European Privacy Policy

Effective date: 18th October 2021

This European Privacy Policy contains information on how we collect, store, process, transfer, share use data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) ("personal data") and information regarding our use of cookies and similar technologies. This European Privacy Policy should be read in conjunction with our rewardStyle Privacy Policy, however, the European Privacy Policy applies solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood this European Privacy Policy and our rewardStyle Privacy Policy before accessing or using the Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our rewardStyle Privacy Policy or as otherwise defined in the General Data Protection Regulation (“GDPR”).

rewardStyle, Inc. d/b/a LTK, its subsidiaries, and company affiliates (collectively “rewardStyle”) is the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used.

1. Personal Data We Collect From You When You Use the Services and How We Use It

We collect personal data as set out in the “Our Collection of Personal Information” and “Our Use of Personal Information” sections of our rewardStyle Privacy Policy. We will indicate to you where the provision of certain personal data is mandatory. If you choose not to provide such personal data, we may not be able to provide those parts of the Services to you or respond to your other requests.

The table at Annex 1 sets out in detail the categories of personal data we collect about you and how we use that information when you use the Services, as well as the legal basis which we rely on to process the personal data and recipients of that personal data.

2. Information We Collect About You Automatically

We also automatically collect personal data indirectly about how you access and use the Services, and information about the device you use to access the Services, or otherwise engage with us. Please see the “Personal Information Automatically Collected” section of our rewardStyle Privacy Policy for more information about what data we collect and how we use it.

• The table at Annex 2 sets out in detail the categories of personal data we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal data and recipients of that personal data. For more information on cookies and other tracking technologies we use, please see our Cookie Policy.
• We may link or combine the personal data you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you) and may use the anonymised and aggregated information or disclose it as set out in our rewardStyle Privacy Policy.

3. How Long Will We Store Your Personal Data

We will usually store the personal data we collect about you for no longer than necessary for the purposes set out in Annexes 1 and 2, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements, and in accordance with our legal obligations and legitimate business interests.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

4. Recipients of Personal Data

We may share your personal data with the recipients as set out in the “Our Disclosure of Personal Information” section of our rewardStyle Privacy Policy (as required in accordance with the purposes set out in Annexes 1 and 2).

5. Marketing and Advertising

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.

• For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
• We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails or by updating your preferences via the App settings.

6. Storing and Transferring Your Personal Data

• Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

• International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Sites from the EEA, Switzerland or UK, your personal data will be processed outside of the EEA, Switzerland or UK.

In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. On the occasion where we would receive a request for personal data from law enforcement agencies in the United States or elsewhere and such requests take the form of a lawful valid legal obligation, process or requirement, where we must comply, we will take reasonable steps to disclose only the minimum personal data necessary to produce the required data specific for the purpose.

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this European Privacy Policy.

7. Your Rights in Respect of Your Personal Data

In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:

• Right of access. You have the right to obtain:
• confirmation of whether, and where, we are processing your personal data;
• information about the categories of personal data we are processing, the purposes for which we process your personal data and information as to how we determine applicable retention periods;
• information about the categories of recipients with whom we may share your personal data; and
• a copy of the personal data we hold about you.
• Right of portability. You have the right, in certain circumstances and where technically feasible, to receive a copy of the personal data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another controller.
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal data we hold about you without undue delay.
• Right to erasure. You have the right, in some circumstances, to require us to erase your personal data without undue delay if the continued processing of that personal data is not justified.
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
• Right to withdraw consent. If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason. 

You also have the right to lodge a complaint to your local data protection authority. We ask that you please contact us first and allow us to attempt to resolve your issue. Information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .

If you wish to exercise one of these rights, please contact us using the contact details at the end of this European Privacy Policy. There may be exceptions to these rights in certain circumstances, and where you cannot exercise a right due to an exception, we will provide that explanation to you. We will use reasonable efforts to fulfil your request within the response time of applicable laws.

Due to the confidential nature of data processing we will require you to verify your identity by making your request through your existing account or we may follow up with you to ask you to provide proof of identity such as a copy of a valid identity document when exercising the above rights.

8. Cookies and Similar Technologies Used on Our Sites

Our Sites use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to monitor and analyse how you use and interact with our Site so that we can continue to improve our Sites. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements. Please see our Cookie Policy for more information about these practices and your choices regarding cookies.

9. Our Policy Towards Children

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13 or older depending on the applicable age of majority of the jurisdiction of residence (“Child”). If you are a Child, you should not use our Services or otherwise provide us with any personal data either directly or by other means. If a Child has provided personal data to us, we encourage the Child’s parent or guardian to please contact us using the contact details at the end of this European Privacy Policy to request that we remove the personal data from our systems. If rewardStyle obtains actual knowledge that it has obtained personal data about a Child, that personal data will be promptly deleted from our records.

10.  Changes to This European Privacy Policy

We may update this European Privacy Policy from time to time and so you should review this page periodically. When we change this European Privacy Policy or Annexes 1 and 2 in a material way, we will update the "Effective Date" above and on Annexes 1 and 2 respectively. We may notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels as may be required by law. Changes to this European Privacy Policy are effective when they are posted on this page.

11.  Contact Us

Please contact datarequests@rewardstyle.com if you have any questions, comments and requests regarding this European Privacy Policy.

12. English Version Controls

Unless prohibited by local laws, if non-English translations of this notice are available, they are provided for convenience only and in the event of any ambiguity or conflict between translations, the English version is authoritative and controls.