Privacy Policy

LAST UPDATED November 11, 2023


WHO ARE WE?

Reklaim Ltd. (“we”, “us”, “our” or “Reklaim”) collects your personal data, interest data (e.g., from survey responses) and demographic information (the “Data”) directly from you (“you”, “your” or the “End User”), through our mobile and web applications (the “Platform”). This Privacy Policy explains how we collect, use, and disclose your information. All capitalized terms not otherwise defined in this Privacy Policy shall have the same definitions ascribed to them in the Terms and Conditions.

WHAT DO WE DO?

Reklaim enables our End Users to monetize their Data by providing it to Reklaim via the Platform and allowing us to license, sell, or otherwise share it with Purchasers and other third-party partners. By joining and participating in the Services, you are providing your consent to Reklaim and the Purchasers (defined below) of Data to utilize your Data as described herein. The Services provided through the Platform allow you to determine what personal information you would like to share and be included in the compensation for the sale of your personal information to various third parties, including, but not limited to, brands, advertisers, ad agencies market researchers, banks, investment firms, and adtech platforms such as DSPs and data management platforms (collectively, the “Purchasers”) in accordance with the Terms and Conditions. Reklaim negotiates and brokers the transactions at fair market value as described in our Notice of Financial Incentive.

Reklaim provides Services directly to you as the owner of the Data by providing a medium to exchange your Data with the Purchasers through the Platform. Purchasers generally use the Data to help tailor their marketing and advertising programs, deliver more relevant advertising messages, conduct market research and product development initiatives, and to better understand consumer perceptions and behaviors.

We act solely as an intermediary between you as the End User and Data Purchasers. As such, we are not responsible for how Purchasers treat or use your Data, and we hereby specifically disclaim any such responsibility. Where applicable, we ask Purchasers to honor theDigital Advertising Alliance self-regulatory codes as well as applicable law.

YOUR DATA

What Data is Collected Through the Platform?

We will store your Data as long as your account is active and/or you are being rewarded for sharing Data. Any time your Data is shared as part of the Services, we will use a pseudonymized ID to recognize you, your browser and/or your device without allowing a Purchaser to know your real-world identity. The type of Data that we collect from you  and license to Purchasers may include:

  • Personal information such as email and phone number;

  • Pseudonymous advertising ID, cookie ID, or similar information about your browser or device;

  • Country, postal code, and time of day;

  • Demographics (such as gender, age, income range, ethnicity, religion, Etc.);

  • List of mobile applications you’ve installed when you’ve enabled that functionality within the Reklaim Platform;

  • Information about devices you use (e.g., make, model, operating systems (e.g., iOS, Android, Windows), and other similar information);

  • The information about permissions set in your app (e.g., when you’ve set delivery notifications, use location services, and other similar Information); and

  • Your opinions on advertising-related questions, such as brand awareness or quality (e.g., when you take a survey via the Platform);

  • Information and analytics about how our mobile apps and Websites are used. 

Reklaim does not collect Data we believe to be sensitive. As an End User, you have the ability to see the Data we have about you. If you want to “see” what Data Reklaim has about you in your Account, you may log onto the Platform, visit your Account settings and select “Download my data.”

How Is Your Data Collected via the Reklaim Platform?

Reklaim collects Data directly from you and other End Users via the Platform. You are able to control the type of Data that we collect. If you want to provide Data via survey responses but not provide Reklaim with your device data, no problem. As an End User, Reklaim puts you in control – the more information that you provide via our “share and earn” functionality (e.g., by participating in surveys, answering questions, sharing information via social media, etc.), the more data points collected via the Platform. We also license Data via third-party data partners, and that Data is stored on our Platform.

How Is Your Data Used and Shared?

The Data is utilized by Reklaim to create a detailed End User profile on our Platform. The more information that you provide via our “share and earn” functionality (e.g., by participating in surveys, answering questions, sharing information via social media, and similar services), the more Data collected via the Platform. The Data is sold by Reklaim to Purchasers at fair market value, and in turn, a portion of this revenue is given to you. If you’re a California consumer and want to know the categories of your Data we have sold over the past 12 months, please email us at privacy@reklaimyours.com.

How does Reklaim advertise its Reklaim Services?

Reklaim is enthusiastic about our Services and is excited to get the word out so that more End Users may use our Services to earn money for their Data. Where permitted by law, we may purchase consumer lists from third-party data brokers and engage in permission-based marketing campaigns via email, and SMS to encourage those consumers to sign up for our Services.

How does Reklaim manage data originating from public data breaches?

