1. Introduction

• This privacy policy (the “Privacy Policy”) describes in detail how Blippon (“Blippon”, “us”, “we”, “our”) collects, uses, discloses and/or disposes of personal information in relation to users, business owners who have an account with Blippon, or guests who do not have an account (collectively referred to as “you”, “your”).
• Blippon takes your privacy very seriously and is committed in respecting and safeguarding your privacy and the confidentiality of your personal information at all times, as a matter of priority, when you use our services.
• Blippon processes personal information in accordance with the obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (also known as the “General Data Protection Regulation” or the “GDPR”) and the Data Protection Act (Chapter 586) of the laws of Malta and all subsidiary legislation thereunder (collectively the “Applicable Data Protection Laws”).

2. Our services

• BlippOn is a platform that allows its users to earn redeemable points, receive offers and important information by interacting with marketers (“Business Partners”) and/or their products and services, primarily through the use of its own proprietary mobile applications (mobile apps) and also through its websites, tools, platforms and services (“BlippOn Service/s”).

3. Data controller

• The data controller is registered with VAT registration number MT20039723 and with business address at 26/4, Ciantar Street, ZRQ230 Zurrieq, Malta.
• The data controller may be reached by mail at the above address or by email at her email address info@blippon.com. Should you have any queries or require further information with respect to the protection of personal data, kindly do not hesitate to contact us.

4. Interpretation

• All terms used in this Privacy Policy, which are not defined herein, shall have the same meaning as in the GDPR.

5. What type of personal information do we process?

• Identification information: your name, address, email address, mobile phone number, age, date of birth, gender;
• Social networking website user account names: Facebook and any other social media as may be advised from time to time when you choose to connect to Blippon through such social media accounts;
• Location information: information contained in the addresses you provide us with and/or information obtained through the GPS function on mobile devices or any other devices used to access the Blippon Services;
• Information in relation to any payment methods that you may choose, as and when applicable, including credit/debit/pre-paid card information and details as and if provided by you from time to time, as well as your payment history;
• Preferences: interests, preferences, feedback and survey responses (where applicable).
• Technical and usage data: IP address, login data, browser type and version, make and model of mobile devices, operating system, hardware version, platform, device settings and other technology identification on the devices used to access the Blippon Services, Bluetooth or WiFi signals, browser plug-in types and versions, operating system and platform, connection information such as the name of your mobile operator or ISP, language and time zone as well as information about how you use the Blippon Services including redemption of our offers, how you use your devices to access the Blippon Services, including the screens you visit and searches you make.
• Photos and any other data uploaded by you on Blippon and shared with other users of Blippon, such as reviews, comments, messages and any other information that you may elect to share with other users, or any information that, upon you explicit request/consent, is shared with Blippon for the purposes of providing the services, such as your address book of your contacts and telephone numbers.

6. Purpose and legal grounds

• Blippon uses your personal data for specific purposes including the hereunder:
  • The provision of the Blippon Services: to operate, maintain and improve the Blippon Services and related functionalities and features of the Blippon Services;
  • Account management: registration, creation and management of your account;
  • Management of your reviews, ratings and photos;
  • Promotional services: to promote our services and activities from time to time, to provide you with offers and any discounts from Blippon or Blippon’s Business Partners;
  • To provide you with a range of choices and information thereof in relation to our Business Partners in the vicinity of the location detected from your GPS;
  • For the purposes of compliance with applicable laws, legislation, regulation and/or any applicable rules to which Blippon may be subject;
  • For the purposes of defending any legal claims;
  • Verification of requests: to verify and process any requests sent by you pursuant to this Privacy Policy;
  • Address any queries that you may have in relation to the Blippon Services;
• Blippon uses your geolocation for the purposes of delivering location-based offers, products or services that may be of interest to you.
• The legal ground for processing your personal information shall be as follows:
  • Performance of a contract (the Terms of Use or the User Agreement with our business partners);
  • Legitimate interest (to perform the Blippon Services efficiently, to keep our records up-to-date, to promote any offers or discounts of Blippon or Blippon’s Business Partners, to keep Blippon updated and relevant, to perform our marketing strategy, to prevent any illegal activities, to defend any legal claims);
  • Consent (to receive marketing communications by emails, push notifications or texts, to access through your Facebook accounts (or any other social media account as may be applicable), to access your address book);
  • Legal obligations.

