Reward Gateway (USA) Inc (“we”, “us” or “our”) is committed to upholding your privacy and respect your rights under the Privacy Act 1974 and other applicable laws.
This Privacy Notice ("Notice") describes how any personally identifiable information (“PII”, “personal information”) we collect from you or from third parties, including AECOM (the “administrator”) who we have entered into a License Agreement with, about you on this website (the “portal”, “Smart Spend”) will be processed by us.
In the event of a conflict between the terms of this Notice and the terms of the License Agreement, the License Agreement shall prevail.
The Type of Information We Collect From you and How We Use It
We will collect various types of personal information from you when you use Smart Spend, depending on the services which you use. Further details of how we use your personal data are set out below.
Before you register
Before you register on Smart Spend, to allow us to carry out our eligibility checks we will ask the administrator to provide two pieces of information about you (such as your ZIP code, payroll ID, start date or date of birth).
The administrator will provide your Employee Number and Date of Birth to us to allow us to establish that you are eligible to register on Smart Spend**.
When you register
In addition to the personal data provided to us by the administrator, when you register on Smart Spend we will also collect and store personal information about you, such as your name, company identifier, email address, password, ZIP code, a contact telephone number, gender and date of birth. At the administrator’s choice, we may also collect additional information about you such as your office location.
You will also need to provide the information necessary to allow us to carry out our eligibility check (which will vary dependent on the information provided by the administrator, see above).
This information will be used in order to complete your registration and to allow you to use Smart Spend. You will not be able to register without at least providing your name, email address, password and ZIP code or date of birth, as these are used to secure your account and to allow us to confirm your identity if you contact the support team. Your date of birth is also used to confirm your identity if you contact the support team.
When you login
Each time you log in to Smart Spend, we automatically conduct checks against your Internet Protocol (IP) address to ensure your security. This includes looking up your IP address against a “proxy denylist” to check that someone is not using your credentials and trying to hide their location. This proxy denylist is operated by MaxMind, Inc. If your IP address appears on it, we will not allow you to login.
We also look up the IP address in a static database we download from MaxMind Inc. to check which country the IP is affiliated with. This helps us to further protect your account against people who may have access to your credentials. If we do spot a change, we will alert you and ask you to confirm your login in order to verify your identity before continuing.
This information along with time and event data (such as successful or failed logins) are also recorded in our database for audit purposes.
Depending on the services you use on Smart Spend, we may collect and process additional PII about you, as set out below.
When you use Cashback
If you visit a Cashback merchant on Smart Spend, we will record that you clicked and visited their website for the purpose of tracking the Cashback earned. We will provide the merchant with a pseudo-anonymous ‘click reference’ to allow us to attribute the purchase and Cashback to you.
If you have a problem with the merchant and your Cashback, we may need to provide them with additional information about your order to help. We will ask you for the minimum information we need to do this, but you will be responsible for the accuracy and level of detail it contains.
Each of these merchants are independent of Smart Spend so you should check their privacy terms to make sure you are happy with them before providing any other details to them.
When you withdraw your Cashback
If you make a request for a Cashback withdrawals to your bank account, you will need to provide your bank details for us to process the withdrawal but we will only store your bank details until the withdrawal is processed. They will be shared with our bank, HSBC, to process your request after which all the details will be destroyed.
Alternatively you will be able to withdraw your Cashback as part or full payment for goods on Smart Spend or ask us to donate it to the nominated charity on Smart Spend.
When you make a debit or credit card purchase
If you choose to purchase goods using a credit or debit card through Smart Spend, we will collect your payment details from you and pass them to Checkout.com, our secure payment processor, who will use them to process the payment and to comply with legal requirements. We do not store or process your credit or debit details on our servers.
We will also collect your delivery address from you, and use the contact details previously provided, to allow us to process the order.
If you opt-in to saving your credit or debit details for future use on Smart Spend, your personal information will be stored securely by Checkout.com and made available to you for future transactions. You can update or opt-out of saving details for future use at any time.
Where goods are dispatched by a third-party supplier, we may need to share your personal information with them to fulfil your order, such as your contact details and delivery address. This will be clearly indicated to you at the point of purchase. You will be able to review these suppliers’ privacy terms before any information is shared with them.
We will also carry out a fraud check during the order process. This check is carried out by our third party provider, Sift Science (“Sift Science”). Sift Science will only act in accordance with our instructions and how they will process your personal information is set out below.
