PRIVACY POLICY

Solution One Partners, Inc. — My Reward Store

Last Updated:

Solution One Partners, Inc., a Nevada corporation doing business as My Reward Store (“My Reward Store,” “we,” “us,” or “our”), operates the My Reward Store platform and related websites, applications, rewards programs, redemption marketplaces, and services collectively referred to in this Privacy Policy as the “Services.” All references in this Privacy Policy to “My Reward Store,” “we,” “us,” and “our” mean Solution One Partners, Inc.

We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you access or use the Services.

By accessing or using the Services, you acknowledge the practices described in this Privacy Policy. Your use of the Services is also subject to the applicable Terms and Conditions presented when you register, join a program, or access the Services.

1. Our Services and Our Role

My Reward Store provides rewards, loyalty, incentive, recognition, referral, promotional, and redemption services for participating businesses and organizations referred to in this Privacy Policy as “Clients.”

Our Role. For nearly all personal information processed through the Services, My Reward Store acts as a service provider (as defined under the California Consumer Privacy Act) and a processor (as defined under other applicable state, provincial, and federal privacy laws). We process personal information on behalf of, and in accordance with the documented instructions of, the Client that sponsors the program in which you participate.

This means:
  • The Client — not My Reward Store — is the “business,” “controller,” or equivalent decision-maker with respect to your personal information.
  • The Client’s own privacy policy governs its collection and use of your personal information, and you should review it.
  • We do not use personal information processed on a Client’s behalf for our own independent purposes, and we do not combine personal information across Clients, except as expressly permitted by applicable law and by our agreement with the Client.
  • We do not sell personal information, we do not share personal information for cross-context behavioral advertising, and we do not disclose personal information to advertising networks, ad exchanges, data brokers, or social media platforms for advertising purposes.

Limited Independent Purposes. My Reward Store acts as a business or controller only for the limited purposes of: (a) authenticating users and securing accounts; (b) detecting, investigating, and preventing fraud, abuse, and security incidents; (c) maintaining our own business, billing, and transaction records; (d) complying with our own legal obligations; and (e) establishing, exercising, or defending legal claims. We do not use personal information for any other independent purpose.

Depending on the services selected by a Client, My Reward Store may:
  • administer or facilitate some or all of a Client’s rewards, loyalty, incentive, recognition, referral, or promotional program;
  • provide a branded or white-labeled My Reward Store experience;
  • provide a connected rewards redemption store or marketplace;
  • facilitate the redemption of points, awards, benefits, discounts, or other incentives; or
  • provide related technology, communications, customer support, fulfillment, reporting, and administrative services.

The scope of the Services and the information processed may vary depending on the applicable Client program.

Financial Incentive Notice. Points and Awards are issued in connection with a Client's rewards program. The Client is the sponsor of that program and is responsible for its program terms and for any notices or disclosures required by applicable law, including any notice of financial incentive required under the California Consumer Privacy Act.

2. Eligibility and Access

The Services are not generally offered to the public.

Access is limited to individuals who are authorized to participate in a program sponsored by a Client. Users may be required to be active employees, members, customers, franchisees, program participants, or other eligible individuals, as determined by the applicable Client.

A Client may establish, confirm, modify, or terminate a user’s eligibility for access to its program. If a user is no longer eligible under the Client’s program requirements, access to some or all of the Services may be suspended or terminated.

Users must be at least 18 years old. Eligibility determinations are made by the Client. My Reward Store does not make automated decisions that produce legal or similarly significant effects concerning a user.

Depending on the applicable Client program, users may access the Services through direct account registration; an invitation or activation link; single sign-on; a Client website or application; an application programming interface or other system integration; or another authentication method approved for the applicable program.

3. Information We Collect

The information we collect depends on the Client program, the features being used, and the user’s interactions with the Services.

