1. Importance of your Privacy

At Cloud Wing Technologies Inc., (CWT), your privacy is of great importance to us. We understand that you entrust us with certain personal information in order for CWT to administer the rewards and/or loyalty programs of our clients/merchants (‘CWT Services’). This Privacy Policy applies to the CWT Website, the CWT’s product FAIRLOY Web app, mobile app or a merchant-branded version of the app, as well as CWT in-store tablets (referred to collectively as ‘CWT Applications’).

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE SUBMITTING ANY INFORMATION TO CWT OR THROUGH ANY CWT APPLICATION. BY VOLUNTARILY PROVIDING ANY INFORMATION TO CWT AND USING OUR APPLICATIONS, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND UNDERSTOOD THIS POLICY AND THAT YOU CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF THIS INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE US WITH ANY INFORMATION, AND SIMPLY EXIT THIS PAGE AND/OR THE CWT APPLICATION WITHOUT ACCESSING OR USING ANY OF OUR SERVICES.

2. Who We Are and Getting in Touch

CWT is located at 470 Sentinel Rd, Toronto, ON, M3J1V6, CANADA. CWT welcomes your comments regarding this Privacy Policy. Any questions or inquiries relating to privacy or data protection should be directed to our Privacy Officer at hr@cloudwingtechno.com

3. What Personal Information does CWT Collect about Me?

‘Personal information’ is any information about an identifiable individual. CWT collects personal information provided to us using fair and lawful means, and for the following specific purposes:

• To log in to CWT on our FAIRLOY Website or app, you must select a username and password. However, the password you select is stored hashed such that it remains unknown even to CWT, and if using social sign in, none of your Facebook profile information is collected by CWT;
• To register for CWT, you will be asked to provide your name, mobile phone number, e-mail address, address, gender, birthday and any specific information requested by CWT merchants such as the products or services you may be interested in. Merchants decide what data fields are mandatory and optional for participating in their loyalty programs;
• To respond to and learn from our users: Any information you voluntarily provide is also collected by CWT, such as if you provide personal information using the ‘Contact Us’ page on CWT’s Website or if you choose to complete a CWT or merchant survey through our Applications;

In addition, when you use CWT’s FAIRLOY Website or app, we automatically receive and record information on our server logs from your browser or mobile platform, including your IP address, unique device identifier, and other device information (such as your operating system version and mobile network provider). CWT also automatically collects and uses additional information from users such as location, purchase activity, Application open date and time, idle time, and all clicks and/or swipes within the Application (together with time and order). We collect such information to assess user experience and improve our Applications. CWT may also collect information posted by users on social media sites for users that have opted to connect to or otherwise link CWT with social media accounts, including Facebook and Twitter.

4. How is My Personal Information Used?

CWT uses personal information responsibly in order to ensure we are meeting your expectations of CWT Services. For example, we use personal information to:

• Administer loyalty/rewards programs on behalf of merchants we have a business relationship with;
• Engage in proximity marketing using geofencing technology on behalf of our merchants;
• Give FAIRLOY and its merchants a clear picture of its users’ purchasing activities;
• Provide FAIRLOY users with merchant benefits;
• Contact you from time to time as requested by merchants; to provide critical information about service updates, technical issues or other information important to know regarding FAIRLOY Services; or to provide support and answer any questions you may have;
• Customize, measure and improve our services and content;
• Analyze our user database to review preferences and trends for statistical and analytical purposes, marketing initiatives and for operations and development;
• Enforce this Privacy Policy and CWT’s Terms of Use.

Note that automated data collection does not lead to profiling that significantly affects FAIRLOY users, but is simply used to give CWT a clear picture of its users and to provide special offers to FAIRLOY users.

5. Who is My Personal Information Shared With?

CWT only shares personal information as authorized by you or as follows:

• With the merchant who has entered into a business relationship with CWT to provide you with their own rewards/loyalty program and other incentives;
• With service providers who directly or indirectly assist us in providing CWT Services to you. In working with our service providers, your personal information may be transferred to a foreign jurisdiction to be processed or stored. Such information may be provided to law enforcement or national security authorities of that jurisdiction upon request, in order to comply with foreign laws; and
• In response to a subpoena, regulatory investigation or court order, or your personal information may be shared with law enforcement authorities who have demonstrated their lawful authority.

