Privacy Policy

Last updated: December 27, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the QPONG virtual loyalty card platform and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve our loyalty card services. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Application refers to QPONG, the mobile application provided by the Company downloaded by You on any electronic device, including but not limited to iOS and Android devices.
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Konoven OÜ, Pärnu mnt 388b, 11612, Tallinn, Estonia.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: Estonia
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Loyalty Card means a virtual card stored in the Application that allows You to collect stamps, points, or rewards from participating merchants.
  • Merchant means any business or service provider that partners with QPONG to offer loyalty rewards through our platform.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Platform refers to the QPONG virtual loyalty card system accessible through the Application, Website, and merchant integrations.
  • Service refers to the Application, Website, and Platform.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of an app session or interaction with loyalty features).
  • Website refers to QPONG, accessible from https://qpong.me
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Loyalty program participation and reward redemption history
  • Merchant preferences and visit frequency
  • Device identifiers and app usage patterns
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service through our mobile Application, We may collect certain information automatically, including, but not limited to:

  • The type of mobile device You use
  • Your mobile device unique ID
  • The IP address of Your mobile device
  • Your mobile operating system (iOS or Android)
  • App version and build information
  • Crash reports and performance data
  • Push notification preferences and engagement
  • QR code scanning activity
  • Loyalty card usage patterns
  • Merchant visit history and check-in data
  • Location data (with Your permission) for nearby merchant discovery
  • Time stamps of app usage and features accessed

We may also collect information that Your browser sends whenever You visit our Website or when You access the Service through our mobile Application.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies

    Type: Session Cookies

    Administered by: Us

    Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

  • Cookies Policy / Notice Acceptance Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

  • Functionality Cookies

    Type: Persistent Cookies

    Administered by: Us

    Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Mobile Application Permissions

Our mobile Application may request access to certain features of Your Device. These permissions include:

iOS Permissions:

  • Camera Access: To scan QR codes for quick loyalty card access and merchant check-ins
  • Location Services: To find nearby participating merchants and provide location-based offers
  • Push Notifications: To send You updates about rewards, special offers, and loyalty program status

Android Permissions:

  • Camera: To scan QR codes for loyalty card functionality
  • Location: To discover nearby merchants and location-based rewards
  • Storage: To store app data and loyalty card information locally
  • Internet Access: To sync Your loyalty data and communicate with our servers
  • Push Notifications: To deliver timely updates about Your rewards and offers

You can control these permissions through Your device settings at any time. Disabling certain permissions may limit some functionality of the Application but will not prevent You from using core loyalty features.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our loyalty platform and mobile applications.
  • To manage Your Account: to manage Your registration as a user of the Service and Your loyalty program participation. The Personal Data You provide gives You access to loyalty features, reward tracking, and merchant partnerships available through our Platform.
  • To process loyalty transactions: to track Your purchases, award stamps or points, process reward redemptions, and maintain Your loyalty program status with participating merchants.
  • To facilitate merchant partnerships: to share relevant transaction data with participating merchants to enable loyalty program features, subject to merchant partnership agreements and Your consent.
  • To provide location-based services: to help You discover nearby participating merchants, receive location-specific offers, and enhance Your loyalty experience when You visit merchant locations.
  • To contact You: To contact You by email, telephone calls, SMS, push notifications through our mobile Application, or other equivalent forms of electronic communication regarding loyalty program updates, reward notifications, special offers from merchants, security updates, and service-related communications.
  • To provide You with personalized offers, merchant recommendations, loyalty program updates, and information about new participating merchants and services unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us, including customer support, loyalty program inquiries, and merchant-related issues.
  • For analytics and improvement: to analyze loyalty program effectiveness, merchant partnership performance, user engagement patterns, and to improve our Service, features, and user experience.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our loyalty programs and merchant partnerships, and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, process payments, provide customer support, and deliver loyalty program services.
  • With Merchant Partners: We may share relevant transaction data, loyalty program status, and visit history with participating merchants to enable loyalty program features, process rewards, and provide personalized offers. This sharing is limited to data necessary for loyalty program functionality and is subject to merchant partnership agreements.
  • For business transfers: We may share or transfer Your personal 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.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services, loyalty programs, or promotions that may be of interest to You.
  • For aggregated analytics: We may share anonymized, aggregated data with merchants and partners for analytics purposes, such as foot traffic patterns, popular merchant categories, and loyalty program effectiveness. This data cannot be used to identify individual users.
  • With Your consent: We may disclose Your personal information for any other purpose with Your explicit consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Data Deletion

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

How to Delete Your Account:

  1. Log into the QPONG mobile app using your credentials
  2. Navigate to your profile page within the app
  3. Look for the “Delete Account” button
  4. Follow the prompts to confirm your account deletion

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.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: [email protected]
  • By phone: +372 5825 7922
  • By mail: Konoven OÜ, Pärnu mnt 388b, 11612, Tallinn, Estonia