A. Account and Identification Information
Name; email address; telephone number; mailing or shipping address; username; password or other account authentication information; Client or program affiliation; membership, employee, customer, or participant identifier; and account status and eligibility information. Depending on the Client program, we may also collect demographic information, such as age or date of birth, gender, and general geographic area, where provided by you or by the Client.
B. Program and Rewards Information
Points or award balances; rewards earned or redeemed; program activity; redemption history; referral activity; promotional eligibility; offer activation and usage; gift card or award information; program preferences; and communications regarding available rewards, awards, or deals.
C. Transaction and Order Information
Products or services ordered; order and transaction history; amounts paid; points, awards, discounts, or credits used; billing and shipping information; order status; fulfillment and delivery information; returns, cancellations, and refunds; and communications relating to the transaction.

Payment card transactions are processed by Stripe or another authorized payment processor. My Reward Store does not store complete payment card numbers. Payment processors collect and process payment information in accordance with their own terms and privacy policies.

D. Communications and Support Information
Information users provide when they contact customer support; submit a question, complaint, or request; report an issue involving an order, reward, offer, or account; respond to a survey or promotion; request access to or removal of their information; or otherwise communicate with My Reward Store or a Client through the Services.
E. Device and Usage Information
Internet Protocol address; browser type; operating system; device type; device identifiers; pages or features accessed; links clicked; date and time of access; referring website or application; approximate location derived from an IP address; session activity; and diagnostic, security, and performance information.
F. Information Received From Clients and Other Sources
We may receive information from participating Clients; Client systems and integrations; identity and authentication providers; rewards and fulfillment providers; merchants and marketplace partners; payment processors; customer service providers; and other parties involved in operating the applicable program.

Clients are responsible for providing personal information to My Reward Store in accordance with their own privacy obligations and applicable law.

G. Referral Information About Other Individuals
Certain Client programs include a referral feature. If you choose to refer another person, you may provide us with that person’s name, email address, or telephone number.

If you provide us with another person’s contact information, you represent that you have that person’s permission to do so.

My Reward Store transmits referral contact information to the Client that sponsors the applicable program. The Client — not My Reward Store — determines whether and how to contact the referred individual, and the Client’s privacy policy and communication practices govern that contact. My Reward Store does not send marketing communications to referred individuals, does not sell referral contact information, and does not use referral contact information for its own purposes.

My Reward Store retains referral contact information solely to report referral activity and credit referral rewards to the referring member. Referral contact information for an individual who does not enroll in the applicable program is deleted or de-identified within twenty-four (24) months of collection, unless a longer period is required by law.

Referred individuals located in Canada: any commercial electronic message sent as a result of a referral is sent by the Client and is subject to Canada’s Anti-Spam Legislation, including the requirement that the message identify the individual who made the referral.

4. Sensitive Personal Information

My Reward Store does not knowingly collect sensitive personal information through the Services. My Reward Store does not use or disclose sensitive personal information for any purpose other than performing the Services requested by the applicable Client, as permitted under applicable law.

Users should not submit health information, biometric information, Social Security numbers, government-issued identification numbers, precise geolocation information, financial account credentials, information concerning racial or ethnic origin, religious beliefs, sexual orientation, immigration status, the contents of private communications, or other sensitive personal information through the Services. If sensitive personal information is submitted to us without having been requested through an authorized feature of the Services, we will take reasonable steps to delete it.

Payment card information is collected and processed by Stripe or another authorized payment processor and is not stored by My Reward Store as a complete payment card number.

5. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, tags, local storage, web beacons, and similar technologies to authenticate users; maintain user sessions; remember settings and preferences; operate shopping carts and redemption features; provide security and prevent fraud; understand how the Services are used; measure performance; diagnose technical issues; and improve the Services.

Categories of cookies. We use (a) strictly necessary cookies, which are required to operate, secure, and authenticate the Services; (b) functional cookies, which remember preferences; (c) analytics cookies, which help us understand how the Services are used; and (d) performance cookies. We do not use advertising or cross-context behavioral advertising cookies. A detailed cookie table listing each cookie, its purpose, its provider, and its duration is available in our Cookie Policy at myrewardstore.com/cookie-policy.

