.

Access to Your Personal Information: You may request access to, correct or delete any personal information that you have provided to us.

Authorized User Notice: If you access our site on behalf of one of our Clients, you are considered an Authorized User under the Client's contract with us. Your use of our site is subject to our privacy policy and terms of use, as well as the contract with our Client.

Changes to Our Privacy Statement: We may revise this Privacy Statement at any time. We will post changes on the site and provide appropriate notice to you if we change the Privacy Statement in a material way.