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ReferTech Privacy Policy

Last Updated: Sept 2023​​

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.refer.tech or app.refer.tech or go.refer.tech (the “Site”).

In this policy, “we”, “us” and “our” refer to Refer Tech Ltd.

We are committed to protecting your privacy.

WHAT DOES REFER TECH DO?

ReferTech enables online businesses (“Clients”) to create referral marketing campaigns and related services. We act as a service provider and data processor to our Clients.

Our Clients can: (a) empower their customers to refer their friends to their brand and then reward both the referrer and the referred friend when the referred friend becomes a customer; (b) deliver rewards and offers to customers; and (c) engage with their customers.

PERSONAL INFORMATION WE COLLECT

We hold various personal data relating to individuals who have interacted with our website or our services. The held and why we hold it will depend on how you interacted with our services.

There are three categories of which some or all may apply to you.

Referrer (Existing customers of our Clients)

Referee (New customer of our Clients)

Website visitor

 

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

We also collect “Customer Information” which is defined below.

As a Referrer we collect:

Your email address;

Your name;

The order details and order history of purchases of goods/services you have made with the Client;

Details of your interactions with our clients and our referral programme;

Details about whether you have referred someone and how you referred them;

If you are a customer of multiple Clients which use Refer Tech’s services, then we will hold your data in respect of each Client separately. Your data is never shared between Clients.

As a Referee we also collect:

Your email address;

Details of your visits to any refer-a-friend programme you are participating in; and

A record of any correspondence between you and us.

If you have registered as a Referred Friend under multiple refer-a-friend programmes provided by different Clients, then we will hold the above data in respect of each separate refer-a-friend programme you participate in. Your data is kept separate for each refer-a-friend programme and is never shared between Clients.

As a Website Visitor we also collect:

Your email address;

Your first and last name;

The details of any content you have downloaded;

Details of your visits to our website; and

A record of any correspondence between you and us.

 

When we talk about “Personal Information” in this Privacy Policy, we are talking about Device Information, Order Information, and Customer Information.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

As a Referrer

Collected from you by our Client (the Data Controller) or one of our Client’s partners and shared with us in accordance with the Client or our Client’s partners’ privacy policy so that we can operate the service for the Client or our Client’s partners; or

We may also receive your email address and name directly from you if you have entered it into our Referrer registration page.

 

As a Referee

Directly from you when you when enter it into our Referee registration page after you have clicked on a sharing link; or

From our Client if you have entered it into their website when using one of our features.

 

As a Website Visitor

We will receive some or all of the above data directly from you if you have:

submitted it to us via our website when completing a contact form;

submitted it to us when downloading content from our website;

submitted it to us when communicating with us through our website chat feature; or

submitted it to us when attending one of our hosted events.

We may also receive certain of the above data from one of our 3rd party partners if you have submitted it to them when downloading any of our content that they publish on our behalf.

HOW DO WE USE YOUR PERSONAL INFORMATION?

As a Referrer we need your data:

To allow us to recognise you and reward you as the Referrer when your friends interact with a sharing link you have sent them.

To send you service emails solely in connection with the refer-a-friend programme or the fulfilment of any reward or offer – for example to help you share offers with your friends, to notify you when your friends engage with an offer and to email you rewards as and when you are eligible to receive them. You can opt-out of receiving these emails at any time by clicking on the unsubscribe link at the footer of any email you receive from us.

To help confirm that friends referred through a refer-a-friend programme are not existing customers of the Client and are therefore eligible for referee rewards.

To allocate you into a customer segment (a set of customers grouped by their characteristics) and display messages, rewards and offers to you based on your segment. This allocation may be done automatically via a segmentation tool.

To process your responses and rewards and offers.

To investigate activity that we suspect as being contrary to the Client's terms and conditions or fraudulent in nature.

To respond to customer service requests.

We hold and process all of the above data as a Data Processor on behalf of our Client, who is the Data Controller. This means that we keep your data strictly confidential and we only ever use your data in accordance with our Client’s instructions.

 

As a Referee we need your data:

To check that you are not an existing customer of the relevant Client.

To allow us to recognise and reward you as a Referred Friend when you fulfil the conditions necessary to receive a reward under the refer-a-friend programme you are participating in.

To send you service emails solely in connection with the refer-a-friend programme – for example to email you rewards as and when you are eligible to receive them. You can opt-out of receiving these emails at any time by clicking on the unsubscribe link at the footer of any email you receive from us.

If, and only if, you have opted-in to receive marketing communications from the relevant Client, we will share your email address with the Client to enable them to send you those communications.

To respond to customer service requests.

We hold and process all of the above data as a Data Processor on behalf of our Client, who is the Data Controller. This means that we keep your data strictly confidential and we only ever use your data in accordance with our Client’s instructions.

As a Website Visitor we may use your data:

To email you specific content you have requested;

To keep you up to date with developments at Refer Tech and to send you marketing communications we think you may be interested in, unless you have opted-out of receiving such messages. You can opt-out at any time by clicking the unsubscribe link in the footer of any email you receive from us;

To respond to any customer service enquiries; and

To monitor traffic to our website and website performance.

We hold and process all of the above data as Data Controller either because you have expressly consented for us to do so, or because it is in our legitimate business interests to process it for the purposes specified above. As Data Controller, we are responsible for keeping your data secure and processing it in accordance with applicable legislation.

 

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

As a Referrer

In the ordinary course, we will only ever share your data with our Client or, on a confidential basis, with our own carefully selected sub-processors who are directly involved in delivering our services.

We never sell or give your personal information to third parties to use for their own purposes.

 

As a Referee

we will only ever share your data with:

our Client; the friend who has referred you (so that we can notify them when they are due a reward for their referral); or

 

As a Referee or Referrer

on a confidential basis, our own carefully selected sub-processors who are directly involved in delivering our services. Our sub-processors are only engaged with our Client’s consent and are primarily used for the purposes of hosting our platform and assisting with sending referral service emails to referrers and referees. We only allow our sub-processors to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may also share personal information with external auditors, accreditation and the audit of our accounts.

We never sell or give your personal information to third parties to use for their own purposes.

 

As a Website Visitor

We will only ever share your data, on a confidential basis, with our carefully selected Data Processors who we use in connection with the sales and marketing operations of our business. We will never sell your data to third parties.

 

for all user categories, in exceptional circumstances we may disclose your data:

  • as required by law.

  • when we (or our Client) believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties, investigate fraud, or respond to a government request.

  • to a third-party buyer or seller in the event that Refer Tech is involved in a merger, acquisition, or sale of all or a portion of its assets.

  • to any other third party with your prior consent to do so.

BEHAVIOURAL ADVERTISING

We may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

 

You can opt out of targeted advertising by:

Visiting some of these service providers that we may, from time to time, use:

    FACEBOOK - https://www.facebook.com/settings/?tab=ads

    GOOGLE - https://www.google.com/settings/ads/anonymous

    BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:  http://optout.aboutads.info/.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.  Additionally, please note that your information will not be transferred outside of the European Economic Area (EEA).

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at sam@refer.tech.

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