Privacy Policy

Effective as of 17 April 2024.

Ascenda Loyalty Pte Ltd. and our subsidiaries and affiliates ("Ascenda," "we", "us" or "our") provides a loyalty rewards redemption platform. This Privacy Policy describes how Ascenda processes personal information that we collect or generate through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the "Services"). Ascenda may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

This Privacy Policy does not apply to information that we process on behalf of our enterprise customers as a “processor” (such as businesses and other organizations) while providing the Ascenda services to them. Our use of information that we process on behalf of our enterprise customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of an enterprise customer, please direct your concerns to that enterprise customer.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as "Europe", and "European" should be understood accordingly) below.

Index

• Personal information we collect
• How we use your personal information
• Retention
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us
• Notice to European users

Personal information we collect

Information you provide to us. Personal information provided to us about you through the Services or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, gender, and age.
• Account data, such as the username and password that you may set to establish an online account on the Services, date of birth, redemption code, and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Services, communicate with us via chat features, social media, or otherwise.
• Transaction data, relating to the Services, such as information about point redemptions, loyalty program membership, spending history, transaction amounts and merchant descriptions, cryptocurrency transfer, carbon certification, travel or hotel details.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Services, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may obtain personal information from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Data providers, such as information services and data licensors.
• Partners, such marketing partners and event co-sponsors.
• Content organizations, such as organizations who facilitate gift card, travel, card-linked offers, carbon offset, cryptocurrency, and other redemption services.
• Our enterprise customers, such as banks, financial institutions and other organizations that use our Services.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Data about others. We may offer features that help users invite their friends or contacts to use the Services or provide redemption benefits to their friends or contacts. To do so, we may collect contact details and other information about these individuals so we can deliver their invitations to the Services or provide the redeemed benefits to them. Please do not share anyone’s personal information with us unless you have their permission to do so.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Services delivery and operations. We may use your personal information to:

• provide the Services and operate our business;
• enable security features of the Services;
• establish and maintain your account profile on the Services;
• facilitate your invitations to friends who you want to invite to join the Services;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate;
• customer service and support; and
• provide support for the Services, and respond to your requests, questions, and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Services and our Services-related communications; and
• remember your selections and preferences as you navigate webpages.

Services improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Services, improve the rest of our business, help us understand user activity on the Services, including which pages are most and least visited and how visitors move around the Services, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes. For example:

• Direct marketing. We may send you or display to you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

• Interest-based advertising. We and our third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Services, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

Events, promotions and contests. We may use your personal information to:

• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Services; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to reidentify any such data. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, promotions, consumer research and website analytics). We use Stripe to process payment card transactions. We do not store your payment card information. You can view Stripe’s privacy policy at: https://stripe.com/en-gb-us/privacy

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Content organizations, such as organizations who facilitate gift card, travel, card-linked offers, carbon offset, cryptocurrency, and other redemption services.

Enterprise customers, such as organizations with whom we contract to provide our loyalty rewards redemption platform and other services.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Ascenda, financing of Ascenda, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Ascenda as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

Access, correct or update your information. If you have registered for an account with us through the Services, you may review, correct and update certain account information by emailing us at [email protected]. If you are located in Singapore, you may make (i) a request for access to a copy of the personal information which we hold about you or information about the ways in which we use or disclose your personal information, or (b) a correction request to correct or update any of your personal information which we hold about you by contacting us. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so, except where we are not required to do so under applicable privacy laws.

Withdrawal of consent. To the extent that you are located in Singapore and we rely on your consent for the collection, use and sharing of your personal information, you may withdraw consent and request us to stop using and/or disclosing your personal information for any or all of the purposes listed above by contacting us in writing. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to perform the actions necessary to achieve the purposes described in How we use your personal information section, or to provide our Service.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
• Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
  • Google: https://adssettings.google.com/
  • Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance: optout.aboutads.info.
  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track," please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the Singapore and may use service providers that operate in other countries. Your personal information may be transferred to the Singapore or other locations where privacy laws may not be as protective as those in your state, province, or country. We will take steps to ensure that your personal information continues to receive a standard of protection that is at least comparable to that provided under the applicable laws of countries in which you are located.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Services are not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Services from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Services and our business.

How to contact us

• Email: [email protected]
• Mail: 380 Jalan Besar, #12-10, Arc380, Singapore 209000

If you are located in Singapore, you may contact our Data Protection Officer if you have any enquiries or feedback on our personal information protection policies and procedures, or if you wish to make any request, in the following manner:

• Data Protection Officer: Junyang Ng
• Designation: Chief Technology Officer
• Email: [email protected]
• Mail: 380 Jalan Besar, #12-10, Singapore 209000

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the European Economic Area and the United Kingdom (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” as defined in the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the GDPR as it forms part of the laws of the United Kingdom (“UK GDPR”). Under the GDPR, “personal data” means information about individuals from which they are either directly identified or can be identified.

Controller. Ascenda is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of the GDPR. See the ‘How to contact us’ section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is Junyang Ng. You can contact them:	Our Representative in the UK. Our UK representative appointed under the UK GDPR is Junyang Ng. You can contact them:
By email to: [email protected] By postal mail to: 380 Jalan Besar, #12-10, Singapore 209000	By email to: [email protected] By postal mail to: 380 Jalan Besar, #12-10, Singapore 209000

Data Protection Officer. You can contact our Data Protection Officer by emailing the email address in the 'How to contact us' section.

Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
• Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
• Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see 'How we use your personal information’

Purpose	Categories of personal information involved	Legal basis
Services delivery and operations	Contact data Demographic data Account data Communications data Transaction data Payment data Data from third-party sources Device data	Contractual Necessity
Service personalization	Account data Device data Online activity data	Legitimate Interests We have a legitimate interest in allowing users to personalize their accounts to optimize the Services
Service improvement and analytics	Demographic data Account data Communications data Transaction data Data from third-party sources Device data Online activity data Communications interactions data	Legitimate Interests We have a legitimate interest in analyzing the use of our Platform to understand user behavior, preferences and needs in a data-driven manner Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to use cookies for the relevant purpose
Direct marketing	Contact data Marketing data Promotion data	Legitimate Interests We have a legitimate interest in promoting our Services and business and sending marketing communications for that purpose Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to send marketing communications
Interest-based advertising	Device data Online activity data	Legitimate Interests We have a legitimate interest in displaying advertising that is relevant to our users’ interests. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to use cookies for the relevant purpose
Events, promotions and contests	Contact data Demographic data Marketing data Promotion data	Contractual Necessity for the purposes of administering the event, promotion and/or contest Legitimate Interests We have a legitimate interest in hosting or (co-)running events, promotions and/or contests in order to promote out business and Services and optimize engagement
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law Legitimate Interests Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests We have a legitimate interest in pursuing relevant business opportunities
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests We have a legitimate interest in using privacy-preserving techniques in order to create insights into our users’ behaviour.

Other info
No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

Your rights
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
• Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe
We may share your personal information with third parties who may be based outside of the EEA and/or UK. In such circumstances, those parties' processing of your personal information will involve a transfer of your personal information outside of the EEA and/or UK where privacy laws may not be as protective as those in your state, province, or country.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.