Last Update: June 30, 2020

Privacy Policy

I. ABOUT THIS PRIVACY POLICY

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”), Engagement Accelerator (“Partner Portal”), and our website at http://www.imfree.com (“Site”) (collectively “Services”).

II. CONSENT

How do we get your consent?

By using the Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, you may not use the Services, including, without limitation, our Site, Partner Portal, or Application. Information gathered through the Services may be transferred, used, and stored in the server and database of Imfree. If you access the Services, you consent to the transfer, use and storage of your Personal and Commercial Information for the purposes of billing, shipping, and operational management of the Services.

By providing your information in order for us to process and provide you with our Services, you consent to the use of your information for the purposes outlined in this Policy.

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, has accessed the Service, Imfree shall immediately delete all of the minor’s Personal Information.

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, Commercial Information, and Behavioral Information in connection with our Services.

Personal Information refers to any information, whether recorded in material form or not, that will directly ascertain the identity of an individual. This may include, but is not limited to, your full name, by itself, or combined with your password, mobile number, sex, date of birth, email address, metadata, and the IP address of your PC or mobile device.

Commercial Information pertains to any business-related information recorded in material form required in order to fulfill a work order. This may include but is not limited to, your registered business name, business and/or physical store addresses, and registered business number. While you will need to input your credit card information every time you purchase a subscription, we do not store this information.

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 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 partners, service providers, and other third-party organizations, businesses, and merchants who are necessary in fulfilling a work order and/or 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 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 your Commercial Information for the purposes of billing your work order/s, provision of Services, and shipping of activation kit/s to your store/s.

When you subscribe to any of the Partner Portal’s products, you must provide your name, email address, mobile number, registered business number, billing address, shipping address, physical store address, brand logo, and credit card information.

For online payments, we use the services of PayPal. PayPal is a globally trusted payment processor that protects data with PCI compliance, a PSD2-ready platform (EU and EEA), next-generation fraud tools, and more. When paired with JotForm’s CCPA, GDPR, and PSD2-ready you can rest assured knowing that your payments will be processed securely. We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.paypal.com/au/webapps/mpp/ua/privacy-full. Please do not send your credit card information to our team directly, for example by emailing this information to an Imfree representative. Please use our secure, online system to enter your credit card information.

We use your Behavioral Information such as location and in-app activities to help us to continuously optimise the Services we provide and to enable us to provide technical support should the need arise.

V. DISCLOSURE OF INFORMATION

How is this information shared?

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.

We do not sell, rent, share, or trade your Personal and Commercial Information to third parties for their own marketing purposes unless you have granted us permission to do so.

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 dataprotection@imfreemobile.com.

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 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?

We may modify or update this Privacy Policy periodically. We shall notify you of any such modification or update posting the updated policy on the Site or Application. We encourage you to check this Privacy Policy from time to time and to refer to the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed.

Your continued use of the Services following the effective date of an updated Privacy Policy constitutes your consent to the contents of such 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
dataprotection@imfreemobile.com

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