Last updated: 26-June-2020
What is this policy about?
This policy describes the information we process to support the Imfree platform, other products offered by Imfree and its related tools and services, including, without limitation, our Mobile Application (“Application”), and our website at www.imfree.com/app (“Site”) (collectively “Services”).
How do we get your consent?
You maintain ownership of your Personal Information and you may permanently extinguish this information on demand at any time.
Imfree does not knowingly collect information from minors nor otherwise consent to the registration of such minors for the Service. Upon being informed that a minor, without parental consent, have accessed the Service, Imfree shall immediately delete all of the minor’s Personal Information.
In addition, you provide your consent to receive relevant content and offers from our third-party clients and partners by opting in to them individually. Should you wish to discontinue receiving personalized content and offers from a particular brand, you may opt-out from such brand/s anytime.
III. COLLECTION OF INFORMATION
What kind of information do we collect and process?
To provide the Services, we must process information about you. The types of information we collect depend on how you use our Services.
We collect Personal Information and Behavior Information in connection with our Services.
Personal Information refers to any information, whether recorded in a material form or not, that will directly ascertain the identity of an individual. This may include, but is not limited to, your full name, username, by itself or combined with your password, personal picture, mobile number, sex, date of birth, email address, personal photograph, metadata, and the IP address of your PC or mobile device.
Profile Information may include but is not limited to, marital status, and your socio-economic classification provided for your Imfree account.
Behavioral Information consists of engagements and activities performed within the Services which may include but is not limited to, your in-app behavior, the products you use, your brand preferences, your geographic location collected from a GPS-enabled mobile device, and any other information you choose to submit via our Services.
Please note that the Services may provide you links to third party sites, such as links to the websites of Clients, Partners, and other third-party organizations, businesses, and merchants who have agreed to make engagements and offers available to you through our Services.
We are not responsible for the privacy policies, practices, or the content of websites owned by others that you may link to or that may be linked from the Services. Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use, and share any Personal Information.
IV. PROCESSING OF INFORMATION
How do we process this information?
We use your Personal Information for administrative purposes to identify you as we provide the Services to you. This may include verifying your identity to assess whether we can grant you access to the Services, responding to you when you contact us and any other activities that may require us to know you to improve the Services that we provide you, and to assess whether you are eligible for certain products and services such as vouchers, promotions, incentives, and contest prizes. We may also ask you for feedback about our products and services, so we may improve it.
We use your login credentials and device information for data security purposes to verify your account and activity, detect and prevent fraudulent transactions (such as fraudulent transactions or redemptions) and other bad experiences, and maintain the integrity of our Services.
We use your contact information to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
We use the Profile and Behavioral Information you provide, including location, preferences, interests, and in-app activities to provide personalized content that are unique and relevant to you, including, but not limited to, surveys and branded content and notifications (referred to as “Engagement”), offers and promotions (referred to as “Promos”), and other content that we deploy to you. We may send you emails or text messages recommending a product or service based on your personal preferences.
We use your location, preferences, and interests and track your in-app activities to help us and our partners to better understand you, measure the effectiveness and distribution of the Engagement and Promos you see and improve the type of Engagement and Promos you see in the future.
V. DISCLOSURE OF INFORMATION
How is this information shared?
We work with third-party vendors, service providers, and other Partners who help us provide and improve our Services or who use other Imfree services to grow their businesses, which makes it possible for us to operate and provide the Services for free. We do not sell, rent, share, or trade your Personal Information to third parties for their own marketing purposes unless you have granted us permission to do so.
We use your Profile and Behavioral Information to provide aggregated statistics and insights that help businesses understand how people are engaging with Engagement, Promos, products, and other content on our Services.
We provide our Partners with reports about the profile of members viewing and engaging with their Engagement and Promos and how they are performing, but we do not share information that personally identifies you unless you grant us permission. For example, we provide general demographic and interest information to our Partners that want to engage with you to help them better understand their audience. We also confirm which Engagement or Promos led you to make a purchase or take an action with a Partner.
We only provide legitimately relevant information and content to vendors and service providers who support our Services, such as providing you with notifications, analyzing how our Services are used, providing customer service, or conducting surveys, in order to deliver or complete a particular work order.
VI. OUR COMMITMENT TO YOUR RIGHTS ON PERSONAL INFORMATION
How can you access, update, or delete information about you?
We provide you with the ability to access, rectify, port, and erase your Personal Information. You may access and correct, if necessary, the Personal Information you provided or created in the course of your use of the Services, and other relevant information pertaining to it. You also have the ability to opt-out of the brands you engaged within the course of your use of the Services, or any changes thereto.
We store data until it is no longer necessary to provide the Services, or until you request for your account to be deleted, whichever comes first. When you request to delete your account, you may no longer have access to or be able to use the Services.
What are your rights?
We respect your rights to determine how your personal information can be used. These rights include:
Right to access information
You have the right to ask us for an overview of your personal information that we process.
Right to rectification
If your personal information is incorrect, you have the ability to rectify it or the right to ask us to do so. If we shared incorrect data with a third party, it is our responsibility to notify the said party.
Right to object processing
You can object to Imfree using your personal data for legitimate reasons. We will consider your objection and whether processing your personal information has any undue impact on you that requires us to halt doing so.
Right to object to automated decisions
We may use internal systems to make automated decisions based on your personal information. Though you have initially provided your consent, you have the right to deny such automated decisions at any point in time.
Right to data portability
You have the right to request that Imfree Inc transfer the personal information we have collected and processed directly to you, under certain conditions.
Right to restrict processing
You have the right to ask us to restrict using your data, if:
- The personal information is incorrect.
- The personal information is being processed unlawfully.
- You have your own legitimate reasons.
Right to erasure
You may ask us to erase your personal data, if:
- You withdraw your consent for processing it.
- You have your own legitimate reasons.
- The law requires us to erase your data.
Right to file a complaint
Should you be unsatisfied with the way we have responded to your concerns, you have the right to submit a complaint to us. If you are still unsatisfied, you can escalate the complaint to the Imfree Data Protection Officer.
Should you wish to exercise any of the above rights, please contact us through firstname.lastname@example.org.
VII. INFORMATION SECURITY
How do we secure the information?
We utilize reasonable information security measures to safeguard your Personal Information. We apply an internal framework of policies and standards across all our business to keep your data safe. These policies and standards are periodically updated to keep them up-to-date with regulations and market developments. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security, etc.) to ensure the confidentiality and integrity of your personal data and the way it is processed.
VIII. CHANGES TO THIS POLICY
How will we notify you of changes to this policy?
IX. CONTACT INFORMATION
How to contact us with questions?
If you have questions or concerns about this policy, you can contact us at:
Imfree Data Protection Officer