Privacy Policy

Last updated: OCTOBER 3, 2024

We operate rewardsX as a cross-platform social rewards program, and we respect your privacy.

This Privacy Policy explains how we collect, use, and share the personal information that we gather on the subdomains and websites that validly link to this Privacy Policy (the “Site”), through your use of our mobile applications (the “App”), and any other services offered as part of the rewards platform (collectively, with the Site and App, the “Services”). The Services are operated by Tiny Co Holdings, Inc., doing business as Webspot (“Company,” “we,” “our,” and “us”).

Please check the following sections to learn more about our Privacy Policy:

1. Whose Information We Collect

We obtain information from various entities. These entities are defined below by what they are referred to in this Privacy Policy and when their information is collected. Entities may overlap and are not exclusive categories.

Site Visitor(s): When you visit the Site or contact us directly for information.
Brand(s): When you engage us to offer brand-specific engagement rewards to Users via our Services.
User(s): When we collect and process information from consumers of a Brand for purposes of facilitating rewards.
Service Provider(s): When you become our service provider.
Employees and applicants: When you apply for or inquire about employment at Company.

The use of “you” and “your” throughout this Privacy Policy will, depending on the context, refer to a Site Visitor, Brand, or User.

2. Information We Collect

Information You Give Us. You may give us information by signing up for an online account, entering information through our online forms or surveys, inputting information while using our Services, contacting us for information or customer service, and authorizing us to collect information from your third-party accounts (e.g., TikTok).

The categories of information include:

Identifiers, such as real name, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name and telephone number.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation.
Audio, electronic, visual, or similar information.
Inferences drawn from the above categories of information.

The categories of sensitive information include:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.

In addition, we may use payment processors for payment, analytics, and other business services. Payment processors collect identifying information about the devices that connect to its services. Payment processors use this information to operate and improve the services they provide to us, including for fraud detection. Please refer to their privacy policies to determine how such payment processors use your information.

Information We Automatically Collect.

Site: Like many website operators, we collect information that your browser sends whenever you visit our Site. This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them.
App: Our App may automatically collect your IP address, log-in credentials, connectivity details, and locations, depending on your permissions.

Information We Collect From Third Parties. If you access our Site through third parties (e.g., Facebook or Google), or if you share content from our Site to a third party social media service, the third party service will send us certain information about you if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

3. How We Use Information

We use your personal information for the following purposes:

To provide you with the Services on our Site, which include:
- maintaining and servicing accounts,
- providing customer service,
- processing and fulfilling orders and transactions,
- verifying customer information, and,
- providing advertising or marketing services to you.

To provide analytic services, such as analyzing customer usage and improving services offered.
To conduct market research and project planning.
To create, train, improve, or otherwise develop models powered by algorithms, machine learning, large language processing, and other artificial intelligence.
To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Sites.
To fulfill our legal and financial obligations.
To provide you with employment opportunities.

Marketing. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Us” section below. You will still continue to receive service-related messages concerning products and Services you have purchased (unless we have indicated otherwise).

4. How We Share Information

With Your Consent. We may share your information with other Users or the public with your consent. The settings you choose for your account or profile will determine how much information is shared.

Affiliates and Service Providers. We share your information with our third-party service providers, affiliates, and any subcontractors as required to offer you our products and Services.

The service providers we use help us to:

run, operate and maintain our Services through third-party platforms and software tools;
perform content moderation and crash analytics;
run email campaigns;
perform marketing analytics;
provide payment attribution; and,
provide technical and customer support.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. We reserve the right to make use of any such aggregated data as we see fit.

Brands. As part of providing our Services, we may share some of your personal information with the Brands with which you interact while using our Services.

Third Party Links and Websites. Our Site may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.

Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

5. How Do We Respond to ‘Do Not Track’ Signals?

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

6. Cookies

To make our Site and Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Site may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

7. Privacy Rights and Additional Disclosures for Certain U.S. Residents

Several jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at support@onwebspot.com.

