Privacy Policy

1. Information We Collect

1.1 Personal Information

We may collect the following types of personal information:

• Account Information: Name, email address, phone number, and password when you create an account
• Profile Information: Profile picture, preferences, and settings
• Business Information: For business accounts - company name, business address, tax identification numbers
• Payment Information: Credit card details, billing address, and payment history (processed securely through third-party payment processors)

1.2 Usage Data

We automatically collect information about how you use our services:

• Device Information: Device type, operating system, unique device identifiers, mobile network information
• App Usage: Features used, time spent in app, crash reports, performance data
• Location Data: GPS location (when permitted) for location-based loyalty features and stamp verification
• Transaction Data: Loyalty card usage, stamps collected, rewards redeemed, visit history

1.3 Communications

• Messages you send to us through customer support
• Survey responses and feedback
• Marketing communication preferences

2. How We Use Your Information

We use your information for the following purposes:

Purpose	Description	Legal Basis
Service Provision	Operating and maintaining the qpong platform, processing loyalty transactions, managing your account	Contract Performance
Customer Support	Responding to inquiries, troubleshooting issues, providing technical support	Contract Performance
Personalization	Customizing your experience, recommending relevant offers and rewards	Legitimate Interest
Security & Fraud Prevention	Protecting against unauthorized access, fraud, and abuse	Legitimate Interest
Analytics & Improvement	Understanding usage patterns, improving our services, developing new features	Legitimate Interest
Marketing	Sending promotional materials, newsletters (with your consent)	Consent
Legal Compliance	Complying with legal obligations, regulations, and court orders	Legal Obligation

3. Information Sharing and Disclosure

We may share your information in the following circumstances:

3.1 With Business Partners

• Merchants: We share relevant transaction data with participating businesses to enable loyalty program functionality
• Reward Providers: Information necessary to fulfill rewards and offers

3.2 With Service Providers

• Payment Processors: Stripe, PayPal, and other payment services for transaction processing
• Cloud Services: AWS, Google Cloud for data storage and processing
• Analytics: Google Analytics, Firebase for app performance and usage analytics
• Push Notifications: Firebase Cloud Messaging, Apple Push Notification Service
• Customer Support: Zendesk, Intercom for customer service management

3.3 Legal Requirements

We may disclose your information when required by law, court order, or to:

• Comply with legal processes and government requests
• Protect our rights, property, or safety
• Prevent fraud or security threats
• Enforce our Terms of Service

3.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

4. Data Security

• Encryption: Data in transit is protected using TLS/SSL encryption
• Data Storage: Personal data is encrypted at rest using AES-256 encryption
• Access Controls: Strict access controls and authentication mechanisms for our systems
• Regular Audits: Security audits and vulnerability assessments
• Secure Infrastructure: Use of enterprise-grade cloud infrastructure with security certifications
• Employee Training: Regular security training for all team members

5. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes outlined in this policy:

• Account Data: Retained while your account is active and for 3 years after account closure
• Transaction Data: Retained for 7 years for tax and accounting purposes
• Marketing Data: Retained until you unsubscribe or withdraw consent
• Analytics Data: Anonymized and retained for up to 2 years
• Legal Requirements: Some data may be retained longer if required by law

6. Your Rights and Choices

6.1 Access and Control

You have the following rights regarding your personal information:

• Access: Request access to your personal data we hold
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your personal data (subject to legal requirements)
• Portability: Request a copy of your data in a machine-readable format
• Restriction: Request limitation of processing in certain circumstances
• Objection: Object to processing based on legitimate interests

6.2 Marketing Communications

You can opt out of marketing communications by:

• Clicking the unsubscribe link in emails
• Updating your preferences in the app settings
• Contacting us directly

6.3 Location Data

You can control location sharing through your device settings or app permissions.

7. Data Deletion

You have the right to request deletion of your personal data and account information. To delete your account and all associated data:

When you delete your account:

• Immediate Deletion: Your account will be immediately deactivated and you will lose access to all qpong services
• Data Removal: Your personal information, loyalty card data, and transaction history will be permanently deleted within 30 days
• Legal Retention: Some information may be retained longer if required by law (e.g., financial records for tax purposes)
• Irreversible: Account deletion is permanent and cannot be undone - you will need to create a new account if you wish to use qpong again

If you encounter any issues with the account deletion process, please contact our support team at [email protected] for assistance.

8. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected such information, we will take steps to delete it promptly.

9. International Data Transfers

qpong operates globally, and your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for international transfers, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for certain countries
• Certification schemes such as Privacy Shield successors

10. California Privacy Rights (CCPA)

California residents have additional rights under the California Consumer Privacy Act:

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information
• Right to opt-out of the sale of personal information
• Right to non-discrimination for exercising these rights

Note: We do not sell personal information as defined by the CCPA.

11. European Privacy Rights (GDPR)

If you are a resident of the European Economic Area, you have rights under the General Data Protection Regulation, including those listed in Section 6.1 above. You also have the right to lodge a complaint with your local data protection authority.

12. Third-Party Services

Our platform may integrate with third-party services and contain links to external websites. This Privacy Policy does not apply to third-party services. We encourage you to review the privacy policies of any third-party services you use.

13. Updates to This Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

• Update the "Last updated" date at the top of this policy
• Notify you through the app or by email for material changes
• Post the updated policy on our website

Your continued use of our services after any changes constitutes acceptance of the updated policy.