Your choices. Non-essential cookies are not set until you provide consent. Our cookie banner allows you to accept all non-essential cookies, reject all non-essential cookies, or select individual categories — and rejecting is as easy as accepting. You may change your cookie settings at any time through the “Preferences” control available on the Services. Users in Québec and in jurisdictions with comparable requirements will find non-essential cookies deactivated by default.

Global Privacy Control. We recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), transmitted by a user’s browser or device, and treat such a signal as a valid opt-out request for the browser or device from which it is sent.

Disabling certain cookies may affect authentication, account access, shopping cart functionality, personalization, or other features of the Services. Cookies that are strictly necessary to operate, secure, or authenticate the Services are not subject to optional cookie controls.

6. How We Use Personal Information

We use personal information only to perform the Services on behalf of the applicable Client, and for the limited independent purposes described in Section 1. Specifically, we may use personal information to:

  • provide, operate, maintain, and support the Services;
  • create and administer user accounts;
  • verify user identity, eligibility, and program participation;
  • connect users to Client-sponsored programs;
  • display points, awards, rewards, benefits, offers, and deals;
  • administer rewards, incentive, loyalty, recognition, referral, or promotional programs;
  • process purchases, redemptions, returns, refunds, and cancellations;
  • arrange product, gift card, reward, or benefit fulfillment;
  • provide order confirmations, delivery updates, and other transactional communications;
  • send information about rewards, points, awards, redemption opportunities, offers, and deals available through the applicable program, at the direction of the applicable Client
  • respond to questions, complaints, and customer service requests;
  • maintain, secure, and improve the Services provided to the applicable Client, consistent with the restrictions applicable to a service provider or processor;
  • personalize the user experience within the applicable Client program;
  • select and personalize the rewards, offers, and promotions displayed to you within the applicable Client program, including on the basis of demographic information, at the Client's direction;
  • monitor performance and usage;
  • secure accounts and systems;
  • detect and prevent fraud, abuse, unauthorized access, and other prohibited activity;
  • maintain business and transaction records;
  • enforce our Terms and Conditions and other agreements;
  • comply with contractual and legal obligations; and
  • protect the rights, safety, property, and security of users, Clients, My Reward Store, and others.

De-identified information. We may de-identify or aggregate information so that it cannot reasonably be used to infer information about, or otherwise be linked to, an identifiable individual. Where we maintain de-identified information, we (a) take reasonable measures to ensure the information cannot be associated with an individual or household, (b) publicly commit to maintain and use the information only in de-identified form and not to attempt to reidentify it, except as permitted by law to test our de-identification methods, and (c) contractually obligate any recipient to comply with the same restrictions. We do not use de-identified information derived from one Client’s program to benefit another Client except where expressly permitted by our agreement with the originating Client.

7. Email Communications

My Reward Store sends email on behalf of the applicable Client. We may send operational and transactional emails relating to account registration and authentication; password resets; order confirmations; completed orders; redemption confirmations; shipping or delivery updates; customer service; security notices; changes affecting the Services; and other activity involving a user’s account or transaction.

We may also send emails concerning rewards, available points, awards, redemption opportunities, benefits, promotional offers, or deals made available through the applicable Client program.

Users may opt out of promotional emails by using the unsubscribe link contained in the email or by updating available communication preferences. Opting out of promotional communications will not prevent users from receiving necessary transactional, security, account, or service-related communications.

Users in Canada: commercial electronic messages are sent in accordance with Canada’s Anti-Spam Legislation and include sender identification and an unsubscribe mechanism.

8. How We Disclose Personal Information

We disclose personal information only as necessary to perform the Services and as described below. We may disclose personal information to the following categories of recipients:

A. The Participating Client
We may disclose information to the Client sponsoring or providing the applicable program, including information relating to program eligibility; account status; points and awards; program participation; reward activity; redemption activity; transactions; referrals; customer service matters; and program performance.

The Client may use information in accordance with its own privacy policy and program terms.

