Effective Date / Last Updated: January 26, 2022

1. Introduction

Your privacy is important to us. We are Xceleration Partners, LLC (“Xceleration” or “we” or “us”). We post this privacy statement (the “Privacy Statement”) so that you are aware of the personal information we collect, how it is handled and with whom it is shared.

This Privacy Statement relates to the following websites:  www.xceleration.com, and www.rewardstation.com (together, the “Xceleration Websites”), and services provided through Xceleration Websites or Xceleration-Powered Websites (collectively the “Xceleration Services” or “Services”).  An “Xceleration-Powered Website” means a website not owned by Xceleration, but which has a license from Xceleration to utilize certain Xceleration technologies. A “User” means any individual who has access through the use of a password to an Xceleration Website or Xceleration-Powered Website, including buyers of Xceleration Services, participants of programs provided through an Xceleration Website or Xceleration-Powered Website, and employees and agents of corporate clients and Suppliers.

Your Use of the Website or Services Implies Your Consent

Your use of Xceleration Websites or Services signifies your acceptance of our collection and use of your personal information in accordance with this Privacy Statement.  If you do not agree or are not comfortable with any policy described in this Privacy Statement, your remedies are to discontinue your use of the relevant website or to follow instructions described elsewhere in this Privacy Statement.

Changes in this Privacy Statement    

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy or use of your personal information, we will notify you within this Privacy Statement and by means of notification on our home page, your program website, another appropriate place or by email. We may also notify you by posting the updated policy on our Websites and revising the “Effective Date” above. Please remember to check back every so often for updates.

Testimonials

We may post customer testimonials on our web sites, which may contain personal information such as the customer’s name.  We obtain the customer’s consent prior to posting such testimonial.

Security of Data

The security of your personal information is important to us.  When you enter information (such as credit card or social security numbers) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, go to http://en.wikipedia.org/wiki/Secure_Sockets_Layer). When we store your information in databases or in flat files, we utilize encryption technologies designed to ensure data protection that is consistent with accepted industry standards.

The security of your personal information is important to us.  When you enter information (such as credit card or social security numbers) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). (To learn more about SSL, go to http://en.wikipedia.org/wiki/Secure_Sockets_Layer). When we store your information in databases or in flat files, we utilize encryption technologies designed to ensure data protection that is consistent with accepted industry standards.

The safety and security of your personal information, however, also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Laws and Regulations

This Privacy Statement has been reviewed by legal counsel in conjunction with applicable laws and regulations, and we will use commercially reasonable efforts to monitor and update this Privacy Statement as necessary for legal compliance purposes.  With regard to any personal information we collect from citizens of the European Union, we agree to comply with the EU’s General Data Protection Regulation (GDPR).

Retention Policy

We will retain personal information only as long as necessary to fulfill the purposes set forth in this Privacy Statement, or for a period specifically required by law or regulation and thereafter will be disposed of securely or made anonymous so that it cannot be identified to any individual.

Xceleration’s specific retention policy is set at three years.  After three years, all data that is not currently in use as part of an active program will be destroyed.

Privacy Incident and Breach Management

We have implemented a formal privacy incident and breach management program, which specifies the following: (a) Incidents and breaches are reported to a member of our breach team.; (b) The manager or employee responsible for privacy issues and security has the overall accountability and is supported by the privacy and security steering committee(s) .; (c) We have a privacy breach notification policy in order to deliver notices in a timely and legal fashion.; (d) Our program includes a clear escalation path.; and (e) Our program sets forth a process for contacting law enforcement, regulatory, or other authorities when necessary.

If you feel there has been an incident or breach please contact Xceleration at 678-680-7363 or email us at info@xceleration.com (put “Privacy Compliance” in subject line).

Changes Related to Privacy

We have ongoing processes in place to monitor, assess, and address the effect on privacy requirements from various changes, including but not necessarily limited to changes related to legal and regulatory environments, industry standards, contracts with third parties, business operations and processes, people assigned responsibility for privacy and security matters, and technology.

