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Privacy Policy and Notice of Personal Information Collection

1. Collection of Information
2. Use of Information We Collect
3. Disclosure of Information
4. Your Choices
5. Your Privacy Rights
6. Other Notices
7. Changes to This Privacy Policy
8. Contact Us

This Privacy Policy describes how Ebates Canada, Inc. dba Rakuten Rewards Canada ("we," "us," "our," "Company") collect, use, disclose, and protect information in connection with the Company websites, mobile websites, mobile applications, browser extensions, and any related services that refer or link to this Privacy Policy ("Services"). Company is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten Group, Inc., based in Tokyo, Japan.

1. Collection of Information

Sources of Collection

We collect, process, and use information about you when you:

• Register for our Services
• Interact with our Services
• Install and/or access our Services through our application(s), including our mobile application and browser extension
• Connect to our Services through third parties, including social media accounts, email accounts, and business partners (described in Section 3 below)
• Contact us for support
• Enter a sweepstakes, contest, or promotion, or respond to a survey or poll

We collect certain information when you submit or provide it to us directly. When you have installed our mobile application or browser extension or when you interact with our Services online, we also automatically collect information about you and your use of the Services through the use of log processes, cookies, location-identifying technologies, and other tracking technologies. Certain information is collected about you from third parties, including when you connect through a third-party service or business partner site or when information is shared by merchants and business partners with whom you’ve also interacted.

Types of Information We May Collect

The types of information we collect about you may include personal information of the following types:

• Identifiers that you provide us directly, such as your first and last name, postal address, email address, tax information (for sweepstakes, contest, and promotion winners), and/or phone number
• Identifiers collected through your use of the Services, such as unique online or device identifiers, IP address, device or session IDs and information regarding your system configuration (operating system and version), network, and connected hardware (e.g., computer or mobile device and carrier) and software applications (e.g., other applications installed on your mobile device)
• Customer Record Information, such as payment account name, payment account number, payment card expiration date and billing address
• Classification Characteristics, such as your gender, age, household income, marital status, or your inclusion in any other classification, only to the extent you provide this information to us as demographic information in a survey response that is identifiable to you
• Commercial Information about you, such as records of products, product types, merchants, merchant types, goods or services purchased, obtained, or considered by you, including products, merchants and coupons you searched for, viewed or clicked, items added to cart and abandoned, shopping trips initiated, merchant sites visited from our Services, transaction history related to our Services, purchase confirmation data, accrued cash-back, Scene+ points, and other loyalty currency
• Internet and other Network Activity, such as your browsing and search history and your interactions with our sites and Services, including:
• Products, coupons, offers, or merchants you search, click, favorite, and/or view, including clicks you make on the merchant sites you visit within our mobile app;
• URL’s of the pages you visit, including those tracked by our browser extensions and mobile application;
• Date and time stamps associated with such browsing, searches, and clicks;
• Click stream data, meaning the page by page clicks that you make as you navigate through our Services, including the web page visited before you came to our website;
• Locale preferences for your use of the Services Sensory-related information, such as audio recordings of your voice to the extent you call our member services representatives, as permitted under applicable law;
• Member account credentials, including username and password; and
• Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you, except “sensitive” information.

2. Use of Information We Collect

We use information we collect about you for the following business and commercial purposes:

To Provide Our Services and Manage Your Account, including to:

• Process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs
• Manage your account and interaction preferences, including tracking your favorite stores, merchants, and preferred locales and your transaction history
• Facilitate and manage your purchase transactions from our gift card mall
• Deliver you rewards or payments and identify opportunities for rewards and/or offers
• Send you technical notices, updates, security alerts and administrative messages
• Provide you member services and support regarding your account and reply to your questions, comments, and requests

To Personalize and Improve Our Services

We may use information we collect about you to create a profile of your preferences to personalize and tailor Services content so that it is more likely to be of interest to you. For example, we may use your most frequently visited stores or shopping history to display offers for similar stores in relevant parts of the Services or to present special offers that may interest you via our Services, including in-store.