Sift Science will collect information about your behavior on the portal (such as the length of time between logging in and reaching checkout), technical information about the device used (such as your browser version and IP address) and the details you enter at checkout (such as your contact details and delivery and billing address).
After you have placed your order and before goods are dispatched, Sift Science will use this information to provide us with a score based on the likelihood of fraud. The score provided determines whether your order is automatically accepted by us or queued for our human review. If it is queued for human review, we will carry out a manual fraud check to decide whether to accept or refuse your order or, in some circumstances, require payment to be made by an alternative, more secure mechanism such as a bank transfer. For more information about this processing activity, please contact us using the details provided at the end of this Notice in the “Contacting Us” section.
After too many failed orders
If too many failed orders originate from your account, we will automatically restrict access to your account. Before allowing you to access your account again, we will notify you and ask you for further supporting documents such as your utilities bill or payslip, as evidence that it is you attempting these orders. If these documents are not to our satisfaction, we may contact the administrator with the intention of verifying that it is you using your account in this way.
These supporting documents will only be used for the purpose of verifying your identity, will not be shared with any third parties and will only be retained by us until we have reviewed them, even if we are not satisfied with their legitimacy or authenticity.
You do not need to provide these supporting documents to us but, if you choose not to, then we will not be able to provide you with access to your account.
When you write a blog or comment / react to content
When you write a blog or comment / react to content on the site, we will collect your name and any other personal information you choose to share via your blog or comment. This information will be visible to us and other users of the portal but will not be used for any other purpose.
When you contact us
If you contact us for support purposes, we will require some information to handle your query. The following data are saved in Zendesk to enable processing: your name, email address, telephone number, and any other personal information you provide to us for the purpose of dealing with your query.
When you visit Smart Spend
When you visit Smart Spend we will automatically collect information about your visit, such as the pages you viewed, offers or services you viewed or searched for, length of visits to certain pages, the times and dates of these actions, details of page response times and any download errors that occurred.
We will also collect data from the device and application that you use to access our services, including your IP address (from which we may infer your geographic location), login information and browser type.
If you arrive at our website from an external source (such as a link on another website or in an email) we record information about that source.
We will use the above information in order to:
to administer Smart Spend and for internal operations, including troubleshooting, data analysis (including analysing the use of the various services available on Smart Spend and measuring their popularity and effectiveness), testing, research, statistical and survey purposes, and to comply with our legal obligations;
to improve Smart Spend to ensure that content is presented in the most effective manner for you and for your computer / device;
as part of our efforts to keep Smart Spend safe and secure to comply with our legal obligations;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. We, or our third party advertisers, may use your age or gender to determine whether advertising is relevant to you; and
to make suggestions and recommendations to you and other users of Smart Spend about goods or services that may interest you or them.
Other information and uses
We will also collect the PII you provide when you use Smart Spend:
- To provide you with our newsletter and with information about other third party benefits we offer that are similar to those you have already used or enquired about or that we feel may interest you.
- To notify you about changes (permanent or temporary) to our service.
- To ensure that content from our website is presented in the most effective manner for you and your computer.
- To administer our website and for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, and as part of our efforts to keep our website safe and secure.
Interaction with Children Online
We do not knowingly collect personal information on children. The content of our website and the products and services available are not intended for, or directed to, children. If you are under 13 years of age, then please do not use or access our website at any time or in any manner.
Information we receive from other sources
We will combine information we receive from other sources (as set out in this Notice) with information you give to us. We will use this information and the combined information for the purposes set out in this Notice (depending upon the services you access).
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and permitted under applicable laws. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosures of your Information
We use service providers to help us to provide the website, such as data storage providers, marketing email providers, analysis providers and benefit providers:
- Amazon Web Services EMEA SARL, a cloud hosting provider;
- Emailcenter UK, a transactional and bulk email gateway;
- Google Inc., a web analytics tool;
- FullStory Inc., an analytics service provider;
- New Relic Inc., a performance measurement tool;
- Twilio Inc., a SMS / text-messaging gateway;
- Formstack, LLC, a configurable data-capture provider;
- Zendesk Inc., a customer support platform;
- Atlassian Pty Ltd., a ticketing system for our internal teams;
- Mailgun Technologies Inc., a transactional and bulk email gateway;
- WalkMe, Inc., Contextual help, support and assistance for administrators.
We also share your personal information with:
Because the administrator pays us to operate Smart Spend for you, they’ll want to know how the website is performing. Except as set out elsewhere in this Notice, we will only share information with the administrator on an aggregated and anonymous basis about how often you’ve used the website and what services you used.