Categories of Who Is Covered in this Privacy Statement

  • If you are a visitor to the portions of Xceleration Websites or an Xceleration-Powered Website that can be accessed without a password (our “Public Website”), please see the section “Public Website Privacy Statement” with respect to data about you. We refer to you as a “Public Website Visitor”
  • If you are a User, please see the section “User Privacy Statement” below for information on our data processing practices with respect to data about you.

 

What Is Not Covered in this Privacy Statement

We cover only our data processing practices described in this Privacy Statement. Without limitation, this Privacy Statement does not cover data that we collect offline, on businesses or legal entities or on our employees.

Xceleration is not responsible for any practices employed by websites linked to or from our website or their information or content. Please remember that when you use a link to go from our Websites to another website, this Privacy Statement is no longer in effect. Your browsing and interaction on any other website is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Children’s Privacy

The Children’s Online Privacy Protection Act was created to protect children under the age of 13 from unsuspecting acts or practices in conjunction with collecting, using, and disclosing any information about them. Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 13, please contact us so that we can delete the child’s information. The Services will never knowingly accept, collect, maintain or use any information from a child under the age of 13. If a child whom we know to be under the age of 13 sends personal information to us online, we will only use that information to respond directly to that child or notify parents.

“Do Not Track” Disclosures

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser over time and across third party websites as it relates to targeted advertising. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests we might receive from you or your browser.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@xceleration.com

How You Can Contact Us

If you have questions or concerns regarding this Privacy Statement, you should first contact us by email at info@xceleration.com (put “Privacy Compliance” in subject line).  You can also write to us at Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA. Xceleration will respond to personal information change requests within 30 days of receiving such requests.

2. Overview of Xceleration Services

2.1 Suppliers of Services to Corporate Clients

Xceleration provides access to its applications via Xceleration Websites and Xceleration-Powered Websites to suppliers of services to corporate clients (“Suppliers”). These Suppliers include travel and event reservation services, and merchandise fulfillment suppliers.  Xceleration may share certain of your information, including personal information, with such Suppliers. For instance, Xceleration may share certain delivery information in order to make sure certain rewards we have offered arrive at your correct address. Any such Suppliers or other service providers are required by contract to implement privacy and security safeguards in respect of your personal information that are consistent with this policy.

2.2 Buyers of Services

Individuals and companies (“Buyers”) use Xceleration’s technology via Xceleration Websites or Xceleration-Powered Websites to design and manage incentive, recognition and reward programs.

2.23 Participants of Programs Purchased by Buyers

Participants (generally corporate client employees or stakeholders) use Xceleration Services when invited or registered by a corporate client to participate in a program or Services being provided to a corporate client. They do so by viewing an Xceleration-Powered Website that contains incentive, recognition and/or reward programs created by the corporate client. By accessing Xceleration Services, the Participant provides information required for participation in reward activities and programs.

3. Public Website Privacy Statement

This section describes how Xceleration uses and disseminates information collected about Public Website Visitors through our Public Website; it does not cover any other data processing activities.

We Won’t Collect Any Information about Public Website Visitors.

We use cookies and various traffic tracking technologies to monitor the use of our Public Websites. We collect such data related to Internet Protocol (“IP”) addresses, browser type, and cookies, but do not link it to any personally identifiable information (such as names and email addresses) that you may submit to us through other means.

Use of Cookies.

A “cookie” is a small text file containing information that a web browser transfers to your computer’s hard disk for record-keeping purposes. On the Public Websites, we may use cookies to analyze our site traffic patterns, but, except as described above, we link cookies only to IP addresses and not any personally identifiable information about Public Website Visitors.