7. Who do we share your personal data with?

• In order to provide the Blippon Services, we may need to share information with certain third parties as well as internally within Blippon, as set out hereunder:
  • Internally: information may be shared internally to any employees of Blippon;
  • Suppliers: we share information with certain suppliers used to facilitate the Blippon Services, for example, our software developers who provide maintenance services and/or email, server, cloud providers;
  • Business Partners: although typically the reservations with Business Partners would be handled directly by you and, typically, your information is not shared with Business Partners, there may be remote instance when we are requested to share information about you and your use of the Blippon Services with our trusted Business Partners with whom we have entered into agreements to regulate confidentiality, privacy and security obligations;
  • Social media sites: when you use the Blippon Services and elect to share information with third-party social media sites, the information you share will be governed by the privacy policies of those social media sites and the privacy settings you have set with those social media websites;
  • Public authorities and any courts of law when necessary for the fulfilment of a legal obligation, and/or upon request from such public authorities and courts of law, and/or for the purposes of defending any legal claims;
  • Banks, and auditors: Blippon may share certain information to the banks where Blippon holds its bank accounts as well as to the auditors in order to fulfil any statutory or internal audit obligations;
  • Advisors: Blippon may share your information to its accountants and any other legal, tax or other advisors/consultants engaged by Blippon to perform certain services as necessary.
• Personal data may be shared by Blippon with entities that are located within the European Economic Area (EEA), which are subject to European Union legislations. Blippon does not share any personal information with entities that are located outside the EEA. Should there be any instances whereby Blippon shall be required to share information with entities located outside the EEA, Blippon shall inform you prior to sharing such information, where allowed by law.

8. How long do we keep your data for? 

• We will not keep your personal data for longer than necessary for the fulfilment of the purposes as set out in this Privacy Policy.
• The typical retention period by Blippon of your data will depend on whether you will continue having an account registered with Blippon. In such case, Blippon will process your personal information for the period that your account is active. Blippon will not retain and consequently will delete your personal information in case of inactivity on your account for a period of five (5) years, subject to limitation as set out in this Clause 8 of the Privacy Policy.
• Blippon shall immediately delete your personal information if you deactivate your account, with the exception of certain personal information that may be necessary to be kept for longer periods in order to comply with legal/statutory obligations or to defend any legal claims, or to be able to respond to any enquiries and/or investigations from any government authorities and/or agencies or courts of law. In the latter cases, the information shall be kept for the time necessary until the said legal/statutory obligation ceases to apply, or the legal claims and/or investigations and/or enquiries are finally concluded up to the last instance, and/or until the risks thereof are finally mitigated or eliminated.

