Shoployal™ Privacy Policy

Your privacy is extremely important to us, therefore in this document we are going to outline how, why and with whom we would share/process/collect information.

Shoployal is a visit based loyalty system with location based notifications and personalized offers. Our vision is to help our users get rewarded based purely on their visit, discover the best products and amazing deals, and have a better experience in our partner stores.

We greatly respect your privacy, and this policy is designed and created in that spirit. In order to provide our service to you when you are shopping, we need data from you; otherwise we cannot give useful offers and visit points, which match the environment or location you are in, and match the preferences you have specified.

We are committed to collect as few personal data as possible, and our commitment to you is that whatever data we collect and process from you, we will do so to make your experience better and better.

In this document, we provide our Privacy Policy to inform you in more detail of our policies and procedures regarding the collection, use, and disclosure of information that we collect and receive from users of our Services.

This Privacy Policy applies to information that is provided or collected through all Services provided by Llyx Co Ltd trading as Shoployal (together, and with their parent corporations, other subsidiaries and affiliates, “Shoployal,” “we,” or “us”).

We are aiming to use common language to avoid any complicated terms, and make our Privacy Policy easily understandable. If you have any issues/questions related to our Privacy Policy, please send us an email to support@shoployal.ie and we will do our best to explain your questions in an understandable terms.

What information do we collect?

Personal Information provided by You to us

When you use the Shoployal website (“Website”), Shoployal mobile application (“Application”) or any of Shoployals’s services (the “Services”) (together, the Website, Application and Services are the “Shoployal Platform”), we may ask that you provide us with some personally identifiable information—information about you that can be used to contact or identify you (“Personal Information”).

When you install the app on Android or iOS, you will be assigned a random personal identification number (“SL ID”). Every data we collect is connected to this SL ID, to keep your Personal Information absolutely safe.

We don’t ask for your email address, or name or any other Personal Information at this stage, as we are trying to keep our system as anonymous as possible. Personal Information that we might collect related to your SL ID may include things like your location, age, gender and, if you elect to participate in certain parts of our Services, loyalty card numbers, and other information you supply to us concerning your preferences and interests expressed while using our Services.

What are “Visits”

If you choose to participate in our visit based loyalty program, we will receive information about visits that you make at select merchants including but not limited to the merchant’s name, the location, the date and time, the steps you take, the time spent in the retailer’s premises. This information will be linked to your SL ID.

Non-Personally identifiable information

When you use our Services (either on your mobile phone/device through the Application or though other devices), our servers may

• automatically record information that your mobile phone/device sends or transmits, including your device type, your device ID number (for example, your UDID), user settings, your geographical location (if you consent to that) and information about your use of the Services such as offers viewed and/or used, stores visited, information you entered,

• record which search terms you used, or which referring/exit pages brought you to our page, and date/time information,

• record certain non-personally identifying information record information provided by you, such as your gender or date of birth,

• record, determine or use information about or from another content delivery platform, and

• record information derived from such above information and other sources such as entries and offers viewed on our website or on our social media presence, or information provided by third parties.

• In addition, the Application and Services include geolocation and location presence awareness technology and functionality intended to make the Application useful at selected locations. To do that, we may use geolocation or presence technology. Some devices broadcast WiFi signals that can be received by a phone on which the Application is installed and if consent if given to receive such notifications. When the phone receives a signal (such as the presence of a WiFi network), the Application records it, and alerts you to available offers or items at that store or other information we deem useful.

• To make the Application and Services operate better, Shoployal may also collect other information based on WiFi signals, for example, the strength of the signal between the router and the phone, the duration the phone is near the router, including when the Application is in the background or not running (collectively, “Non-Personally Identifiable Information”).

Cookies and other usage data

We may use “cookies” (a cookie is a small data file that is kept in your device’s memory for record-keeping purposes), and/or other storage on your device to help us collect, maintain, and use this information, for two purposes.

First, to make the interactions easier and more personalized for you, we may utilize persistent cookies to save information relating to your Account and/or activity for future interactions with the Services.

To better understand how you interact with our Services and to monitor aggregate usage by Shoployal users and web traffic routing on the Services, we utilize session ID cookies to enable certain features of the Services. Third party advertisers on the Services may also place or read cookies on your browser. At any time, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please understand that if you do not accept cookies, you may not be able to use all portions or all functionality of the Services.

