The protection of your personal data is important to us,
RewardTower service. Therefore, we would like to offer you
comprehensive transparency regarding the processing of your
data in our services through this data protection
declaration. Because only if the processing is
comprehensible to you as a data subject are you sufficiently
informed about the scope, purposes and benefits of the
processing and we have complied with the requirements of the
GDPR and CCPA.
The person/team responsible within the meaning of the Basic
Data Protection Regulation (GDPR), the California Consumer
Privacy Act (CCPA) and other data protection regulations
is:
zhaokan5@gmail.com
Hereinafter referred to as "responsible party" or "we".
a. Information about our authorizations
We process personal data within the legally permissible
limits. This means that data processing operations are based
on a legal basis. These are standardised in Art. 6 Para. 1
GDPR. Most data processing operations are based on a
legitimate interest on our part (Art. 6 para. 1 lit. f
GDPR), on processing operations necessary for the
performance of the contract (Art. 6 para. 1 lit. b GDPR) or
on the basis of consent granted by you (Art. 6 para. 1 lit.
a GDPR). In the latter case you will be informed separately
(e.g. via a cookie banner) of the consent procedure.
Personal data will only be passed on in the cases described
below.
We process personal data only for clear purposes (Art. 5
para. 1 lit. b GDPR). As soon as the purpose of the
processing ceases to apply, your personal data will be
deleted or protected by technical and organisational
measures (e.g. by pseudonymisation).
The same applies to the expiry of a prescribed storage
period, subject to the cases in which further storage is
necessary for the conclusion or fulfilment of a contract. In
addition, a legal obligation may arise for longer storage or
disclosure to third parties (in particular to law
enforcement agencies). In other cases, the storage period
and the type of data collected as well as the type of data
processing depends on which RewardTower app functions you use
in each individual case. We will be happy to provide you
with information on this in individual cases, in accordance
with Art. 15 GDPR.
b. Information about the technical process of our app
Our app or the technical backend of our app ("network") is connected to various market research companies, marketplaces and enterprises (collectively "marketplaces"). These marketplaces regularly create surveys for their customers (companies). For these surveys, the marketplaces are looking for participants to participate in the surveys. In order to support the marketplaces in their search for participants, we have built our app with the services RewardTower app. We bring the marketplaces that are looking for participants together with the participants, i.e. you. As a user of the app, you deposit personal data in your user account when creating a user account and when using a user account. This personal data is also called "qualifications" in our app. This is because we have to filter each new survey for which participants are being sought to determine whether you are eligible for the survey. Either we can find this out based on the qualifications you have already provided or we will ask you again to complete some additional qualifications that you can store in your user account. If you are eligible for a survey because the qualifications required by the marketplaces and the qualifications you have stored match, you have the opportunity to participate. If you decide to participate, we will pass on the matching qualifications to the marketplace. The survey itself is either conducted in our app itself or on the marketplace website or the website of the market research company or a company. A link in our app will connect you directly to the survey.
The use of RewardTower app with all its functions requires the processing of certain personal data.
3.1 Informational use of the services of RewardTower app
The purely informational calling of RewardTower app requires
the processing of the following personal data and
information: the operating system used, the address of the
terminal device with which you access RewardTower app (IP
address) as well as the time of calling RewardTower app. All
this information is automatically transmitted from your app,
unless you have configured it in such a way that
transmission of the information is suppressed.
These personal data are processed for the purpose of the
functionality and optimization of RewardTower app, as well as
to ensure the security of our information technology
systems. These purposes are at the same time legitimate
interests according to Art. 6 para. 1 lit. f. GDPR.
The storage period of your personal data is a maximum of 14
days. This personal data will not be merged with other data
sources. Data will only be passed on to third parties in
necessary cases. Subject to further provisions of this
privacy policy, data will not be transferred to third
countries or international organisations.
to information according to Art. 15 para. 1 GDPR.