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

The categories of personal information we collect about you.
The categories of sources from which your personal information is collected.
The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).
The categories of third parties with whom we share your personal information.
The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
The specific pieces of personal information we have collected about you.

In addition, you may have the right to request we delete your personal information.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale of the consumer’s personal information. However, we do not sell your personal information, nor do we share your personal information to provide personalized or targeted advertising.

Limit the Use of My Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law.

Third Party Marketing. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights. To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process. If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.

8. Privacy Rights and Additional Disclosures for EEA & UK Individuals

Rights. If you are from the European Economic Area or United Kingdom, you have the right, under certain circumstances, to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to the processing of your personal data for reasons relating to your particular situation.
Request restriction of processing your personal data.
Request to export the personal data that we process based on our contract with you or your consent and transfer it to another company (if technically feasible).
Withdraw any consent you have previously provided to us.

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

You may contact us using the contact details provided in the “Contact Us” section below for more information or to exercise your rights.

Legal Bases for Processing. If you are from the European Economic Area or United Kingdom, our legal bases for collecting and using your personal information is as follows:

The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and improvement of our Services.
Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your personal information to record your requests to exercise your rights and to verify your identity for such requests.
Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.
In some limited cases, we may also have a legal obligation to collect personal information from you, in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in “How We Share Information.”

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided in the "Contact Us" section below.

International Transfers of Data. Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail the transfer of your personal information across international borders. The data protections standards may differ and be lower than the standards enforced in your jurisdiction.

9. Notice of Financial Incentive

We offer programs, benefits, free products, discounts, and other incentives to consumers relating to the collection, use, retention, sale, or disclosure of your personal information (our “rewards program”). Specifically, by agreeing to opt in to our rewards program, you agree that we can analyze your engagement with third-party Brands and provide points for engagement activities such as following, commenting, liking, sharing, and posting about participating third-party Brands.

Categories of Personal Information Involved. Our rewards program may involve the following categories of personal information from participating individuals:

The categories of information include:

Identifiers, such as real name, online identifier, email address, account name, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name and telephone number.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.
Geolocation.
Audio, electronic, visual, or similar information.
Inferences drawn from the above categories of information.

The categories of sensitive information include:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.

We are providing you with this information so that you may make an informed decision on whether to participate in our programs.

Who Receives Rewards Program Information. Personal information provided under the rewards program may be shared with the following third parties: Other merchants (e.g., participating Brands).

For the avoidance of doubt, personal information provided under the rewards program will not be provided to data brokers.

How to Get These Incentives. Our financial benefits programs reward you for being a valued customer who trusts us with your personal information. To access these programs, benefits, discounts, free products, and other incentives, you can sign up for an account via our Site.

How to Opt Out of Incentives. Opting in to get these benefits does not mean you are locked into them for life. If you change your mind, you can easily opt out. Participation in our promotional and benefits programs is always optional, and you can terminate program participation at any time by contacting us at support@onwebspot.com.

Additional Disclosures. We respect your decision to opt in to our financial benefits program, and we strive to provide financial benefits worth your time and attention. While it is extremely difficult to assign a monetary value to the personal information that we collect, we believe that, based on our reasonable estimates, the value of your personal information is reasonably equal to or greater than the value we provide with our financial benefits program.

We arrived at this conclusion by analyzing market trends and similar financial benefits programs, and comparing these factors against our good-faith estimate of what we receive from your personal information.

10. Retention and Security

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the Sites, we cannot ensure or warrant the security of any information you transmit to us.

11. Children’s Privacy

The Sites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided in the “Contact Us” section below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

12. Change of Control

Personal information may be transferred to a third party as a result of a sale, acquisition, merger, reorganization or other change in control. If we sell, merge or transfer any part of the business, part of the sale may include your personal information.

13. Updates

This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal data to our Site. The date the policy was last updated is indicated at the top of this page.

14. Contact Us

You can contact us at support@onwebspot.com if you have any questions regarding this Privacy Policy.

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