B. Service Providers and Subprocessors
We may disclose information to service providers that perform functions on our behalf, including website and cloud hosting; payment processing; order processing; product and reward fulfillment; shipping and delivery; gift card fulfillment; email delivery; customer support; authentication; analytics; fraud prevention; cybersecurity; data storage; and professional and administrative services.

These providers are engaged as subprocessors, are permitted to process information only as necessary to provide their services to us, are contractually prohibited from using the information for their own purposes, and are subject to written obligations at least as protective as those in our agreement with the applicable Client.

C. Merchants, Rewards Providers, and Fulfillment Partners
We may disclose information necessary to process a reward or redemption; complete a purchase; issue a gift card or award; activate an offer; fulfill and ship an order; provide a service selected by the user; manage a return, refund, or cancellation; or resolve a customer service issue.

These parties receive only the information necessary to perform the requested transaction and are not permitted to use it for their own marketing purposes, except where you have chosen to claim a partner offer as described in Section 8.C.1 below.

C.1. Partner Offers You Choose to Claim
Some Client programs surface offers from third-party partners. If you choose to claim such an offer, you may be asked to provide information — such as your name, email address, or postal address — so that it can be shared with the partner in order to deliver the offer. Claiming a partner offer is entirely optional. No offer is claimed on your behalf, and your information is never shared with a partner unless you affirmatively choose to claim that partner’s offer.

We identify the partner by name at the point you are asked to share your information, and you must take an affirmative step to share it. We do not use pre-selected checkboxes. We do not share your telephone number with partners.

When you choose to share your information with a partner, that partner receives it as an independent business. The partner’s own privacy policy — not this Privacy Policy — governs how it uses your information, including whether it sends you marketing communications. You should review the partner’s privacy policy before claiming an offer. If you later wish to stop hearing from a partner, you will need to contact the partner directly or use the unsubscribe mechanism in its communications.

Because these disclosures are made at your direction, to a partner you have intentionally chosen to interact with, and only after your affirmative election, we do not consider them to be a “sale” or a “share” of personal information under applicable privacy laws.

D. Legal and Protective Disclosures
We may disclose information when reasonably necessary to comply with applicable law, regulation, subpoena, court order, or legal process; respond to requests from government or regulatory authorities; investigate fraud, security incidents, or unlawful activity; enforce agreements and policies; protect the rights, property, or safety of My Reward Store, our Clients, users, or others; or establish, exercise, or defend legal claims.

Where we receive a legal demand for personal information that we process on a Client’s behalf, we will, unless legally prohibited, notify the Client and direct the requesting party to the Client.

E. Business Transactions
Information that My Reward Store processes on behalf of a Client may be transferred in connection with an actual or proposed merger, acquisition, financing, sale of assets, reorganization, or bankruptcy only to the extent permitted by our agreement with the applicable Client and by applicable law. Any recipient will be bound by obligations no less protective than those in this Privacy Policy and in the applicable Client agreement.

9. Sale, Sharing, and Targeted Advertising

My Reward Store does not sell personal information. My Reward Store does not share personal information for cross-context behavioral advertising, and does not disclose personal information to advertising networks, ad exchanges, data brokers, or social media platforms for advertising purposes. My Reward Store does not process personal information for profiling in furtherance of decisions that produce legal or similarly significant effects. We have not sold or shared personal information in the preceding twelve (12) months.

Partner offers. If you affirmatively choose to claim an offer from a third-party partner, your information is shared with that partner at your direction, as described in Section 8.C.1. We do not consider a disclosure made at your direction, to a partner you have intentionally chosen to interact with, to be a sale or a share under applicable privacy laws.

At the direction of the Client sponsoring your program, we may use information collected through the Services — including demographic information such as age range, gender, or general geographic area — to select which rewards, offers, and promotions are displayed to you within that program. This is first-party advertising based solely on your activity within, and relationship to, the applicable Client program. It does not rely on information collected about you across other businesses’ websites or applications, is not disclosed to third-party advertisers, and is not combined with information from other Clients’ programs. We do not consider this to be a sale, a share, or cross-context behavioral advertising under applicable law.