We may also use information we collect about you to identify usage trends and perform statistical analyses to improve our Services, websites, applications, marketing efforts, and the products and services of our business partners we recommend or offer, in order to provide a better service to you in the future.

To Provide You Marketing Information

Subject to your consent where required, Company may use information we collect about you to provide you more personalized offers, special offers, discounts, and/or more relevant offers from our participating merchants via email and other direct communications, and through digital advertising. Subject to your consent where required, we may use your information to directly send you email newsletters, rewards offers, discounts, promotion codes, events and general information about the Services. You can manage these direct marketing communications as provided in Section 4 (Your Choices) below. We may also use your information to advertise to you online, including targeting advertising to you on other websites. You can withdraw your consent of use of your personal information for targeted online advertising as provided in Section 4 (Your Choices) and Section 5 (Your Rights).

To Protect You, Others, and our Business

We may use collected information to assess risk and to investigate and limit fraud, spam, and other malicious online activities in our Services, and to improve our security measures. We may also use collected information to assert our legal rights or to defend our legal rights against third parties.

To Comply With Applicable Laws

We may use information we collect about you to enable us to comply with applicable laws, rules, regulations, and judicial authorities in each geographical region in which we operate.

To Administer Contests, Sweepstakes, Surveys, Polls, and Promotions

From time to time, Company may invite you to enter various contests, sweepstakes, surveys, polls, and promotions. If you choose to participate in a contest or promotion, your personal information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize. If you choose to participate in a survey or poll, the feedback you submit will be aggregated and deidentified to provide us insight on business and shopping trends. We maintain this information in a deidentified manner and do not attempt to re-identify it.

To Administer Referral Programs

We may offer features that allow you to inform another individual about our Services. If you choose to use our referral features, we will ask for your referral’s email address to send them an electronic communication inviting them to join our Services. We will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Company for the purpose of Company sending a communication to invite them to join the Services. If you believe that one of your contacts has provided us with your personal information through our referral service and you would like to request that it be removed from our database, please contact us through our Member Services page. Please be sure to select “Other” under Email Topic in your request.

3. Disclosure of Information

We may disclose the below-specified categories of information for our business or commercial purposes, including the following:

Disclosure to Our Service Providers

We may disclose all categories of your collected personal information as necessary with our third-party service providers (which may include Company affiliates) who perform various business operations, solely for our benefit or on our behalf, under our instructions and in compliance with appropriate contractual, technical and organizational security measures to protect your data from unauthorized use, retention, or disclosure. For example, we may partner with other companies to provide you member support services, authentication services, prevent fraud on our Services, process payments, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, deliver direct marketing and communications, limit delivery of repetitive or unnecessary marketing or communications, facilitate your gift card purchases, fulfill your product purchases, place and fulfill your takeout orders, and administer your rewards or payments.

Disclosure to Our Business Partners

We work with various types of third-party business partners to offer you our Cash Back shopping Services. We may disclose the following types of information with the following types of Business Partners:

Affiliate Partners

When you click on a link to a merchant site presented on our Services to start your Cash Back shopping, you evidence your intent to interact with that business through our Services, and thereby are directing us to disclose certain information about you (including the link you clicked in our Services and a unique ID assigned to track that your shopping originated from our Services) to an affiliate network to properly account for your purchases with a merchant. For a small number of merchants that do not utilize an affiliate network, this information is provided directly to the merchant. The Affiliate Partner will collect Internet and Network Activity information about your use of our Services in relation to the merchant site, products, or offers. Our Affiliate Partners collect this information to track the shopping trip, but some of them may also use this information to measure performance, contribute it to their own user profiles and/or combine it with information they collect elsewhere, which they may make available for use by their other business clients. In such cases, via the instructions in Section 5, below, we offer our consumers with the ability to withdraw their consent which would signal these Affiliate Partners to not collect or use your information from our Services except as necessary to validate and provide your Cash Back.