We may also use data collection tags or directives such as Javascript scripts, API calls, or similar means (individually or collectively, “Usage Tracking”) in combination with cookies and the demographic or psychographic data we have collected, and with third-party analysis partners, to analyse usage patterns of users anonymously and to serve advertisements to you that are tailored based on our analysis of what we believe you would respond favourably to in light of the information that we have collected or accessed about you as described above.

Usage Tracking allows us to count users who have visited certain web sites and pages within web sites, or used applications or features, to analyse the behaviour of users of our web sites and application, in order to improve the web sites and application, and to personalize and determine the effectiveness of promotional or advertising campaigns.

Information from Third Parties

We may also receive information about you from merchants or other third parties subject to the limitations of the privacy policies of those third parties.

How do we use the information?

We are trying to refrain sharing information, whoever sometimes it is necessary. We always keep our users information in high regard, therefore we will try to be clear on how this information is used/shared.

Subject to the restrictions described in this Privacy Policy and applicable law, we use information about our users only for purposes related to Shoployal’s business, including to

• communicate with you,

• to provide you information about Shoployal’s products and services,

• to respond to your requests,

• to update our Shoployal Platform and other offerings,

• to improve the content and user experience on the Application,

• to help you and others discover more about products and services,

• to let you know about offers of interest from Shoployal,

• to prepare and perform demographic and if permitted by the applicable Transaction Provider, benchmarking, advertising, marketing, performance and promotional studies.

Personal Information

We use Personal Information for the following purposes:

• to administer the Services,

• to provide, improve and optimize the Services,

• to personalize your experience,

• to provide you with software updates and/or product announcements,

• to understand users' needs and interests,

• to provide you with further information and offers from us that we believe you may find useful or interesting, such as targeted advertising and promotional campaigns. In order to contact you more efficiently, we may at times contact you through email, push notifications or through the Application.

Non-Personally identifiable information

We may use Non-Personally Identifiable Information for a variety of purposes. We may analyse trends through aggregated demographic and other information about users. We may also share this Non-Personally Identifiable Information with our preferred merchants or other 3rd parties to allow them to assist us in delivering tailored advertisements, promotions, discounts, and other incentives to you when you use the Services.

In addition, the geolocation and location presence information is used for other services, including but not limited to

• offering rewards points based on presence in a store,

• providing a reminder of items previously liked at the store,

• showing the best deals at the store,

• showing what is on sale or interesting in a certain area.

To offer those benefits, we use your device’s built in location services, Wifi Signals and similar internal sensors where present (pedometer, accelerometer, girometer etc.) to confirm your visit. When the phone receives your location of interest, if the Non-Personally Identifiable Information that we have collected about you is applicable, you would receive a message, for example, about available offers or an item based on your preferences. To avoid geolocation data from being used or received by Shoployal while the Application is in the background or not currently running on the phone, you can switch off notifications near or at stores in the Settings of the Application at any time.

Loyalty partners

If you have scanned a physical loyalty card to the loyalty wallet in the mobile application, the information acquired will only be saved locally on your device. Essentially the information used related to your scanned loyalty card will be guided by the 3^rd party’s Privacy Policy, whoever issued the card for you.

When do we share information?

Shoployal will not disclose any Personal Information to third parties except in limited circumstances which are set out below.

Before Shoployal begins to transfer Personal Information to any third party acting as our agent, we will confirm that they have adopted, are subject to, or are contractually obligated to comply with the principles and objectives of this Privacy Policy.

Examples of the limited scenarios where Shoployal may disclose Personal Information to third parties are:

• with your knowledge and consent;

• as described in this Privacy Policy;

• as may be required by law, regulatory authorities, or legal process;

• as permitted to protect the rights, property, safety, confidentiality, or reputation of Shoployal or its users

• to enforce our terms and conditions;

• to prevent fraud or cybercrime;

• to permit us to pursue available remedies or limit the damages that we may sustain.

Merchants and loyalty partners

If you chose to participate in the Visit based loyalty program, we share select visit information you with the appropriate Partner.

Group companies

We may share personal information with our affiliated, parent or group companies so that they may use personal information for the purposes described in this Privacy Policy, to provide additional services of those group companies, and for the purposes of connecting you to users of the other websites operated by the group companies. Shoployal remains responsible for the management of this information.

