Last updated: 20 July 2020
1. We care about your privacy
Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt out of such uses.
2. Who are we?
3. How do we collect data?
Your personal data will either be provided by you, or will be collected by us, SmartReward X, or any affiliates of us or our Partners, or captured automatically. For example, we collect your personal data when you complete your Membership application, when you transact with a Partner and accumulate Points on your Membership account ("Account"), when you redeem a Reward, when you send us emails or when you browse our Site or App.
4. Are you over 18?
5. What information do we collect about you?
It may be necessary for you to provide us with certain personal data in order for you to receive the benefits of SRX, our Site or App. We will let you know when such data is essential for Membership. All other personal data is up to you to provide or not, as you prefer.
(a) Your Membership
If you are a SRX member ("Member"), some of the personal data we may collect about you includes:
your full name, month and year of birth, email address, telephone number, postal address, username, and password;
your Membership number, points balance, Account status and activities relating to your Account;
your transaction history or payment details when you purchase anything from our Partners and you use your Membership to accumulate Points (including the product or service purchased, the date of purchase, where you made your purchase, the cardholder's name, credit card number, expiry date and billing information);
information about the Rewards you redeem; and
your shopping preferences, including brand preferences and the types of products and services you may be interested in.
(b) When you visit our Site or App
We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:
your visits to our Site or App, such as your browsing history, how long you stay on our Site or App, and how often you visit;
your location information as provided by your mobile or other device when you interact with our Site or App, including your IP address and general geographic location; and the device that you use to browse our Site or App (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).
You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.
(c) Other information
We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).
6. How do we use your information?
We will only use your personal data for the purposes set out below.
(a) Account administration
To help administer and maintain your Account, including:
creating and updating your Account;
verifying your identity;
creating a single profile about you, including combining your information with any other personal data already held by us or any members of the SmartRewardX groups;
processing Points issuance and Reward redemptions;
completing transactions, including processing or facilitating payments;
sending you updates about new features and benefits relating to SRX; and
enabling features that allow you to personalize your Account on our Site or App, such as bookmarking your favourite Partners.
(b) Customer support
To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.
To provide you with marketing and promotional materials ("Marketing Communications"), if you choose to receive them. Please see the section on Direct Marketing below for more information.
To create personalised Marketing Communications tailored to your interests and preferences, and to provide you with the best possible customer experience in relation to our Site, App and your Membership. We may also use data analytics tools to determine whether our or any ‘SmartRewardsX Group members' offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, services and Rewards that we present to you.
(e) Optimisation and improvements
We may use your personal data to understand and improve our Site, App or SRX operations, or our Partners' or SmartRewardX Group members' operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Partners and our SmartRewardX Group members to enhance services or products, develop new features and benefits, and amend business, marketing and strategic operations and plans.
(f) Legal and administration purposes
We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.
7. Who do we share your information with?
If you are a Member, your personal data may be shared with our Partners to facilitate the processing of Points issuance, Points redemption and related transactions, as well as for data analytics purposes in order to improve their operations, services or products.
(b) SmartRewardX Group
Your personal data may be transferred to any SmartRewardX Group members for any of the purposes we have set out above. However, we will not provide your personal data to any SmartRewardX Group member in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.
(c) Service providers
Your personal data may be shared with our or any SmartRewardX Group members' service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate SRX, our Site and our App, to conduct data analytics, to help aggregate and anonymize the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services. Our service providers may contact you on our behalf or on behalf of our SmartRewardX Group members, for any of the purposes set out above.
(d) Professional advisors and assignees
When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.
(e) Government and regulatory authorities
8. Aggregated and anonymized data
Aggregated or anonymized data that does not include any personally identifiable information, may be used by us, our Partners, our SmartRewardX Group members or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.
9. Direct Marketing
If you have opted to receive offers and promotions from us, we may use your personal data to:
send you direct marketing communications in connection with the latest news, events, updates, offers, contests and promotions in relation to SRX;
send you direct marketing communications in connection with the latest news, events, updates, contests, promotions, offers, products, services and Rewards offered by our Partners or SmartRewardX Group members, which relate to retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications;
Analyze your preferences, online behaviour and transactional history in order to gain insights, so that we can customize the content and types of news, events, updates, contests, promotions, offers, products, services and Rewards that we present to you via our Site, our App, our direct marketing communications, social media or other communication means; and
in conjunction with any seasonal events, lucky draws and contests or other promotional activities.
We may send you direct marketing communications and market research invitations by email, through your online Membership user account or in-app notifications on your mobile device, when you access the Site or App, or through online banner advertisements, post, telephone or SMS.
Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time not to receive any direct marketing communications from us. Please see the section on Your rights below.
10. Can our Partners or affiliates send you marketing materials?
We will not provide your personal data to our Partners or our SmartRewardX Group members for them to send you marketing materials, unless you allow this.
If any of our Partners or SmartRewardX Group members wish to directly send you any marketing materials regarding their own products and services directly, then they must obtain your separate consent for this. We are not involved in any marketing done directly by our Partners or SmartRewardX Group members that is unrelated to SRX. However, we may send Marketing Communications to you on behalf of our Partners or SmartRewardX Group members, subject to your consent and in accordance with the Direct Marketing section above. If you agree to receive any marketing materials directly from our Partners or SmartRewardX Group members, then please carefully read our respective Partners' own privacy policies.
11. How do we keep your information secure?
12. How long do we keep your data for?
13. Your rights
(a) Access and correction
You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at email@example.com
In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.
(b) Opt-out of direct marketing
At any time, you can ask us to stop using your personal data to send you direct Marketing Communications, or you can customize how you would like to receive direct Marketing Communications from us. You can exercise your rights to do this by:
changing your settings on your online Membership user account or in the Site; or
following the unsubscribe instructions in the Marketing Communications we send to you.
We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.
We are not involved or responsible for any marketing materials sent directly by our Partners or SmartRewardX Group members that are unrelated to SRX. If you would like to stop receiving any marketing materials from our Partners or SmartRewardX Group members, please contact them directly in order to unsubscribe from their mailing lists.
14. Online tracking technology
Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.
You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalized experience.
15. Links to other sites
Our Site and App may contain links to other third party websites and applications, including those of our Partners or SmartRewardX Group members (“Third Party Sites”). We do not own or control, and are not responsible for the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our Site or App, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.
16. How do we manage updates to this policy?
17. How to contact us