The privacy of customers personal data is important to GoReward Agency. This Policy describes the rules according to which GoReward Agency processes the personal data of any person using the GoReward Agency’s website www.goreward.eu, mobile apps and any services offered by GoReward Agency.
General Definitions GoReward Agency
Service provider who needs to process customer’s personal data for the provision of service. Depending of the service the service providers are the following: Xolo Go OÜ - Asan Flaviu Alexandru (registry code 14717109, address Kalasadama 4, Tallinn, Estonia)
Natural person who is using GoReward Agency’s website, app or any services provided by GoReward Agency
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data
Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
A person who alone or jointly with others, determines the purposes and means of the Processing of Personal Data.
Depending of the service the Controller of the Customer’s Personal Data is:
Xolo Go OÜ - Asan Flaviu Alexandru or its affiliate if Customer requested GoReward Agency Service
A person who Processes Personal Data on behalf of the Controller
In the course of provision of Service, GoReward Agency may act as Processor by Processing Personal Data on behalf of its Customer or Customer’s legal entity. However, this Policy shall not regulate the GoReward Agency’s actions as Processor
Any services provided by GoReward Agency via website www.goreward.eu
GoReward Agency - Affiliate Marketing Agency
Content & Design of Affiliate Marketing Programs
GoReward Agency offers creative design and content services for affiliate programs, integration of web applications that lead to optimization of conversion rate and real-time click statistics
Payment Solutions & Affiliate Marketing Platforms
GoReward Agency offers integration services for online payment systems and affiliate marketing platforms that lead to the development of the number of affiliates that will generate sales through referrals
Online Promotion & Advertising of Affiliate Marketing Programs
GoReward Agency offers online promotion services for affiliate programs in order to increase the number of affiliates and increase online sales through recruitment solutions of affiliates
This Policy applies to Personal Data Processing where GoReward Agency acts as a Controller. Any personal data Processing conducted on behalf of the Customer or his legal entity is subject to an additional data processing agreement signed between GoReward Agency and the legal person controlled by the Customer.
Personal Data being collected
GoReward Agency Processes the following Personal Data about the Customer:
Personal Details – full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal address, e-mail address, mobile phone number, bank where the personal bank account exists;
Payment Data – data concerning payments for GoReward Agency’s Service and state fees, such as account number (IBAN), account holder name, bank name, transaction details, If the Customer chooses to pay for the Service by credit card or by PayPal, his/her payment details are not stored by GoReward Agency and therefore cannot be accessed by GoReward Agency.
Device Data – information regarding the device on which the Customer is using the GoReward Agency’s website/app, including the device’s model, name or any other identifier and the IP address;
Preference Data – Customer’s preferences in the GoReward Agency’s website/app;
Customer Support Data – communication between GoReward Agency and the Customer (inquiries submitted via the website, email, social media or chat);
Usage Data – data about Customer’s interaction in GoReward Agency’s website/app.
Sources of Personal Data collection
Majority of Customer’s Personal Data Processed by GoReward Agency is collected directly from the Customer.
Purposes for collecting and Processing Customer's Personal Data
Personal Data collected by GoReward Agency is Processed for the purposes established in the law or as described herein, including but limited for the following purposes:
Contractual Purpose – GoReward Agency needs to Process Customer’s Personal Data in order to enter into service agreement with the Customer and to provide Service to Customer;
Compliance Purpose – GoReward Agency needs to Process Customer’s Personal Data in order to perform obligations under applicable laws, such as to comply with anti-money laundering requirements, and combat fraud, ensure the fulfilment of international financial sanctions, comply with the lawful inquiries and orders of public authorities with whom GoReward Agency is obligated to cooperate;
Analytical Purpose – GoReward Agency needs to Process Customer’s Personal Data in order to manage, analyse and improve the Service, website and app;
Marketing Purpose – GoReward Agency needs to Process Customer’s Personal Data in order to send relevant promotional information to the Customer about GoReward Agency services and the related offerings by third parties we work with, if the Customer has granted an explicit consent to use his/her Personal Data for this purpose;
Personalization Purpose – GoReward Agency needs to Process Customer’s Personal Data in order to personalize the Service and the content provided to the Customer;
Communication Purpose – to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;
GoReward Agency shall not use Customer's Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted or authorized by law.