As our business continues to grow and change, we might restructure, buy, or sell subsidiaries or business units. In these transactions, customer information is often one of the transferred assets, remaining subject to promises made in then prevailing privacy policy. In the event that Shoployal, or substantially all of its assets are acquired, transferred, disposed of (in whole or part and including in connection with any bankruptcy or similar proceedings), personal information will as a matter of course be one of the transferred assets.

Third-Party service providers

Under the protection of appropriate agreements, we may disclose personal information to third party service providers we use to perform various tasks for us including

- for the purposes of data storage,

- consolidation, retrieval, analysis, or other processing,

- effective management of customer information

- to help us communicate with you.

These third parties are only given access to that information needed to perform their support functions, and are prohibited from using it for other purposes. These third parties include affiliated and unaffiliated service providers in the United States, Europe and in other jurisdictions.

Non-Personally identifiable information

We may share with third parties or the public (e.g., through white papers or press articles) aggregated information in a form that does not disclose your Personal Information, nor be reasonably likely to allow you to be personally identified, for industry analysis, demographic profiling and similar purposes.

We share this aggregated information so that merchants or other 3rd parties also understand how interested our users are in their products and services, so that they may also provide you with an optimal online experience, and so that additional retail or brand partners can see the opportunity in Shoployal and may also become partners and further enrich the Services and offers for our users.

How can You change or delete your Personal Information?

You may review, update, correct or delete your Personal Information by contacting us or by making the appropriate modifications in your preferences. You can also make changes in the Application by clicking on Settings and making changes. If you would like us to delete your SLID and/or remove your related records from our system, please contact us and we will delete your details within 30 days if we do not have any legal obligation to retain the record.

Security

We employ (sometimes in collaboration with 3^rd parties) administrative and electronic measures designed to safeguard and protect your information from unauthorized access and disclosure. In addition, we periodically review and enhance our security and privacy practices. While we cannot guarantee that loss, misuse or alteration of data will not occur we use commercially reasonable efforts to prevent this. It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.

International data

Your information will be stored and maintained on computers located in Europe or in United States, which might be outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Our Privacy Policy and its protection applies to your data. If you are located outside the United States and choose to provide information to us, Shoployal collects Personal Information in Europe and processes it there. Your submission of such information represents your agreement to this collection, storage and processing.

Reports

Shoployal occasionally discloses statistical information about app usage (e.g number of created rewards cards for a specific provider) in an aggregated form to the card providers. This data is exclusively not individualizable and therefore not person-related.

Links to other sites

Our Services may contain links or API’s (e.g. data or content exchange interfaces) to external services or websites of other companies or merchants. If you choose to select or click on a button, banner ad, or other type of third party link, you will be directed to that third party’s resources. The fact that we may link to or incorporate a merchant's services, functionality, or website, or present a banner ad or other type of advertisement, is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.

We do not exercise control over third party services, functionality, websites or other resources, including their use of personal information, and you should exercise caution when deciding to disclose any personal information to a third party.

We encourage you to read the privacy policies or statements of the other websites you visit to learn more about their privacy practices. These other parties may place their own cookies or other files on your computer or device, collect data or solicit personal information from you.

Children’s Information

The Services are not directed to children. We do not knowingly collect personally identifiable information from children under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us.

If we become aware that a member is under the age of 16 and has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.

Changes to this Privacy Policy

We are committed to complying with all applicable laws and regulations governing the collection and use of personal information. From time to time, Shoployal will review its collection, use, and disclosure practices in order to assure that we are complying with our Privacy Policy and all applicable laws and regulations.

If we decide to change our Privacy Policy, we will issue an updated version of this Policy with an updated date legend and/or notify you via the Websites or mobile applications or by other appropriate means prior to the change becoming effective if it is a significant change. You should review this Privacy Policy regularly to ensure you are familiar with any changes to it. If you do not consent to any changes to our Privacy Policy and as a result you would like us not to use or hold personal information about you in accordance with the revised terms, you may notify us here so we can discontinue your account.

How can you contact Shoployal?

If you have any questions about this Privacy Policy, please contact us at support@shoployal.ie. Our office is located at 27 Ferns Close, Ferns Bridge, Monasterevin, Co. Kildare, Ireland.

Last Updated: 23^rd of February 2017.