3.2 Contact form / Contact by e-mail
We process the data you provide us with when contacting us for the purpose of answering your enquiry, your e-mail or your request for a callback. Processed data categories are master data, contact data, content data, possibly usage data, connection data and possibly contract data. In individual cases, we forward this data to companies affiliated with us, i.e. only within our company/group. The legal basis of the processing depends on the purpose:
3.3 Creation and use of a user account
You can create a user account (hereinafter also referred to
as "profile") in our services in order to use the RewardTower
app services and your features.
Other personal data that you can independently store in your
user account or that you will be asked for in the context of
the qualification query for a new survey include your age,
your location, your gender and, if applicable, other
personal characteristics ("qualifications") required by the
survey partners for joining a survey.
When you log in to your profile, RewardTower app places
cookies on your device to allow you to stay logged in - even
if you need to reload the app in the meantime. By creating
your profile, you can use the functions of RewardTower
app.
The processing procedures connected with the creation and
completion of a profile serve the purpose of being able to
assign future usage procedures and to be able to access the
entire range of RewardTower app Services. Directly connected
with this is, for example, the checking whether you are
suitable for surveys that we receive from the marketplaces.
In order to participate in surveys, you must meet the
criteria requested for the specific survey. We will check
whether you meet the criteria either by asking you (if we
have not yet asked you for the criteria of the survey) or
automatically (if we have already asked you for the criteria
of the survey) after receiving the survey by comparing the
criteria with the information you have provided about
yourself. The processing of your data thus serves the
implementation of the contract, is therefore purpose-bound
and necessary in accordance with Art. 6 para. 1 lit. b
GDPR.
The storage of IP address and time of registration is
necessary to ensure the security of our information
technology systems. This is also in our legitimate interest,
which is why the processing is also lawful in accordance
with Art. 6 para. 1 lit. f GDPR.
The storage of the personal data entered by you is carried
out up to the time of the deletion of your profile at Make
Money app, beyond that only as long as the processing is
necessary for possible fulfilment of the contract.
It is not intended to pass on your data to third parties.
All checks on the requested criteria in a survey are carried
out by us on our servers.
3.4 Processing of payment & provision of credits
Payment
To process the payout/redemption of credits you receive through participation in surveys in or via our app, we offer various payment methods, some of which use payment service providers such as AdvCash, Payeer, Wise or Amazon (hereinafter “Payment Processors”). Processed data in this context are usage data, connection data, master data, payment data, contact data or even contract data. The legal basis for the use of payment service providers results from Art. 6 para. 1 lit. b GDPR. We have signed an order processing contract with each of the payment service providers so that the security of the processing of your data is guaranteed at all times.
Payment Processors
It is possible to process the payment requests with the
online payment service Payment Processors make it possible
to make online payments to third parties. If you choose any
Payment Processors, as your payment method, your data
required for the payment process will be automatically
transmitted to the Payment Processors. This is regularly the
following data:
Name, email address, IP address. The purpose of this
transmission is to check identity and creditworthiness.
Payment Processors may also pass on your data to third
parties if this is necessary to fulfil contractual
obligations or if the data is to be processed on behalf of a
third party. You can read each Payment Processor privacy
policy at their displayed websites. As the processing of the
data is necessary for the payment with and thus for the
execution of the contract.
3.5 Tracking & Tools
Information on the cookies used
Cookies are small files that are stored on your device (computer, tablet or smartphone). When a website is accessed, the cookie stored on a device sends information to the party that placed the cookie.
How we use cookies
We want you to be able to make an informed decision for or
against the use of cookies, which are not absolutely
necessary for the technical features of the app. Please note
that if you choose to decline the use of cookies for
advertising purposes, you will still receive advertisements,
but they will be less likely to be targeted to your
interests. However, you can still use the full functionality
of the website/service.
We distinguish between
We offer you the opportunity to choose your preferences regarding functional and marketing cookies when you first visit our app and at any time thereafter.
If your personal data is processed, you are the person concerned within the meaning of the GDPR and you as a user have the following rights vis-à-vis the person responsible:
4.1 Right to information
You can request confirmation from the person responsible as
to whether personal data concerning you is being processed
by us.
If such processing has taken place, you can request
information from the data controller about the following:
- the purposes for which the personal data are processed
4.2 Right of rectification
You have the right to ask the data controller to correct and/or complete the data if the personal data processed concerning you is incorrect or incomplete. The data controller shall make the correction without delay.