Because we do not sell or share personal information, no opt-out is required. We nonetheless recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), and we maintain a “Do Not Sell or Share My Information” control on the Services for users who wish to record a preference.

Disclosures to service providers and to the Client sponsoring a user’s program, as described in Section 8, are made under written contracts that restrict the recipient’s use of the information to the purposes of performing the Services. We do not consider such disclosures to be a sale or a share under applicable privacy laws.

10. User Privacy Rights

How requests are handled. Because My Reward Store generally acts as a service provider or processor, we act on privacy requests at the direction of the applicable Client. If you submit a request to us directly, we will either (a) fulfill it on the Client’s behalf where the Client has instructed us to do so, or (b) promptly forward your request to the Client and inform you that we have done so. Depending on where a user resides and subject to applicable law, the user may have the right to:

  • request confirmation of whether we process personal information about the user;
  • request access to, and a copy of, personal information;
  • request correction of inaccurate personal information;
  • request deletion of personal information;
  • withdraw consent where processing is based on consent;
  • opt out of certain uses or disclosures of personal information;
  • opt out of promotional communications;
  • manage cookie preferences;
  • request information regarding categories of personal information collected, used, or disclosed, and categories of recipients;
  • request portability of personal information where applicable; and
  • appeal a decision concerning a privacy request where required by law.

Response timelines. We (or the applicable Client) will confirm receipt of a request within ten (10) business days and respond substantively within forty-five (45) days. Where reasonably necessary, we may extend this period by an additional forty-five (45) days and will notify you of the extension and the reason for it.

Appeals. If a privacy request is denied in whole or in part, you may appeal by replying to our response or by emailing compliance@myrewardstore.com with the subject line “Privacy Request Appeal.” We will respond to an appeal in writing within forty-five (45) days, stating the reasons for our decision. If your appeal is denied, we will provide you with a method to contact your state Attorney General or applicable supervisory authority to submit a complaint.

Available privacy tools may include: Request My Data; Remove My Data; Do Not Sell or Share My Information; cookie preference controls; account communication settings; and email unsubscribe links.

Users may also submit a request by contacting compliance@myrewardstore.com.

We may take reasonable steps to verify a requester’s identity and authority before completing a request. Authorized agents may submit requests where permitted by applicable law. We may require proof that the agent is authorized to act for the user and may separately verify the user’s identity.

We will not unlawfully discriminate against a user for exercising applicable privacy rights.

11. Removal of Personal Information

When a verified user submits a valid “Remove My Data” request, My Reward Store will delete the user’s personal information from our active records, subject to permitted exceptions and to the instructions of the applicable Client.

We may retain limited information when reasonably necessary to complete a transaction requested by the user; process or document an order, redemption, refund, cancellation, or return; satisfy legal, tax, accounting, audit, or reporting obligations; maintain records of privacy requests and our response; preserve an email address or other limited information on a suppression list to honor an opt-out request; detect, investigate, or prevent fraud, abuse, security incidents, or unlawful activity; resolve disputes; enforce agreements; establish, exercise, or defend legal claims; or comply with another purpose permitted or required by applicable law.

Deletion from My Reward Store’s records may not automatically delete information independently maintained by the participating Client, Stripe, a merchant, a fulfillment provider, or another third party. Users may need to contact those parties regarding information maintained in their separate systems.

Deletion may result in the loss of account access, points, rewards, awards, transaction history, redemption eligibility, or other program benefits, depending on the applicable Client program.

12. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services; administer the applicable Client program; maintain an active account; complete transactions and redemptions; provide support; comply with legal, contractual, accounting, tax, and reporting requirements; prevent fraud and protect security; resolve disputes; and enforce agreements.

Illustrative retention periods. Unless a Client instructs otherwise or a longer period is required by law: account and program records are retained for the duration of program participation and for twenty-four (24) months thereafter; transaction and redemption records are retained for seven (7) years for tax, accounting, and audit purposes; referral contact information for individuals who do not enroll is retained for no more than twenty-four (24) months (see Section 3.G); device and usage logs are retained for thirteen (13) months; and suppression-list entries are retained indefinitely in order to honor an opt-out.