Referral Marketing Partners

In order to expand your options to sign up for our Services and start your Cash Back shopping from third-party sites where you learn about our Services, we contract with certain referral marketing business partners to enable that functionality, which may require that we disclose certain data about you to them. For example, if you are referred to our Services from a business partner’s websites, we may provide that partner with information about your sign up to validate the referral and activate your Services account access from the partner’s site. In addition, we may disclose information about whether you have made a purchase with us recently and whether you have installed our mobile app or browser extension so that the partner can personalize their email and site content to you. We provide you with the opportunity to withdraw your consent from our disclosure of your information to these referral marketing business partners via the instructions in Section 5, below.

Financial Partners

For the purposes of providing you additional redemption options for your Cash Back we may disclose your collected information, including Identifiers, to financial business partners, which may include Rakuten Group Companies. If you select to receive points from Scene+ or other alternative methods of receiving your Cash Back, you are directing us to disclose your personal information, as necessary, to the relevant financial partner to facilitate that transaction. We may also disclose personal information about you to our financial partners in order to facilitate their marketing purposes and in some instances for the financial partner to directly send marketing to you. You may withdraw your consent of this disclosure for partner marketing via the instructions in Section 5, below.

Disclosure to Digital Advertising Providers

To provide us with targeted advertising and marketing services, we partner with certain third parties that automatically collect Internet and Network Activity information about your use of the Services, such as your browsing history, IP address, pages viewed, and links clicked, so that they can use this information to serve you ads for our Services on other sites you visit. Some of these third parties may also use this collected information to draw inferences about you for their own purposes or separately collect personal information about your online activities over time and across different websites (in addition to our Services) to help predict your preferences and to display (and enable other third parties to display) ads to you that are more likely to be of interest to you. You have the right to withdraw your consent of our sharing of your information with certain third parties for the purposes of cross-context behavioral or targeted advertising. To exercise this right, you can withdraw your consent via the instructions in Section 5, below. Note that this Privacy Policy covers only our use of data and does not include further use of data by third parties. If you wish to withdraw your consent of interest-based advertising in general, please visit http://www.aboutads.info/choices/ .

Disclosure to Other Rakuten Group Companies

We work closely with our affiliated businesses and companies within the Rakuten Group and disclose your personal information for our internal business administration. Some of our Service Providers and Business Partners to whom we disclose personal information, as described above, may include other Rakuten Group Companies. We may also disclose information in the categories of Identifiers (email address), Commercial Information (product metrics), and Internet and other Network Activity to our affiliates within the Rakuten Group for those corporate affiliates to analyze and monitor usage and trends to improve their services and websites and for strategic planning purposes at the Rakuten Group level. You may withdraw your consent of this disclosure with our affiliated businesses and companies within the Rakuten Group via the instructions in Section 5, below.

Disclosure for Legal Purposes

We may disclose the information we collect, including personal information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal processes or if, in our good faith opinion such disclosure is required or permitted by law without a specific disclosure; (ii) at the request of governmental authorities conducting an investigation; (iii) to enforce our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of Company or any third party.

In Relation to Business Asset Transfers

We may disclose the information we collect, including personal information, to any third party in connection with, or during confidential negotiations of, any proposed or actual merger, purchase, sale (including a liquidation, realization, foreclosure or repossession) or any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company. In such event, the acquiring company would be contractually required to use your collected information in accordance with this Privacy Policy and applicable law or to provide prior notice to you of any new or materially changed practices.

In addition to the above listed disclosures, we may also disclose aggregated or de-identified information that cannot reasonably be used by recipients to identify you.

4. Your Choices

Updating Account Information

We encourage you to maintain the accuracy of the information you submit to us. You may provide account updates by logging into your Service account and updating your information in the settings.

Communications Preferences

Email Marketing

We may send you periodic electronic communications and direct mailings when you sign up for an account. If you consented to receiving promotional email communications, you can withdraw your consent of receiving promotional communications from us at any time by following the instructions provided in those communications to unsubscribe or stop them, modifying the settings of your account, or contacting us through the Services. Please note that even if you withdraw your consent of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us.

