privacy

This privacy policy (the “Privacy Policy”) explains OTHERWARDS (“OTHERWARDS”, “we”, “us” or “our”) policies in relation to Personal Information collected from users of the OTHERWARDS .

We take the privacy of users of the OTHERWARDS Application seriously. We will obtain, retain and process information (including your personal and sensitive data) in accordance with the applicable law. We respect your right to privacy and we understand that, as a user to this OTHERWARDS Application you prefer to control your own personal information and preferences. [For this reason, we may ask you to register or to provide personal information and preferences when you visit certain areas of the OTHERWARDS Application, OTHERWARDS mobile application or request information.]

This Privacy Policy forms part of the conditions of use of the OTHERWARDS Application, which can be found at www.theOTHERWARDS.io. By using the OTHERWARDS Application, the OTHERWARDS mobile application and the services on the OTHERWARDS Application, you consent to the collection and use of your personal data by us for the purposes authorized below and for any other purpose, which is reasonably necessary for the provision of the proper administration of our relationship with you and the OTHERWARDS Application.

WHAT INFORMATION DO WE COLLECT?

In general, your use of our Application as a user is anonymous: we do not engage in any activity that will personally identify our users.

We collect Personal Information (such as name, address and e-mail address for example) provided by you when you use the OTHERWARDS Application and other services on the OTHERWARDS Application.

In particular, we may collect information from you through the OTHERWARDS Application in the following circumstances:

When you contact us by email or through the OTHERWARDS Application or through the OTHERWARDS mobile application with any particular comments or inquiries;

When you sign up / register on OTHERWARDS Application or OTHERWARDS mobile application;

When you sign-up to the OTHERWARDS newsletter; and

When you contact us to receive details about our OTHERWARDS product.

Marketing and communications data includes preferences in receiving marketing from OTHERWARDS and your communications preferences. For more details about data collection through the OTHERWARDS app see “Use of OTHERWARDS Application through mobile device” below

We may collect additional information in connection with your participation in any promotions or competitions offered by us and information you provide when giving us feedback or completing profile forms and questionnaires. We also monitor customer traffic patterns and the use of the OTHERWARDS Application, OTHERWARDS mobile application which enables us to improve the service we provide.

Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the individual identity has been removed.

Please note that while we do not explicitly collect personal information, we will treat any information held in accordance with the Data Protection Act 1998 and all applicable laws and regulations governing the protection and privacy of personal information.

We will only retain your personal information for as long as necessary to fulfil the purposes of satisfying any legal, accounting, and/or reporting requirements.

HOW DO WE USE THE DATA WE COLLECT?

We use personal information collected from you for the following purposes:

To deliver our products and services (including, without limitation, the OTHERWARDS Mobile Application);

To provide a more personalized service;

To contact you regarding the products or services that you have requested;

To respond to any comments or queries you may have;

To carry out auditing, research and analysis in order to maintain, protect and enhance the services we provide;

To transfer your details (including account details) to relevant third parties, public bodies, industry organizations and regulators as reasonably required for the operation of our business; and

To disclose your details to government and associated organizations as required by law.

Where you have not objected to such use, we might also use your information to let you know about other products and services which we offer which may be of interest to you. If you do not object initially, but you change your mind later, please email us at: info@theOTHERWARDS.io

CHILDREN UNDER THE AGE OF 13

The OTHERWARDS Application and OTHERWARDS mobile application is not intended for children especially those under 13 years of age. You must be 13 years of age or older to register, or use the OTHERWARDS Application and/or OTHERWARDS mobile application in any manner. By registering, visiting, downloading and using OTHERWARDS Application and/or OTHERWARDS mobile application, you represent and warrant to OTHERWARDS that you are 13 years of age or older, and that you have the right, authority and capacity to use the Application and/or mobile application.

CHANGES TO OUR POLICY

We reserve the right to make changes to this Privacy Policy at any time with or without prior notice by posting new terms on the OTHERWARDS Application and OTHERWARDS mobile application. We will only use information in accordance with the Privacy Policy under which the information was collected. If you regularly use the OTHERWARDS Application you should continue to check this Privacy Policy for updates and amendments, as you will be deemed to have accepted the changes if you continue to use the OTHERWARDS Application or OTHERWARDS mobile application after any changes have been posted.

HOW DO WE STORE AND MAINTAIN PERSONAL INFORMATION?