When information is no longer reasonably necessary, we may delete, de-identify, or securely dispose of it.

13. Data Security

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against accidental or unlawful loss, destruction, alteration, unauthorized disclosure, or access. These safeguards may include access controls, authentication measures, system monitoring, encryption where appropriate, vendor management, employee confidentiality obligations, and security policies.

No system, transmission method, or storage environment can be guaranteed to be completely secure. Users are responsible for maintaining the confidentiality of their account credentials and for notifying us of suspected unauthorized access.

In the event of a security incident affecting personal information, we will notify the applicable Client without undue delay and will cooperate with the Client in providing any notice required by law.

14. Third-Party Services and Links

The Services may contain links to or integrations with Client websites, merchants, Stripe, fulfillment providers, rewards providers, and other third-party services. Those third parties operate under their own terms and privacy policies. My Reward Store is not responsible for the privacy, security, or information-handling practices of third-party services that are not controlled by My Reward Store.

15. Children’s Privacy

The Services are intended only for individuals who are at least 18 years old. We do not knowingly collect personal information from individuals under 18. If we learn that we collected personal information from an individual under 18, we will take reasonable steps to delete it. A parent or legal guardian who believes that an individual under 18 has provided personal information through the Services may contact us at compliance@myrewardstore.com.

16. United States and Canada

The Services are intended for eligible users located in the United States and Canada.

My Reward Store is based in the United States. Information collected from Canadian users may be transferred to, stored in, or processed in the United States or another jurisdiction where My Reward Store or its service providers operate.

Privacy and data protection laws in those jurisdictions may differ from the laws of the user’s province or country. Personal information stored or processed in another jurisdiction may be accessible to courts, law enforcement, or government authorities in that jurisdiction as permitted by applicable law.

Québec — Law 25

Privacy Officer. The person responsible for the protection of personal information at My Reward Store is:

Paul Linehan, Privacy Officer
My Reward Store — Solution One Partners, Inc.
11340 W. Bell Rd., Suite A110, Surprise, AZ 85378
compliance@myrewardstore.com

Privacy Impact Assessment. Before communicating personal information concerning a Québec resident outside the province, My Reward Store conducts a privacy impact assessment evaluating the sensitivity of the information, the purposes for which it is to be used, the protection measures applied, and the legal framework of the receiving jurisdiction, and ensures that the information will receive adequate protection. Personal information is communicated outside Québec only where that assessment demonstrates adequate protection and where a written agreement with the recipient imposes appropriate safeguards.

Automated decision-making. My Reward Store does not use personal information to render a decision based exclusively on automated processing. Eligibility and program decisions are made by the applicable Client. If this changes, we will inform affected users at or before the time of the decision and provide the right to submit observations to a person able to review the decision.

Additional rights. Québec residents may request access to, correction of, and portability of their personal information in a structured, commonly used technological format, and may request that the dissemination of their personal information cease or that a hyperlink be de-indexed where permitted by law. Requests may be directed to the Privacy Officer above.

Canada — PIPEDA
My Reward Store is accountable for personal information under its control. The Privacy Officer identified above is responsible for our compliance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act and substantially similar provincial legislation. Complaints that are not resolved to a user’s satisfaction may be directed to the Office of the Privacy Commissioner of Canada or to the applicable provincial commissioner.

17. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our Services; Client programs; our information practices; available privacy controls; technology; legal requirements; or business operations.

When we update this Privacy Policy, we will revise the “Last Updated” date at the top. We may provide additional notice when required by law or when changes are material.

Continued use of the Services after an updated Privacy Policy becomes effective constitutes acknowledgment of the updated policy, to the extent permitted by applicable law.

18. Contact Us

Questions, concerns, complaints, and privacy requests may be submitted to:

Solution One Partners, Inc.
My Reward Store
Attn: Paul Linehan, Privacy Officer
11340 W. Bell Rd., Suite A110
Surprise, AZ 85378
Email: compliance@myrewardstore.com