Privacy Policy

1. We care about your privacy

We care about protecting and respecting your privacy.  In order to serve you better and provide you with the best customer experience, we need to collect some personal data about you.  This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with, and how you can control the way your personal data is collected and used by us.

If you access or use our website (www.dragonrewards.com) (which we will refer to as “Site” in this Privacy Policy) or mobile application ("App"), then this Privacy Policy is deemed to be agreed by you and will apply to you. If you do not agree with this Privacy Policy, please stop using our Site or App, and do not apply for a Membership.

Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and will always give you the choice to opt-out of such uses.

2. Who are we?

Dragon Rewards App (“DRA”) that enables users to redeem Dragon Points (“Points") in return for services or vouchers (“Rewards”) from participating businesses (“Partners”). Dragon Rewards is owned and operated by Coin Dragon Limited (“CDL”, "we", "us", “our”), an affiliate company of Dragon Technology Global Pte Ltd (“DTG”).  Personal data we collect about you will be used in line with this Privacy Policy.

3. How do we collect data?

Your personal data will either be provided by you, or will be collected by us, CDL, or any affiliates of DTG or our Partners, or captured automatically. For example, we collect your personal data when you complete your App registration, when you transact with the account ("Account"), when you find our service using in-app location services, when you exchange for Rewards, when you send us emails or when you browse our Site or App.

4. What information do we collect about you?

It may be necessary for you to provide us with certain personal data in order for you to receive the benefits of Dragon Rewards, our Site or App. We will let you know when such data is essential for Membership. All other personal data is up to you to provide or not, as you prefer.

(a) Your Membership

If you are a Dragon Rewards member ("Member"), some of the personal data we may collect about you includes:

• your email address (via Google account or Apple account), telephone number;

• your Membership number (“DRA ID"), points balance, account status and activities relating to your Account;

• information about the Rewards exchange;

(b) When you visit our Site or App

We may use online tracking technology such as cookies, pixel tags, web beacons, and other similar technologies to automatically collect information about:

• your visits to our Site or App, such as your browsing history, how long you stay on our Site or App, and how often you visit;

• your location information as provided by your mobile or other devices when you interact with our Site or App, including your IP address and general geographic location; and the device that you use to browse our Site or App (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.

(c) Other information

We also collect some of your personal data whenever we communicate with you (e.g. email content, contact information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).

5. How do we use your information?

We will only use your personal data for the purposes set out below.

(a) Account administration

To help administer and maintain your Account, including:

• creating and updating your Account;

• verifying your identity;

• processing Points issuance and Reward redemptions;

• sending you updates about new features and benefits relating to DRA; and

• enabling features that allow you to personalise your Account on our Site or App, such as bookmarking your favourite Partners.

(b) Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(c) Marketing

To provide you with marketing and promotional materials ("Marketing Communications"), if you choose to receive them. Please see the section on Direct Marketing below for more information.

(d) Optimisation and improvements

We may use your personal data to understand and improve our Site, App or Dragon Rewards operations, or our Partners' or DTS/DTG’s operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Partners and our affiliate members to enhance services or products, develop new features and benefits, and amend business, marketing and strategic operations and plans.

(e) Legal and administration purposes

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

6. Who do we share your information with?

To protect your privacy, there may be very limited circumstances where we will share anonymised (non-identifiable to individuals) data with third parties who may or may not be located overseas, as detailed in this section. By using our Site or App, or applying for a Membership, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.

(a) Service providers

Your personal data may be shared with our or any DTS/DTG service providers (including technology providers and contractors) who process personal data on our behalf to help us administer and operate DRA, our Site and our App, to conduct data analytics, to help aggregate and anonymise the personal data, or to carry out any of the purposes set out above. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, data management and analytics service providers, and customer contact services.

We only use trustworthy service providers, who are under an obligation to only use your personal data in accordance with this Privacy Policy.

(b) Professional advisors and assignees

When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.

(c) Government and regulatory authorities

This Privacy Policy is governed by the laws of the Republic of Singapore ("Singapore"). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy, shall be subject to the exclusive jurisdiction of the courts of Singapore.

7. Aggregated and anonymised data

Aggregated or anonymised data that does not include any personally identifiable information, may be used by us, our Partners, DTS/DTG or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services, or for the purposes of industry benchmarking, machine learning, research or analytics.

8. Direct Marketing

If you have opted to receive offers and promotions from us, we may use your personal data to:

• send you direct marketing communications in connection with the latest news, events, updates, offers, contests and promotions in relation to Dragon Rewards;

• send you direct marketing communications in connection with the latest news, events, updates, contests, promotions, offers, products, services and Rewards offered by our Partners which relate to retail, clothing, accessories, cosmetics, beauty, healthcare and wellness, personal care, toiletries and medical, baby care, maternity care, insurance, financial, music, sports, lucky draws and contests, food, beverages, dining, travel, transportation, banking, electronics, home, household, textiles, telecommunications, groceries, office and business supplies, technology, outdoor furniture and accessories, furniture, lighting, décor, home accessories, media, e-commerce platforms and facilitators, and publications;

• analyse your preferences, online behaviour and transactional history in order to gain insights, so that we can customise the content and types of news, events, updates, contests, promotions, offers, products, services and Rewards that we present to you via our Site, our App, our direct marketing communications, social media or other communication means; and

• in conjunction with any seasonal events, lucky draws and contests or other promotional activities.

We may send you direct marketing communications and market research invitations by email, through your online Membership user account or in-app notifications on your mobile device, when you access the Site or App, or through online banner advertisements, post, telephone or SMS.

Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time not to receive any direct marketing communications from us. Please see the section on Your rights below.

9. Can our Partners or affiliates send you marketing materials?

No. We will not provide your personal data to our Partners or DTS/DTG for them to send you marketing materials.

10. How do we keep your information secure?

We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All transactions under the terms and conditions of this Privacy Policy are based on the encryption of data exchanged between you and us on our secure Site and App.

11. How long do we keep your data for?

We will keep your personal data only for so long as is necessary to fulfil the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it on our servers.

12. Your rights

(a) Access and correction

You have the right to access and correct your personal data held by us, at any time, by sending an email to our Data Protection Officer at privacy@dragonrewards.io

In order to ensure that your personal data is kept as accurate as possible, please notify us at the email address above of any changes to your personal data.

(b) Opt-out of direct marketing

At any time, you can ask us to stop using your personal data to send you direct Marketing Communications, or you can customise how you would like to receive direct Marketing Communications from us. You can exercise your rights to do this by:

• changing your settings on your online Membership user account or in the Site; or

• following the unsubscribe instructions in the Marketing Communications we send to you.

We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your Account, and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.

13. Online tracking technology

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.

We use cookies and other similar identification technologies such as web beacons and pixel tags on our Site, App, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our Site or App; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our Site and App; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our Site, our App and the websites of our Partners or DTS/DTG.

You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.

14. How do we manage updates to this policy?

From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our Site.