All of our employees are subject to obligations of confidentiality regarding information which they have access to in the course of their employment including the personal information of customers. All personal information is held in secure computer storage facilities and paper-based files. We take steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.

It may be necessary for us to maintain our records for a number of years. However, when information is no longer required, we will destroy records containing personal information securely.

DISCLOSURE OF YOUR INFORMATION

As we develop our business we might buy or sell businesses or subsidiaries. Where such a transaction occurs, or in the event that we are or substantially all of our assets are acquired, the transferred assets will generally include customer information but any such transfer shall be conditional on this information remaining subject to the restrictions on its use as set out in the Privacy Policy notice pre-existing the transfer.

We may employ other companies and individuals to carry out functions on our behalf including sending mail, providing marketing assistance, analyzing data and providing customer service. In order to carry out their functions these companies and individuals may require access to your personal data but we shall only disclose such relevant personal information as is needed by them to perform their functions.

Where requested to do so, we may co-operate with any court, tribunal, regulatory body, police authority or other similar authority in any investigations or proceedings concerning you or your use of the Application. This may include disclosing information about communications transmitted via the OTHERWARDS Application to such authorities where required.

We may also use and share information relating to groups of customers, without identifying individuals, to learn more about customer behavior and find ways of enhancing our service.

COOKIES – WHAT ARE THEY AND HOW DO WE USE THEM?

theOTHERWARDS.io may collect certain information by automated means, such as cookies and web beacons, when a user visits our Application. A “cookie” is a small piece of data that a Application can send to your browser, which may then be stored on your system. For further information on the cookies we use on our site and why we use them.

We sometimes collect anonymous information from visits to our Application to help us provide better customer service. This anonymous information is sometimes known as “click stream data”. We may use this data to analyze trends and statistics and to help us provide you with a better customer service.

We use Google Analytics cookies on our site to enable us to track user behavior and measure site performance. This helps us to improve the way our site works, for example, by ensuring that users can find what they are looking for easily.

All the data contained in our cookies is completely anonymous and does not contain any personally identifiable information. More information about Google Analytics cookies can be found at: support.google.com/analytics

We do not use flash cookies (sometimes known as local shared objects).

Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser, but this may restrict the use of some parts of the Application.

LINKS

The OTHERWARDS Application and OTHERWARDS application may contain links to other Applications. Please note that we are not responsible for the privacy practices of such other Applications, and we recommend you read the privacy statements immediately on entering other Applications. This Privacy Policy applies only to information collected through the OTHERWARDS Application and OTHERWARDS mobile application.

YOUR RIGHTS

IF YOU DO NOT WISH YOUR PERSONAL DATA TO BE USED IN THE MANNER SET OUT IN THIS PRIVACY POLICY PLEASE EXIT the OTHERWARDS Application and OTHERWARDS mobile application IMMEDIATELY AND DO NOT USE the OTHERWARDS Application or OTHERWARDS mobile application IN THE

FUTURE

You have the right to obtain a copy of any personal information, which we hold, about you and to notify us of any inaccuracies. If you would like to obtain a copy of your personal information please write to us using the address provided in this Privacy Policy. You will need to verify your identity and specify what information you require. We may charge you a fee to cover our costs incurred in providing you with a copy of your information.

We will be happy to answer any inquiries from you regarding this Privacy Policy, the personal data we hold about you or the use we make of it. If you have any queries, comments, or if you wish to correct or update the data we hold about you, please email us at: info@theOTHERWARDS.io

JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of New Jersey, USA applicable to agreements made and to be entirely performed within the State of New Jersey (even if your use is outside of the State of New Jersey), without resort to its conflict of law provisions. You agree that any action at law or in equity arising out of or relating to this Application or these terms shall be filed only in the state or federal courts located in the State of New Jersey and you hereby irrevocably and unconditionally consent and submit to the exclusive jurisdiction of such courts.

USE OF OTHERWARDS APPLICATION THROUGH MOBILE DEVICE

This Privacy Policy applies to our collection and processing of personal data through the OTHERWARDS Mobile Application.

Through the Mobile Application, we may collect mobile device identifiers, such as device type, IP address, operating system and your geographic location. If you choose to activate Facebook or Twitter on the OTHERWARDS application, we may also collect your name, sex, occupation and/or any other personal information you have provided to Facebook or Twitter.