Privacy Policy

Last updated February 20, 2020

This Privacy Policy describes how Tenqube Inc. (“we”, “us”, “our”, “Company”) collect, use, share, and protect information in connection with the Company websites, mobile websites, mobile applications, browser applications, and any related services that refer or link to this Privacy Policy (“Services”).

1. COLLECTION OF INFORMATION.

User-provided information

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

Automatically collected information

We and our service providers automatically collect certain information about you through:

The types of information you provide may include Personal Information. “Personal Information” means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:

We may also collect Personal Information and other information based on your use of the Services:

Information collected through our Apps

If you use our Apps, we may also collect the following information:

2. USE OF INFORMATION WE COLLECT. WE MAY USE INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:

Manage Your Account

If you provide us with Personal Information, we may use it to: (i) process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs; (ii) monitor and manage your account; (iii) track your shopping, deliver you any rewards or payments, and identify opportunities for rewards and/or offers; (iv) send you technical notices, updates, security alerts, and administrative messages; (v) provide you customer service regarding your account and reply to your questions, comments and requests; and (vi) comply with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that the Company operates in. We may also use your information to assess risk and prevent fraud.

Improve Our Services

We may process information through analyzing and monitoring usages and trends and performing statistical analyses to improve our Services and the websites, applications, marketing efforts, and the products and services of our affiliates to provide a better service to you in the future. We may also use this information to adapt Service content to be more likely to be of interest to you.

Provide You Marketing Information

To provide you more personalized offers and/or special offers, discounts and similar information, Company may send you newsletters, rewards, discounts, promotion codes, events, and general information about the Service if you consent. To match your profile and interest, we may create a profile of your preferences and provide advertisements, content or features. You can manage these communications in accordance with Section 4 (Your Choices) below.

Administer Contests, Sweepstakes, and Promotions

From time to time, Company may invite you to enter various contests, sweepstakes, surveys or 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.

3. SHARING OF INFORMATION

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services or Apps, which will enable them to collect data about how you interact with the Services or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share and disclose your information with the following third parties. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

5. YOUR CHOICES

You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may unsubscribe or opt out of receiving marketing emails from us by using the unsubscribe link on the footer of our marketing emails, by logging into your account settings, or by using the Contact Us option through the Services. Upon written request, we will provide you with information on whether we hold any Personal Information. We encourage you to maintain the accuracy of the information you submit to us, such as the information you provide us to register for your account. The Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. You may provide account updates and changes by logging into your account and changing settings or by using the Contact Us option through the Services. With respect to our mobile and other applications, you can prospectively stop all collection of information by the application by uninstalling the application. You may at any time opt out from further allowing us to have access to your mobile location data by adjusting the permissions in your mobile device. We will make good-faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. We will respond to your requests within a reasonable timeframe.

6. RIGHTS APPLICABLE TO EU USERS

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

Legal basis for using your Personal Information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. For the European Economic Area, there are different legal bases that we rely on to use your Personal Information, namely:

Choices under EU law

To exercise any of these rights please contact us in accordance with the contact details set forth below in Section 14 below. Please note that if you are not subject to EU law, these rights do not apply to you.

7. DATA SECURITY AND RETENTION

We take reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Although Company uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Company cannot guarantee the security of your information collected through our Services. Except as otherwise set forth under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. We retain the information collected via our Services until such time as you choose to close your account. After that time, we may aggregate the data and retain it for analytical purposes. We may also retain your information on backup media to comply with applicable law, to support financial audits, to resolve disputes, to maintain compliance efforts, and for other legitimate business reasons.

8. PROMOTIONAL COMMUNICATIONS

By signing up for an account, you may receive periodic emails from Company. If you consented to receiving promotional email communications, you can opt out of receiving such communications from us at any time by (i) following the instructions provided in those communications; (ii) modifying your Email Preferences in the Account Settings of your account; or (iii) contacting us through the Services. Please note that even if you opt out 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. Company mobile applications, browser extensions, and websites may send you notifications, such as alerts, sounds, and icon badges. Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.

9. ANALYTICS, TARGETING, TRACKING

We, and third parties with which we partner, may also use cookies, pixels, and other technologies to automatically collect information about your use of the Services, such as your click-stream data, browsing history, IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. Data collected from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such data was collected (also known as cross-linking). We may also work with third parties to serve ads to you as part of a customized campaign on other websites or platforms. These third parties may also collect Personal Information about your online activities over time and across different websites when you use our Services to help predict your preferences and to display (and to enable other third parties to display) ads to be more likely to be of interest to you. Some third-party service providers that we engage (including third-party advertisers) may also place their own cookies on your browser. If you wish to opt-out of interest-based advertising click here: http://preferences-mgr.truste.com/ (or if located in the European Union click here: http://www.youronlinechoices.eu/). Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.

10. THIRD-PARTY DATA

The Services contain hyperlinks to websites of merchants and retailers and other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.

11. SOCIAL FEATURES

Certain functionalities on the Services are specifically designed to permit interactions that you initiate between the Services and third-party websites or services, including third-party social networks (“Social Features”). Examples of Social Features include features that enable you to transmit your account content from a third-party website or service to our Services; to “like” or “share” our Services’ content on other websites or services; to sign in to the Services using your username and password from a third-party site or service; and to connect our Services with a third-party website or service. If you choose to use Social Features, the information you post or provide access to may be used by us and/or publicly displayed on our Services or by the provider of the Social Feature that you use. Similarly, if you post information on a third-party platform that references our Services (e.g., by using a hashtag associated with Company in a tweet or status update), your post may be published on our Services in accordance with the terms of the third-party website or service. When you use our Services with a third-party site or service, both Company and the third party may have access to certain information about you and your use of our Services and the third-party site or service. In addition, we may receive information about you if other users of a third-party website give us access to their profiles and you are one of their “connections,” or information about you is otherwise accessible through your connections’ web pages, profile pages, or similar pages on a social-networking or other third-party website or interactive service. The information we collect in connection with Social Features is subject to this Privacy Policy. The information collected and stored by the third parties remains subject to those third parties’ privacy policies, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third party websites or services.

12. SOCIAL LOGINS

Our Services or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Services or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

13. REFERRAL PROGRAMS

Company may offer features which allow you to inform an individual about our Services. If you choose to use our referral features, we will ask you for your referral’s email address to send them an electronic communication inviting them to join our Services. Company 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 sending this communication to invite them to join the Services. If you believe that one of your contacts has provided us with your Personal Information and you would like to request that it be removed from our database, please contact us at contact@tenqube.com.

14. CHANGES TO PRIVACY POLICY

This Privacy Policy is current as of the date set forth above. Company reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and where such changes will impact you as a data subject, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).

15. CONTACT US

If you have any questions regarding this Privacy Policy, please feel free to contact us by email at contact@tenqube.com or by mail at 83 Euisadangdaero 20th floor, Youngdenpogu, Seoul, Republic of Korea.