Customer is not subject to statutory obligation which obligates Customer to provide Personal Data described herein to GoReward Agency. The collection of certain Personal Data referred herein may be required under the law and/or inevitably necessary for the provision of service to the Customers (such as data necessary for the verification of the Customer). Failure to provide data may result in adverse consequences, such as, GoReward Agency’s inability to comply with our obligations under law. The Customer is welcome to ask for clarifications regarding the obligation to submit any specific Personal Data and also about possible consequences arising from the failure to provide the Personal Data.
Automated decision making
GoReward Agency is providing services for the Customers active in the certain field of activities. Not all fields of activities are supported by GoReward Agency’s services. GoReward Agency is using automated decision making in the pre-contractual Processing in order to establish sufficiently whether the Customer is eligible to use GoReward Agency’s services.
Automated decision making refers to a decision which is taken solely on the basis of automated Processing of Customer’s Personal Data. This means Processing using, for example, software code or an algorithm, which does not require human intervention.
During onboarding process, the Customer is being asked for the field of activity of the service provided in course of using GoReward Agency’s services. The automated decision making is necessary for entering into agreement with GoReward Agency. The automated decision making is used in order to accept or reject the Customer’s application to enter into a service agreement with GoReward Agency. In case the field of activity which the Customer wishes to act is not supported by GoReward Agency’s services, then the Customer’s application will be rejected. Upon rejection, GoReward Agency will inform the Customer by e-mail about the reasoning for rejection.
The Customer is entitled to request human intervention or object to the decision by contacting GoReward Agency.
Legal grounds for Processing
GoReward Agency is relying on the following legal grounds when Processing Customer’s Personal Data:
Processing is necessary for the performance or entry into a contract between Customer and GoReward Agency (GDPR article 6 (1) (b)), GoReward Agency is Processing Personal Data for Contractual Purpose under contract entered into between GoReward Agency and Customer;
Processing is necessary for compliance with a legal obligation to which GoReward Agency is subject (GDPR article 6 (1) (c)). GoReward Agency is Processing Personal Data for Compliance Purpose under legal obligations to which GoReward Agency is subject to;
Processing is necessary for the purposes of the legitimate interests pursued by GoReward Agency (GDPR article 6 (1) (f)). GoReward Agency is Processing Personal Data for Analytical or Personalization Purpose under legitimate interest;
Customer has granted a consent to the Processing of his Personal Data (GDPR article 6 (1) (a)). GoReward Agency is Processing Personal Data for Marketing Purpose under Customer’s consent.
GoReward Agency will take appropriate legal, organisational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized Processing, disclosure or destruction.
Upon transferring Personal Data to third parties, GoReward Agency will apply the following safeguards:
GoReward Agency enters into a data processing agreement with the relevant third party;
GoReward Agency makes sure that such third party undertakes to implement appropriate technical and organizational measures ensuring the Processing of Customer’s Personal Data in accordance with this Policy and applicable law;
GoReward Agency makes sure that (a) the third party is established in a jurisdiction which the European Commission has recognized as ensuring an adequate level of personal data protection, or (b) the Processing of Customer’s Personal Data is subject to other appropriate safeguards stipulated in the GDPR.
Integrity and retention of the Personal Data
GoReward Agency will retain Personal Data for the period required or permitted by applicable law, but no longer than it is reasonably necessary in order to achieve the purposes for which the Personal Data was collected.
GoReward Agency takes reasonable steps to ensure that the Personal Data we Process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.
Customer's rights in regarding to the collection of Personal Data
Customer has the following rights in relation to the Processing of his Personal Data:
Request information - GoReward Agency has provided all information which the Customer has right to receive in this Policy. The valid version of the Policy is available in GoReward Agency’s website at any time.
Right to access - Customer has the right to ask GoReward Agency to provide a copy of Customer’s Personal Data which GoReward Agency Process.
Right to Rectification - Customer has the right to ask GoReward Agency to rectify Personal Data in case the data is incorrect or incomplete.
Right to Erasure - Customer has the right to ask GoReward Agency to erase Personal Data, unless GoReward Agency is obliged to continue Processing Customer’s Personal Data under law or under a contract between the Customer and GoReward Agency, or in case GoReward Agency has other lawful grounds for the continued Processing of Personal Data.
Right to Restriction - Customer has the right to ask GoReward Agency to restrict the Processing of his Personal Data in case the data is incorrect or incomplete or in case his Personal Data is Processed unlawfully.
