For the purpose of the processing personal data, we may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Rowan Rewards. In such cases, we shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of and applicable European Union legislation. Shall also require the personal data processors to implement appropriate measures for the security of personal data. In such cases, we shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
Rowan Rewards may collect two (2) types of information about you: personal and non-personal.
According to the federal personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Rowan Rewards is considered personal information. Failure to provide all information required by Rowan Rewards may prevent access to any or all Rowan Rewards materials, and failure to maintain accurate information may also result in suspension or termination of access to any or all Rowan Rewards materials.
Personally Identifiable Information (PII). We acquire PII that may include, in certain contexts, your name, postal address, post code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or device if it were combined with other identifying information.
Registration. Prior to using one or more of the Rowan Rewards materials, Rowan Rewards may require certain personal information and non-personal information to create an individual account (“account”) or to enable features or functionality of the Rowan Rewards materials. Failure to provide all required information required by Rowan Rewards may prevent access to any or all Rowan Rewards materials, and failure to maintain accurate information may result in suspension or termination of access to any or all Rowan Rewards materials.
Sensitive PII. In certain circumstances, such as when purchasing a service, you may provide a credit, debit, or payment account number, or other payment information to our payment gateway provider such as PayPal which we recognise as more sensitive than other PII. We generally do not request on or through the service other data that is often considered “highly sensitive,” such
as other financial account information (e.g., credit report information, bank account numbers), or government issued identification numbers (e.g., drivers’ license number, or passport number), although we reserve the right to do so when such data is necessary to offer you certain services.
Anonymous Data. Some of the data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your device, but is instead used in an anonymous way, often aggregated with other anonymous data about other users.
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). Rowan Rewards may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
While you are able to visit the Rowan Rewards site and remain anonymous, Rowan Rewards or its third party service providers may still collect non-personal information about your use of the Rowan Rewards materials (e.g. your internet browser, operating system, IP address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:
addresses automatically. An IP address is a number that is automatically assigned to your computer whenever you begin services with an internet services provider. Each time you access the Rowan Rewards site and each time you request one of Rowan Rewards’ pages, the server logs your IP address.
You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.
We may use your data for the following purposes:
We may use algorithms and other automated means to implement any of the above.
We use these services to advertise to visitors of Google ad network websites who have previously visited our website or who Google deems to have shared interests with visitors of our
We share data with third parties as follows:
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymise it.
If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that
your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
We enable you to make numerous choices about your data:
Rowan Rewards takes appropriate security measures to protect against unauthorised access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Rowan Rewards’s data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorised access to systems where Rowan Rewards stores personal information. All Rowan Rewards employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorised use or disclosure of personal information.
The Rowan Rewards contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Rowan Rewards may use third parties to provide components of the Rowan Rewards contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Rowan Rewards. Rowan Rewards: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such website; and (c) does not make any warranties or representations about the contents, products or services offered on such website or the security of any information you provide to them
By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).
We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorised individuals, and we regularly upgrade our security as better methods become available.
Our data centers and those of our partners utilise modern physical security measures to prevent unauthorised access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access.
All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
The website may offer chat rooms, Chatbots, forums, message boards, or news groups to users. It is important to remember that any information disclosed in these areas becomes public information. Accordingly, as with any public forum, you should exercise extreme caution when deciding whether to disclose your personal information.
This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Rowan Rewards' policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to United Kingdom (or other countries) based upon the following legal frameworks:
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.
If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
Where you believe that we have not complied with our obligations under this Privacy Notice, or the applicable law, you may have the right to make a complaint to a relevant Data Protection Authority or through the courts. Although not required, we would encourage you to let us know about any complaint you might have and Rowan Rewards will respond in line with our complaints procedure – our contact details are set out in the contact us section below.
We want to deal with your concerns fairly, effectively and promptly. However, some complaints are more complex than others and may take some time to investigate.
In order to assist in the speedy resolution of any complaint you may have, it’s important that we understand your complaint fully. Sometimes this means we may ask you to address your concerns to us in writing. This can be either by email or post to the addresses. We have established internal procedures for investigating any complaint, which may also involve experienced members of staff from Rowan Rewards Companies considering or investigation the complaint. Where appropriate, the complaint will be dealt with by someone who was not directly involved in the matter which is the subject of your complaint. The member of staff will either have authority to settle your complaint or will have ready access to someone who has the
authority. Our response will fully address the subject matter of your complaint and, if appropriate, will offer redress. If you phone us during our investigation and the member of staff handling your complaint is not available, then another member of our team will try to assist you.
Unless applicable data protection laws require responses within shorter timescales, we will try to resolve any privacy complaints you have within 15 business days of receiving your complaint and in exceptional circumstances, within 35 business days (and we will let you know if this is the case).
As noted above, if you are not satisfied with our reply/outcome, or otherwise with the handling of the complaint, you may have the right to lodge a claim before a relevant Data Protection Authority or the courts.
If you have any query regarding our data collection and protection practices or your rights, please do not hesitate to contact our data protection officer, at firstname.lastname@example.org.