Reklaim believes that consumers have a right to know if they were the victim of a data breach. Fortunately, there are laws that require companies that experience a data breach to notify persons affected by the breach. Reklaim enables you to look up whether your data was breached as a public service. Reklaim does not obtain any additional data from these data breaches beyond confirmation if an email address or phone number is included in a publicly available data breach. We otherwise make no claims regarding the accuracy of the Breach data and disclaim all liability for the Breach data (if any) that Reklaim may enable you to view.

What Data is Collected Through the Reklaim Website(s), and how is it utilized?

When you visit our corporate Websites (e.g., www.reklaimyours.com, https://www.investors.reklaimyours.com) or related websites (collectively, “Websites” and each, a “Website”), we may collect and store information related to the use of the Websites, such as IP Address and information pertaining to devices, network, protocols and software and the date and time of visits.

We enable third-party partners to collect some data via the Reklaim websites and apps, including but not limited to Amplitude, Google Analytics, and Branch.io. This data is used to better understand Reklaim's Website and app traffic to improve the overall product. In some jurisdictions, their data collection may constitute a sale. You may click on the link for each of the aforementioned companies to better understand their privacy practices and your choices. Some of these companies may collect pseudonymous data on the Websites and mobile apps to serve targeted ads on other websites – a practice sometimes referred to as interest-based advertising. For more information about interest-based advertising and your choices, please visit http://aboutads.info/.

We will use this information to help us provide a more relevant and useful site experience to our Website visitors. This information is also used in the aggregate to perform statistical analyses of End User behavior and characteristics in order to measure interest in and use of the various areas of the Websites and apps. In order to use some functions of our Websites and apps, you may be required to register or provide personal information, such as your name and email address.

DATA SECURITY

We understand security's importance and are committed to safeguarding the Data collected or accessed. We have implemented reasonable security procedures to protect the storage and disclosure of Data we process, including encryption in transit and at rest. Access to Data is restricted to select personnel. No method of transmission over the Internet or method of electronic storage is 100% secure; therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

DATA RETENTION

Reklaim hopes to have long-term relationships with all our End Users. We generally retain Data as long as your Account is active, although we do our best to ensure that the Data we have on you is accurate and up to date. We count on our End Users to ensure that their Data is accurate and up to date. Reklaim reserves the right, in its sole discretion, to delete your Account and/or any rewards you may have earned if your Account has not been in use for 180 consecutive days. Reklaim also reserves the right in its sole discretion to retain aggregated End User response data for the purpose of analysis and marketing.

INACTIVE ACCOUNTS

Any Account that has not been logged into and for which no rewards have either been earned or redeemed for 180 days or more may be deemed inactive and the Account closed. In such instances, to request Account reactivation (subject to such terms, limitations, and requirements as we may impose from time to time), you may reach us by using the “Contact Us,” “Get in touch,” or similar contact link in the footer of any of the Reklaim sites or applications. We may modify our inactive Account rules and policies in our Rewards Programs from time to time, and if your Account becomes inactive pursuant to such then-current rules or policies, we may close your Account without any compensation or further obligation to you.

CALIFORNIA DATA SUBJECTS

The California Consumer Privacy Act (CCPA) provides additional privacy protections for California consumers, including a) the right to see what personal information we have about you, your computer or device (i.e., the right to know), b) the right to delete the information we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of personal information about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights.

The CCPA defines personal information broadly, and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.

Reklaim may not be able to honor a right if doing so would violate applicable law, but we believe these rights should apply to consumers everywhere. We’ve outlined how to honor them below. If you do not have a Reklaim Account but think we may have some personal information about you and want to better understand your rights, please email us at privacy@reklaimyours.com. California residents may also call our toll-free California consumer privacy hotline at +1 855 908 3282.

DATA ACCESS

If you want to “see” what Data Reklaim has about you in your Account, you may log onto the Platform, visit your Account settings and select “my info”. To be able to download and see all of the Data Reklaim has about you, scroll down the page and click “download my data.”

YOUR DATA CHOICES, OPT-OUT AND DELETION

Opting Out of Data Sharing, Preventing Future Use of Data, Data Deletion

Reklaim enables you to control the type of Data that we collect and how it gets shared. In some places like the State of California, Reklaim’s sharing of Data constitutes a sale. To opt-out of a data point from being sold or shared, you can simply log into the Platform and visit the Account page. From there, you may go to the specific data point in your Account profile and select not to share it. You may also choose to opt-out of all Data sales by Reklaim by selecting “opt-out of data sales” on the Account page or by filling out this form here. Alternatively, if you would like to stop sharing all your Data on the Platform and request that all Data associated with your Account be purged, you can delete your registered Account. Please refer to the Terms and Conditions for additional instructions on terminating your registered Account.