Our Internal Teams
We also use information about you on an aggregated and anonymized basis for internal management purposes. This type of information includes, for example, the number of activities you complete. However, you can’t be identified from this information.
Members of our Group
We share personal information with members of our group for the purposes of providing the benefits to you and managing our business: RG Engagement Group Ltd, Reward Gateway Pty Ltd, Reward Gateway (USA) Inc, Reward Gateway (UK) Ltd Branch, International Benefits Holdings Ltd., Asperity Employee Benefits Group Ltd
We will also disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case PII held by us about our customers will be one of the transferred assets; and/or
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of us, our users, customers and providers. This will include sharing your personal information as part of a legal or official investigation if we have evidence or reason to suspect that purchases on your account could be fraudulent.
Transfers of your Information
Your information, including PII, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this notice, and applicable law, and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
We remain fully accountable for these transfers.
To withdraw your consent in relation to direct marketing, please contact us using any of the details set out below in the “Contacting Us” section or change your preferences in the “My Account” section of Smart Spend.
California Privacy Rights
Residents of the European Economic Area (EEA)
If you are located in the EEA, applicable EU and Member State data protection laws provide certain rights to you. These include the rights to:
- Request details about the personal data that we process, and obtain a copy of the data that we hold about you;
- Correct or update your personal data;
- Port personal data that has been provided by you, in machine readable format, to another supplier
- Erase the data that we hold about you in some cases;
- Restrict processing in some cases;
- Object to processing based on grounds relating to the individual’s particular situation, where the processing is based on legitimate interest;
These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject.
We will only collect personal information from you where we need the personal information to enter into a contract or perform a contract with you (e.g. to provide you with a service), where the processing is in our legitimate interests when your interests and fundamental rights do not override those interests, where we have your consent, or where we have a legal obligation to collect and process personal information.
Where the provision of data is necessary to enter into a contract with us or for us to perform a contract with you and you choose not to provide the information we will not be able to provide our services to you.
You have the right to object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party), which is not overridden by your data protection interests or fundamental rights and freedoms. In particular we process your personal data to pursue the following legitimate interests:
- To prevent fraud on our platform;
- To provide customized communications, marketing, and advertising;
- To provide reporting and analytics;
- To provide troubleshooting, technical support, or to answer questions;
- To trial new features or additional services; and
- To help improve our services, applications, and websites.
Where we rely on your consent to process your personal data, you may decline to give your consent, or withdraw your consent for that specific processing at any time.
In some cases, we may also have a legal obligation to collect personal information from you.
If you have questions about the legal basis on which we collect and use your personal information or if you wish to assert your rights, please contact us using the contact details provided under the “Contact Us” section below.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We or the administrator may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Please know that you also have the right to submit a complaint concerning our processing of your personal data to the appropriate supervisory authority.
Resolving your privacy concerns and complaints
If you have a question or complaint about how your personal information is being handled by us, our affiliates or contracted service providers, please contact us using the contact details provided below.
Please note that as the administrator may store other information from your use of this service, you should also contact them directly if you would like to exercise your rights in relation to the data held by them.
Updating your information
It is important that the personal information we hold about you is accurate and current. Please keep your records on Smart Spend up-to-date. If you wish to update or amend your personally identifiable information or data you may do so by making the change within your account once logged in or by contacting our Helpdesk. We will respond to your request within 5 working days.
Storage of your information
Unless we need to keep your data for legal purposes, we will only retain your personal information for 60 days after the administrator lets us know you no longer have a relationship with them or they decide to use a different service.
The legal purposes for which we may need to retain your data for include:
- retaining payment records for one year to comply with PCI DSS regulations;
- retaining backups for up-to 180 days after deprovisioning; and
- retaining your order history for two years from the date of your order in case of a dispute.
We may also retain anonymized data about you for longer periods for integrity and financial reporting purposes.
Recordings of calls are retained for 40 days and chat transcripts are retained for 90 days.
We take the security and confidentiality of your personal information very seriously. We will use strict procedures and security features to aim at preventing unauthorized access, such as implementing ISO 27001 standards, access controls, penetration testing, the use of encryption and hashing and robust physical security controls.
Changes to this notice
Any changes we make to our Notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Notice.
If you have any queries, comments or requests regarding this Notice, or you would like to exercise any of your rights set out above, or contact our Data Protection Team, you can contact us in the following ways:
- by email at firstname.lastname@example.org or;
- by post at Reward Gateway (USA) Inc., 141 Tremont Street, Boston, MA 02111.