 

 4. User Privacy Statement

4.1 Buyers of Services for Corporate Clients

If you are a User acting as a Buyer of Services, the following terms are applicable to you:

4.1.1 General Information

  • We may use your personal information for the purposes of (a) providing Xceleration Services or to provide you information you request about your account or our products or services; (b) facilitating communications between you and third parties; (c) our marketing activities; (d) all credit and other financial checks in relation to any payments made by you for Xceleration Services; (e) carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection; and (f) fulfilling any other purpose for which you provide your personal information or any other purpose with your consent.
  • Xceleration does not resell or transfer your e-mail addresses or any other personal information to third parties without your explicit permission or as allowed by law. The following are some examples of when Xceleration may share your personal information: (a) to our advisors, contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; (b) to comply with any court order, law or legal process, including to respond to any government or regulatory request; (c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Xceleration, our employees and customers or others; and (d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Xceleration’s assets or equity interests, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Xceleration about our users is among the assets transferred.

 

  • You have a right to access personal information about you that Xceleration holds. You have the right to correct, amend, or delete that information when it is inaccurate (except when the burden or expense of providing access would be disproportionate to the risks to your privacy, or when the rights of other persons would be violated). It is your responsibility to update personal information as necessary.
  • Registering to use Xceleration Services requires you to give us some contact information (like your name, phone number, street and e-mail address).  We will use this contact information to send you information about our systems and Xceleration. Your contact information is also used to contact you when necessary (for example, following up on a request from you for technical support).
  • You can update your records in the Xceleration system by accessing the user information administration feature in the system or by sending an email to info@Xceleration.com (put “Update Records” in the subject line). You can also write to us at Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA.

 

4.1.2 Communications

You may choose to receive special offers and other messages from Xceleration or its partners.  You may, however, also choose to cease receiving such messages by updating your profile or sending an e-mail to info@Xceleration.com (put “Privacy Compliance” in subject line) to change information previously provided, remove your information from our database, cancel any future communications or to cancel our service. You can also write to us at Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA.

4.2 Participants of Programs Hosted by Corporate Clients

If you are a participant using Xceleration Services to register for a program hosted by a corporate client, the following terms are applicable to you:

4.2.1 General Information

  • Your personal information and other pertinent information will be collected when you register for a program on an Xceleration-Powered Website. Any information that you provide will be stored on a system managed or controlled by Xceleration or a trusted partner on Xceleration’s behalf.
  • The information you provide is the property of the corporate clients to whom you have provided the information.
  • All such personal information is completely accessible to the respective corporate client and its agents.  Each Xceleration corporate client has its own privacy statement.  By providing your personal information to Xceleration for use by a corporate client or a Supplier (e.g. to make reservations with a particular hotel, or order an award to be shipped to your home address) you consent to Xceleration providing a copy of your personal information to that corporate client or Supplier for collection, processing and any further transfer in accordance with the privacy statement (if any) of that corporate client or Supplier.  Xceleration in not responsible for any actions of corporate clients or Suppliers; however, Suppliers are required by contract to implement privacy and security safeguards consistent with this policy.

 

4.2.2 Communications

Xceleration corporate clients may use various methods for allowing you to choose to receive or cease receiving messages, depending upon the individual corporate client’s needs and the requirements for each specific program. Corporate clients may include in their registration web site a question about not receiving messages, use an unsubscribe email reply option, or use other means in which removal from the invitee or participant list is an option.  Xceleration does not sell or distribute data to any third party (other than to the applicable corporate clients and Suppliers) except as authorized under this policy.

 

5. EU and Switzerland Privacy Statement

5.1 Notice

Xceleration collects personal information from and about individuals via Xceleration Websites and Xceleration-Powered Websites for the purposes of (a) providing Xceleration Services; (b) facilitating communications between you and third parties; (c) our marketing activities; and (d) all credit and other financial checks in relation to any payments made by them for Xceleration Services.

Any complaints or questions should be first sent to us by email at info@Xceleration.com (put “Privacy Compliance” in subject line).  Users can also write to us at Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA. Xceleration will respond to personal information change requests within 30 days of receiving such requests.

When Xceleration receives personal information from the EU or Switzerland merely for processing purposes in the United States and does not control the collection of the personal information, Xceleration may not provide notification of this EU and Switzerland Privacy Statement to the Users to which such personal information relates. In such event, Xceleration reserves the right to process personal information in the course of providing Xceleration Services to Buyers, Suppliers or other of its clients or otherwise for Xceleration’s operation of its business without the knowledge of the Users involved.