Reklaim also wants you to be aware of additional choice mechanisms that are available to you. For example, the Digital Advertising Alliance self-regulatory codes (the “DAA Codes) in the United States and Canada enable you to opt-out of certain advertising and marketing uses of Data. Reklaim adheres to the First Party principles of the DAA Codes, and many of our Purchasers adhere to the DAA Codes. For more information about the DAA and to better understand those choice mechanisms, please visit https://youradchoices.com/.

You can also use the tools made available via most mobile operating systems to refresh your IDFA and stop sharing your location at any point by doing the following:

  • Apple devices:

    • Opt-out of app-based tracking for interest-based advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to ‘ON.’  For iOS 6, you can do this by selecting Settings -> General -> About -> Advertising and toggling Limit Ad Tracking to ‘ON.’ You can do this for iOS 7 and higher by selecting Settings -> Privacy -> Advertising and toggling Limit Ad Tracking to ‘ON’. 

  • Android devices:

    • Opt-out app-based tracking for interest-based advertising by taking the following steps: (i) Open the Google Settings app on your device; (ii) Select “Ads”; and (iii) Opt-out of interest-based ads. You can obtain further information about how identifiers on mobile are used for advertising and receive instruction on how to opt-out of mobile advertising here: Google Privacy & Terms webpage.

A trade association called the Network Advertising Initiative also publishes a helpful list of ways to opt-out of targeted ads on mobile devices at https://www.networkadvertising.org/mobile-choice/. 

HEALTH DATA

Health information provided to Reklaim as part of the Data collected via the Platform is not subject to the Health Insurance Portability and Accountability Act (“HIPAA”) as we don’t request or accept patient data, diagnosis, or other Personal Health Information (“PHI”) as described under HIPAA. All health information is considered self-reported by End Users as part of the Data and may include self-reported questions about health conditions, medical diagnoses, and overall wellness information. Reklaim maintains stringent data security standards for health information collected as part of the Data in compliance with HIPPA HP as outlined in the “DATA SECURITY” section above.

Any health information provided to Reklaim may be used as described in the section “How Is Your Data Used and Shared?” above. End Users are provided a mechanism to opt-out of authorizing health information provided as part of the Data being sold or shared you can simply log into the Platform and visit the Account page and opt-out.

ONWARD TRANSFER

In addition to sharing data with Purchasers as described above, Reklaim shares information with trusted third-party vendors who may help us to manage the Websites and our Platform (e.g.,  cloud hosting services, email, and SMS messaging companies). These third party vendors are prohibited via written contract from using the information for purposes other than performing services for Reklaim.

Reklaim also contracts with trusted third-party vendors to collect and receive data on our behalf for use on the Platform. 

Reklaim may be required to disclose your information to third parties when obligated to do so by law and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including transfer, reasonably intended to meet national security or law enforcement requirements, or when we believe in good faith that disclosure is necessary to protect our rights, including but not limited to fraud and situations involving potential threats to the physical safety of any person.

Finally, Reklaim may transfer information, including any Data we have on the Platform, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. We will provide notice of this transfer in our privacy policy.

CHildren

Neither the Reklaim Website, the Platform, nor our Services are directed to children. They are intended for persons who are at least 16 years old as the Minimum Age defined in the Reklaim Terms and Conditions. While we do not knowingly obtain data from persons under 16, if we are made aware that we have received personal data from someone under 16, we will use reasonable efforts to remove that information from our systems.

CHANGES TO THE PRIVACY POLICY

We reserve the right to modify this Privacy Policy from time to time. If we make changes to the Policy, we will notify you by revising the “Last Updated” date at the top of the Policy. The most current version of this Privacy Policy will govern our current use of your information and your use of our Services, the Websites and/or the app and is located here. We encourage you to review our Privacy Policy regularly to stay informed about our privacy practices. Your continued use of the Website and/or the app and/or any of the Services following a change or changes to this Privacy Policy constitutes your binding acceptance of the change or changes.

GOVERNING LAW

We are based in Toronto, Ontario, Canada, and this Privacy Policy will be interpreted in accordance with the laws of the Province of Ontario. The information we collect may be transferred in or out of Canada and may be subject to foreign laws. Please refer to our Terms and Conditions for more information on how we handle disputes arising out of the use of the Services or the interpretation and application of the Terms and Conditions and this Privacy Policy.

CONTACT REKLAIM AND OUR PRIVACY OFFICER

If you have questions concerning the Privacy Policy or concerning the collection, use, and disclosure of your personal information, please contact us at:

Attn: Privacy Officer
Reklaim Ltd.
PO Box 60029 Etobicoke RPO 
Thorncrest, ON
M9A 5G2

Email: privacy@reklaimyours.com

For additional information on your rights regarding the collection and use of your personal information, you can contact the Office of the Privacy Commissioner in your jurisdiction.