Right to Data Portability - Customer has the right to ask GoReward Agency to provide the Customer or, in case it is technically feasible, a third party, his Personal Data, which the Customer has provided to GoReward Agency and which is Processed in accordance with Customer’s consent or a contract between the Customer and GoReward Agency.
Right to Object - Customer has the right to object to Processing his Personal Data in case there is a reason to believe that GoReward Agency has no lawful grounds for Processing the Personal Data.
Right to withdraw Consent for the Processing of Personal Data - Customer is entitled to withdraw the consent granted for the Processing of Personal Data et any time. Withdrawal does not affect the lawfulness of the Processing conducted before the withdrawal.
Right to File Complaints - Customer has the right to file complaints regarding Processing of his Personal Data.
In order to exercise any rights referred herein the Customer is required to submit a written application to GoReward Agency (GoReward Agency’s contact details can be find under Section 16). GoReward Agency has the right to decline this application by justifying the reasons for the refusal.
According to the article 12(3) of GDPR, GoReward Agency is obligated to respond to the application within 1 month. However, GoReward Agency will make its best efforts to respond to Customer’s request within 1 week.
Cookies and tracking technologies
GoReward Agency is using automatically collected information and other information collected within its website through cookies and similar technologies.
Cookies are small text files that a website or its service provider transfers to the Customer's computer hard drive through his website browser (if Customer allows) that enables the website's or service provider's systems to recognize Customer's browser and capture and remember certain information. For example, cookies may help a website remember certain preferences the Customer has selected on the website, such as language preferences.
Within the website GoReward Agency is using the following types of cookies:
first-party cookies, which are stored to the Customer’s device by GoReward Agency. These cookies allow website owners to collect analytics data, remember language settings, and perform other useful functions that provide a good user experience;
third-party cookies, which are stored to the Customer’s device by other service providers on GoReward Agency’s website. GoReward Agency may use third-party analytics tools (such as Google Analytics), to help us measure traffic and usage trends for the GoReward Agency’s Service. Web analytic service providers analyse the usage of the GoReward Agency website and services so that GoReward Agency could improve and amend our website/app and function thereof.
Cookies are being used to serve the following purposes:
to store authentication information and protect Personal Data from third parties;
to personalize our Service, help remember Customer's choices within the website, understand and save Customer's preferences for future visits;
to provide customized advertisements, content and information;
to track Customer's entries, submissions, and status in any promotional or other activities on the Service;
to monitor and analyse the effectiveness of the Service;
to compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
The Customer can delete or block cookies through his browser settings at any time. However, some cookies might be necessary for the functionality of the GoReward Agency Services and usage of the website. Therefore, the Customer understands that when blocking or deleting the cookies some features within the website might not function correctly. For more general information about cookies please see http://www.allaboutcookies.org
Google Analytics and ads
GoReward Agency have implemented the following Google Analytics features:
Google Display Network Impression Reporting;
Demographics and Interests Reporting.
GoReward Agency along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding Customer interactions with ad impressions, and other ad service functions as they relate to our website.
Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, the Customer can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
GoReward Agency is using Google Analytics to measure and evaluate access to and traffic on the public area of our website and create user navigation reports for our website administrators.
GoReward Agency takes measures to protect the technical information collected by the use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the website and identify visitor preferences.
If a Customer receives commercial emails from us, he may unsubscribe at any time by following the instructions contained within the email or by sending an email to firstname.lastname@example.org
The Customer is able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the "Settings" section in the restricted area of the website.
The Customer has to be aware that if he opts-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications he receives from us, it may take up to five (5) business days for us to Process the request. Additionally, even after he/she opts-out from receiving commercial messages from us, he/she will continue to receive administrative messages from us regarding the Service.
Right to amend this Policy
GoReward Agency is entitled to unilaterally amend this Policy from time to time. Upon amending the Policy, GoReward Agency will notify the Customer about the terms by e-mail. In case the new terms refer to Processing of Customer’s Personal Data for any new purpose, which requires Customer’s consent, then GoReward Agency will not Process Personal Data for such new purpose, before it has received respective consent.
Should the Customers have any questions regarding this Policy or Processing of Personal Data, they are welcome to contact GoReward Agency with requests, inquiries or any complaints via email: email@example.com
By accepting this Policy, the Customer confirms that he has familiarized himself with this Policy, understood it and agree to its terms.
Last updated: Jan 01, 2022