9. What rights do you have? 

• Blippon has taken adequate technical and organisational measures in order for your rights to be respected.
• The following are your rights in relation to your personal information:
  • Right to information: you have the right to be informed on, amongst others, who, how, why, where, when and for how long your personal information is being processed. Should you require any further information, which may not provided in this Privacy Policy, kindly contact us on info@blippon.com;
  • Right to access: you have the right to know what personal data we hold on you. You also have the right to have access and/or obtain copies of such personal data when technically possible and when it does not have a negative impact on other data subjects. You shall have full control to access, view and manage your personal data by navigating through your Profile section on the app or website. However, should you wish to exercise your right to access, you may also send your request on info@blippon.com and we shall make sure that we comply with your request as soon as possible, and in any case not later than one (1) month from the date of the request. When Blippon is unable to provide the answers within one (1) month due to the high number of requests or the complexity thereof, Blippon shall inform you and shall comply by not later than two (2) months from the date of your request;
  • Right to rectification: you have the right to rectify your information in case it is inaccurate or not up to date. In order for you to be able to rectify your information, you can do so by navigating through your Profile section, and selecting ______________. Should you wish us to update your information or rectify any of your personal data, kindly contact us on info@blippon.com;
  • Right to be forgotten: You have the right to be forgotten and Blippon has an obligation not to hold your personal information for longer than it is necessary. Should you wish to deactivate your profile, please do so by selecting _________________ on your Profile section. Should you wish to request Blippon to have all your data deleted, kindly contact us on info@blippon.com and we shall respond to your request with undue delay by deleting your personal information, unless we have reasons of necessity or any obligations to continue holding your data for longer periods. In the latter events, Blippon shall duly notify you when possible and subject to restrictions set out at law;
  • Right to portability: when processing of your personal data is based on consent or contract you may require Blippon to have your data transmitted directly to you or to a third party, when this is technically feasible. Should you wish to exercise this right, kindly forward your request to info@blippon.com;
  • Right to object: you have the right to object to the way we process your personal information. Should you wish to exercise this right kindly contact us on info@blippon.com;
  • Right to withdraw consent: if you have given consent to Blippon to hold your personal information, and consent is the only legal ground for Blippon to hold such personal information, you have the right to withdraw your consent. Should you wish to withdraw your consent kindly submit your request to info@blippon.com, or unsubscribe from our contact list through the unsubscribe function from the app or at the end of any emails received from Blippon. Blippon shall immediately act upon your request;
  • Right to lodge a complaint: Should you have any complaints in relation to processing of your personal data, kindly address same to info@blippon.com. In case we were not able to address your concerns you may lodge a complaint with the Information and Data Protection Commissioner.

10. Automatic decision making

• Blippon will detect and automatically block, without any human intervention, any requests for registration of any individual that is not yet sixteen (13) years of age. Such individuals will not be able to create an account with Blippon.

11. Cookies 

• Our website uses cookies to help us provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile devices when you browse websites. Our cookies help us to:
  • Make our website/app work as per your expectations;
  • Save you from having to log in every time you visit the website/app;
  • Remember your settings during and between visits;
  • Improve the speed and security of the website/app;
  • Allow you to share pages with social networks such as Facebook;
  • Continuously improve our website/app for the benefit of our users;
  • Make our marketing more efficient (ultimately helping us to offer the best and most suitable service for you).
• We use the following types of cookies:
  • Essential – cookies that are essential to provide you with services you have requested (eg. stay logged in on your account);
  • Performance – cookies which measure how often you visit our sites and how you use them;
  • Functionality – cookies that are used to recognise you and remember your preferences or settings when you return to our site, so that we can provide you with a more personalised experience;
  • Advertising – cookies that are used to collect information about your visit to our site, the content you have viewed, the links you have followed and information about your browser, device and your IP address.
• You can “Like” or “Share” contents from our platform, app or website on different social media. The privacy implications in relation to the website cookies of such social media will vary from one social network to the other and will be dependant on the privacy settings you have chosen on such respective social networks.
• By accepting our use of cookies, you can benefit in full from all the functionalities of our website/app. By not accepting the use of some cookies, you can still access our website/app and view the content therein, however some features of our website/app may not be working properly.
• You can turn off cookies by adjusting your browser privacy and security setting to stop it from accepting cookies.

12. Updates to this Privacy Policy

• This Privacy Policy is subject to changes from time to time. Any revision of the Privacy Policy will take effect on the date that it was published on the website. Blippon shall keep you updated of any changes in such Privacy Policy by sending an email on the email address that you have provided us and/or by posting a notice on the website/app. Blippon invites you to check the Privacy Policy from time to time in order to be informed on the most current one.

This updated version of this Privacy Policy was issued on