4.3 Right to limit processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4.4 Right of cancellation
4.4.1 You may request the controller to delete immediately the personal data concerning you and the controller is obliged to delete such data immediately if one of the following reasons applies:
4.4.2 If the data controller has made the personal data concerning you public and is obliged to delete it pursuant to Art. 17 para. 1 DPA, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to this personal data or to make copies or replications of this personal data.
4.4.3 The right of cancellation does not apply where processing is necessary
4.5 Right to information
If you have asserted the right to rectify, erase or limit
the processing vis-à-vis the controller, the controller is
obliged to notify all recipients to whom the personal data
concerning you have been disclosed of this rectification,
erasure or limitation of processing, unless this proves
impossible or involves a disproportionate effort.
You have the right vis-à-vis the controller to be informed
of these recipients.
4.6 Right to data transferability
You have the right to receive the personal data concerning
you that you have provided to the data controller in a
structured, common and machine-readable format. You also
have the right to have this data communicated to another
person in charge without interference from the person in
charge to whom the personal data has been communicated,
provided that the processing is based on a consent pursuant
to Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a
GDPR or on a contract pursuant to Art. 6 para. 1 letter b
GDPR and the processing is carried out by means of automated
procedures.
In exercising this right, you also have the right to obtain
that the personal data concerning you be transferred
directly from one controller to another controller, insofar
as this is technically feasible. The freedoms and rights of
other persons must not be affected by this.
The right to data transferability shall not apply to the
processing of personal data necessary for the performance of
a task carried out in the public interest or in the exercise
of official authority vested in the controller.
4.7 Right of objection
You have the right to object at any time, for reasons
arising from your particular situation, to the processing of
personal data concerning you which is carried out pursuant
to Article 6 paragraph 1 letter e or f FADP; this also
applies to profiling based on these provisions.
The controller will no longer process the personal data
concerning you unless he can demonstrate compelling reasons
for processing which are justified on grounds of protection
and which outweigh your interests, rights and freedoms, or
unless the processing serves to assert, exercise or defend
legal claims.
If the personal data concerning you are processed for the
purpose of direct marketing, you have the right to object at
any time to the processing of personal data concerning you
for the purpose of such marketing, including profiling,
insofar as it is linked to such direct marketing.
If you object to processing for the purposes of direct
marketing, the personal data concerning you will no longer
be processed for those purposes.
You have the possibility to exercise your right of objection
in relation to the use of information society services,
without prejudice to Directive 2002/58/EC, by using
automated procedures involving technical specifications.
4.8 Right to revoke the declaration of consent under data protection law
You have the right to revoke your data protection
declaration of consent at any time. Revocation of your
consent does not affect the legality of the processing that
has taken place on the basis of your consent until
revocation.
The processing is lawful until your revocation - the
revocation therefore only affects the processing after
receipt of your revocation. You can informally revoke your
consent by mail or e-mail. Your personal data will then no
longer be processed, subject to the permission of another
legal basis. If this is not the case, your data must be
deleted immediately after the revocation in accordance with
Art. 17 para. 2 GDPR. Your right to revoke your consent
subject to the above-mentioned conditions is guaranteed.
Your revocation must be addressed to:
zhaokan5@gmail.com
4.9 Right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial
remedy, you have the right to lodge a complaint with a
supervisory authority, in particular in the Member State in
which you are resident, your place of work or the place
where the alleged infringement occurred, if you consider
that the processing of personal data concerning you is in
breach of the DPA.
The supervisory authority to which the complaint has been
lodged shall inform the complainant of the status and
outcome of the complaint, including the possibility of a
judicial remedy under Art. 78 GDPR.
Automated decisions in individual cases, including profiling, are not carried out.
If your personal data have been disclosed to other recipients (third parties) for legal reasons, we will inform them of any correction, deletion or restriction of the processing of your personal data (Art. 16, Art. 17 para. 1 and Art. 18 GDPR). The obligation to notify is not applicable if it involves a disproportionate effort or is impossible. We will also inform you of the recipients upon request.