Mobile Application Notifications

When using our mobile application, your preferences for receiving push notifications and other mobile alerts can be configured in the settings of your mobile device.

Data Collection and Sharing Preferences

You may in some cases have the option to decline to provide us with certain information; however, your choice may impact your use of certain features or services for which that information is a necessary component.

Mobile App/Browser Extension

You can prospectively stop all collection of information by our mobile application and/or browser extension by uninstalling our mobile application and/or browser extension. Because the browser extension and mobile application permit data about your online behavior on that device or browser to be collected when installed, even without interaction, they must be uninstalled to withdraw your consent to this data collection. In some instances, you can withdraw your consent of certain data collection by updating your mobile device settings.

5. Your Privacy Rights

You have certain rights in relation to your personal information under applicable laws, subject to certain exceptions.

Right to Know and Access

You have the right to request to know the personal information specific to you that we collected, used, disclosed for a business purpose, and sold or shared for the purposes of cross-context or targeted advertising, including the purposes of use, categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information. You also have the right to request to access (receive a copy of) the specific pieces of personal information we have collected about you (note that we will not provide any sensitive personal information we may hold in response to this type of request).

Right to Request Deletion

You have the right to request that we delete any personal information we collected from you or maintain about you, subject to certain exceptions. We will delete your personal information upon such request, except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, in which case we will inform you of that legal exception.

Right to Correct

You have the right to request that the Company correct any inaccurate or incomplete personal information we have collected from you or maintain about you, subject to certain exceptions. You have the ability to correct information provided by you in your account settings located at https://www.rakuten.ca/member/account-settings once you log in to your account.

Right to Withdraw Your Consent of the Sale or Sharing of Your Personal Information/Personal Data

As described in Section 3 of this Privacy Policy, we may make certain disclosures of information to our merchant partners, third parties or affiliates in order to provide you rewards and benefits and for our targeted marketing purposes. If you would like to withdraw your consent of having your personal information used or disclosed in this way, please contact us through our Member Services page. Please be sure to select “Other” under Email Topic in your request. Please note that to the extent you withdraw your consent of certain disclosures we may be unable to offer you some of our services which require such disclosures. If you have further questions, you can contact us using the information listed in the “Contact Us” section, below.

How To Exercise Rights to Know, Access, Correct, and Request Deletion

To assert your privacy rights please contact us through our Member Services page. Please be sure to select “Other” under Email Topic in your request. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Agents

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. For any agent making a request on your behalf, we may require you to prove that you authorized this agent to submit a request on your behalf, and we may require you to independently verify your identity or log in to your account to provide the access code.

6. Other Notices

Notice Regarding Information of Minors

This site and any related services are intended for adults 18 years of age or over as applicable by provincial law, and we do not knowingly collect or sell or share personal information of consumers under 16 years of age without affirmative authorization or without verifiable consent from a parent for those under age 13.

Retention of Data

We may retain information about you for as long as it is necessary to fulfill the purposes described in Section 2. Some of your information may be retained in our systems even after you request your information to be deleted if an exception applies, or in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, undertake any investigations necessitated by the foregoing, or otherwise use internally in a lawful manner that is reasonably aligned with your reasonable expectations or compatible with the context in which the information was provided.

Information Security

We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.

7. Changes to This Privacy Policy

This Privacy Policy is current as of the effective date set forth below. We reserve the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles and our practices in relation to personal information. If we make changes to this Privacy Policy, we will notify you by revising the date on this Privacy Policy. In the event of a material change, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).

8. Contact Us

Rakuten Rewards Canada is responsible for all personal information under our control. Our Privacy Manager is accountable for Rakuten Rewards Canada’s compliance with the principles described here. If you have any questions, concerns or complaints regarding the privacy practices of our organization or would like information on our use of service providers located outside of Canada please feel free to contact us at the following:

Email: privacy@ebates.com

Mail:

Rakuten Rewards Canada

Attn: Legal

800 Concar Drive, Suite 175

San Mateo, CA 94402

USA

Updated: 1 August 2024