CWT does not sell personal information to third parties for marketing or any other commercial purposes other than in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, CWT users will be notified before any such business transaction occurs, and be given the opportunity to deactivate or terminate their account should they so choose to. The acquiring company will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

6. How is My Personal Information Kept Secure?

CWT has implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful processing of the data we collect. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by CWT significantly reduce the likelihood of a data security breach.

In addition, we recommend that you do your part in protecting yourself from unauthorized access to your CWT account by ensuring no one else uses your computer or device when you are logged in, by logging off when CWT Services are not in use and by keeping your password confidential. CWT is not liable for any unauthorized use of your personal information that is beyond our reasonable control.

Here are some examples of the data security controls in place at CWT (this is not an exhaustive list):

• The use of encryption when personal information is transferred to and stored on CWT’s servers. Transmission between your browser and our web server is implemented using Secure Sockets Layer (SSL) technology;
• Limited access to personal information by CWT staff on a need-to-know basis, and the use of robust authentication processes (e.g. complex passwords are required);
• The use of data centers with effective physical and logical data security controls, and the use of reputable third parties who have demonstrated security consciousness; and

No method of transmitting or storing data is 100% secure. As a result, although we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us. If you have reason to believe that your FAIRLOY account is no longer secure (for example, if you feel that the security of your account has been compromised), you must immediately notify us of the problem at hr@cloudwingtechno.com in order for CWT to resolve the issue in a timely manner. Also keep in mind that e-mail is not a secure form of communication so never send sensitive personal information to us via e-mail. Examples of sensitive information include social insurance numbers or credit card numbers

7. Not for Children under Thirteen

CWT Services are neither designed nor intended to collect personal information from children who are under the age of thirteen (13).

In order to ensure compliance with the provisions of the U.S. Children's Online Privacy Protection Act and other data protection laws around the world aimed at protecting children, children under the age of thirteen (13) are not permitted to access or use CWT Applications, and children under the age of thirteen (13) should not provide any personal information to CWT. You may reside in a country where local laws fix the digital age of consent to be older than 13. You may only use CWT if you have reached this age of consent, in accordance with applicable local laws. If you do not meet the digital age of consent of your country, you must immediately cease using CWT Services.

8. Cookies and Usage Tracking

A cookie will be used here to mean a Web cookie, being a small text file stored on your computer hard drive, or a token or “mobile cookie” placed in the FAIRLOY app’s local storage, in order to tailor the environment based on your preferences, and track user behavior. This unique code identifies your device to CWT. Since cookies are only text files, they cannot run on your device, search your device for other information or transmit any information to anyone.

Most web browsers can either alert you to the use of cookies or refuse to accept cookies entirely. You should be aware that if you elect not to accept cookies, some parts of the CWT’s FAIRLOY Website may not function properly.

CWT uses the following types of cookies for the purposes set out below:

9. How long is my Personal Information Retained?

We will retain your information as long as you have a FAIRLOY account, to permit us to use it for the purposes that we have identified in this Privacy Policy. However, CWT has implemented retention schedules to avoid indefinitely storing personal information associated with an inactive account.

Personal information this is no longer required for administrative or business purposes, and that does not need to be archived by CWT, will be overwritten or scrambled such that it no longer identifies the FAIRLOY user. Keep in mind however that third parties who store data on our behalf have their own retention rules.

10. External Links and CWT Social Media

We may offer links from our Applications to the sites or apps of our service providers, affiliates or unrelated companies that may be of interest to you. CWT makes no representations as to such third parties’ practices for dealing with your personal information.

CWT’s use of social media serves as an extension of our presence on the Internet. Social media account(s) are public and are not hosted on CWT’s servers. Users who choose to interact with CWT via social media should read the terms of service and privacy policies of these third party services/platforms.

This Privacy Policy only applies to the CWT Applications and does not govern the activities of third parties. We recommend that you check the privacy policies of any apps, sites or platforms you associate with before sharing your personal information with such third parties.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time in order to better reflect our current data handling practices. Thus, we encourage you to review this Privacy Policy frequently! The “Last Updated” date at the top of this Privacy Policy indicates when changes to this policy were published and thus in force. Your continued use of our Services following the posting of any changes to this Privacy Policy means you accept such changes.