5.2 Choice

Except as provided below, Xceleration gives Users from whom it collects personal information the opportunity to choose not to allow Xceleration to disclose his or her personal information to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected (the “opt-out” rights). For Sensitive personal information, Xceleration requires such User to affirmatively choose to allow for the data is to be disclosed to a third party or used for a purpose other than its original purpose (the “opt-in” choice).

Users desiring to exercise their opt-out rights should first contact us by email at info@Xceleration.com (put “Privacy Compliance” in subject line). Users can also write to us at Attention: Privacy Officer, Xceleration Partners, LLC, 5901-A Peachtree Dunwoody Rd, Suite 200, Atlanta, GA 30328, USA.

When Xceleration receives personal information merely for processing purposes in the United States and does not control the collection of the personal information, Xceleration may not provide such choices to the Users to whom such personal information relates.

5.3 Accountability for Onward Transfer to Third Parties

Xceleration may disclose personal information to a third party if (a) Xceleration has received the applicable User’s permission to make the disclosure, (b) the disclosure is required in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or (c) allowed by a law that creates conflicting obligations for Xceleration or that explicitly authorizes disclosure (except that we will limit such disclosure to the extent necessary). otherwise permitted by law.

5.4 Data Integrity and Purpose Limitation

Xceleration takes reasonable steps to ensure that personal information is reliable, accurate, complete, current and relevant for the purposes for which it was collected.

5.5 Access

Xceleration acknowledges that EU and Swiss individuals have the right to access the personal data that we maintain about them.  Consistent with any applicable client commitments, Xceleration will permit Users upon their request to access their personal information and correct any erroneous information. The User may need to provide sufficient identifying information, such as name, address, birth date, and social security or national health insurance or an equivalent number. Such access may be denied or limited by Xceleration if providing such access is unreasonably burdensome, expensive under the circumstances, or if in giving such access would violate another person’s rights. In some circumstances, Xceleration may charge a reasonable fee for access to personal information. Users can contact the Xceleration customer services team at support@rewardstation.com to request access to change or delete personal information.

6. RIGHTS OF EU RESIDENTS UNDER GDPR

This Section 6 only applies to users of our Websites who are residents of the European Union.

6.1 Whenever we collect personal information from you, we may do so on the following legal bases:

  1. Your consent to such collection and use;
  2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our solutions;
  3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using personal information is necessary for: (i) intra-organization transfers for client data for administrative purposes; (ii) product development and enhancement, where the processing enables us to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our users, and to better understand how people interact with our Website; (iii) communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising; (iv) fraud detection and prevention; (v) enhancement of our cybersecurity, including improving the security of our network and information systems; and; (vi) general business operations and diligence.

In each circumstance, however, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

6.2  We may retain your personal information for a period of time consistent with the original purpose for collection.  For example, we keep your personal information for no longer than reasonably necessary for your use of our products and services and for a reasonable period of time afterward. We also may retain your personal information during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

6.3  Residents of the European Union have the following rights under GDPR:

  1. The right to be informed. You are entitled to be informed of the use of your personal information. This Privacy Policy provides such information to you.
  2. The right of access. You have the right to request a copy of your personal information which we hold about you.
  3. The right of correction: You have the right to request correction or changes of your personal information if it is found to be inaccurate or out of date.
  4. The right to be forgotten: You have the right to request us, at any time, to delete your personal information from our servers and to erase your personal information when it is no longer necessary for us to retain such data. Note, however, that deletion of your personal information will likely impact your ability to use our services.
  5. The right to object (opt-out): You have the right to opt-out of certain uses of your personal information, such as direct marketing, at any time.
  6. The right to data portability: You have the right to a “portable” copy of your personal information that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your personal information stored on our servers / IT environment to another service provider’s servers / IT environment.
  7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
  8. The right to lodge a complaint with a supervisory authority.