This Privacy Policy describes how TradeHolding Ltd. (“we,” “us,” “our,” “Company”), the owner and operator of the wonderspend.com business collects, uses, shares, and protects information in connection with the Company websites, mobile applications, browser applications, and any related services that refer or link to this Privacy Policy (“Services”).

In order to fully understand our policies and practices and how they are maintained, please read and revise it carefully. By not agreeing to these policies and practices, you have the right to deny our Services. By accessing or using our Services, you agree to this Privacy Policy. This may change from time-to-time so in order to keep up to date, please revise our Privacy Policy periodically.
Collection of Information

We collect, process, and use your information when you:

Access our Services through our application(s)
Register for our Services or sign in to an existing account
Visit our website(s)
Contact us for support
Connect to our Services using third-party accounts, by email, social media, or payment account(s)
Participate in our shopping or influencer programs
Enter a sweepstakes, contest, promotion, survey, or poll

Further, we and our service providers automatically collect certain information about you through:

Interaction with our Services
Cookies and other tracking technologies
Monitoring and analyzing trends, usage, and activities

Regarding all the information that you supply to us, it will contain Personal information as well. “Personal Information” means information that can be used to identify you (whether alone or in combination). The Personal Information you may provide to us includes:

Your First and last name
Your Email address
Your Phone number
Information regarding the network and connected hardware (e.g., computer or mobile device)
The nature of the product or service purchased from one of our merchant partners
How you connect to our Services, such as your IP address, unique device identifiers, device or session IDs, and
Your Bank account information

Legal Basis for Processing

Legally we have access to all your Personal Information described in this Privacy Policy, all which is based on your consent alone. Also, we are authorized to use this Personal Information to supply you with goods or services, facilitating a continuous relationship with you and to prevent fraud. Accordingly, you have a contractual rather than a statutory obligation to provide such information. In any case you fail to provide such information, unfortunately your access to our goods and services will/might be limited.
Use of Information We Collect

Your information might be used in the following ways.
Manage Your Account

The supply of Personal Information might be used for:

Registration processing with our Services, also including e-mail address verification in order to confirm your eligibility for enrolling you into our programs
Notifying you with updates, security alerts, technical notifications and administrative messages
Account handling by providing member services like replies to your questions, comments and requests
Compliance with legal and regulatory provisions in force and with the competent judicial authorities in each geographical jurisdiction that WonderSpend operates in, also with risk assessment and fraud prevention.

Improve Our Services

Information might be processed in order to keep up with trends and monitoring usages, data management by performing statistical analyses in order to improve our Services, websites, applications, marketing efforts and the quality of products and services for our merchant partners provide for a better service to you. This information might be also used to make sure our Service content will adapt more to your interests.
Administer Contests, Sweepstakes, and Promotions

WonderSpend might send invites to you to take part in various contests, surveys, sweepstakes or promotions. Your Personal Information might be used if you are willing to participate in such contests or promotions. This is due to the determination of eligibility, that you can either enter and/or to be awarded a prize.
Sharing of Information

Your Personal Information might be shared with third parties under the following circumstances.
Providers and Business Partners

Your Personal Information will never be sold, only shared with third parties in order to keep our Services operational. Your Personal Information might be shared with our service providers when performing marketing services and/or other business operations on our behalf, but within limits, as we will regulate their access by enforcing the appropriate technical and organizational security measures in order to keep your data secure. For example, we may partner with other companies to provide you support services, fraud prevention on our Services, administer promotions, sweepstakes and surveys we may elect to run, perform analytics, maintain the accuracy of our databases, and administer your rewards or payments. As we mentioned, your Personal Information will never be sold, however we might use an incognito based system in order to pseudonymize some of your Personal Information to keep it secure so it won’t be ascribed to you without the use of other separately maintained information, or convert or combine some of your Personal Information into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. This pseudonymize data might be disclosed without any restriction.
Protection of Rights and Other Legal Purposes

All the information collected might be shared, including Personal Information, whereas it is applicable by law:

In response to subpoenas or other legal process or if in our good faith opinion such disclosure is required or permitted by law
To defend our terms and conditions or other policies applicable to our Services
Whereas a request is made by a governmental agency for information relevant to their investigation
Regarding the safety, health, life, property and protection of rights for us or for any third party.

Affiliated Companies; Business Transfers

We share the information we collect, including Personal Information, with any third parties that we are in a connection with, thus your Personal Information might be disclosed to these parties in the event of a merger, purchase, sale (including a liquidation, realization, foreclosure, or repossession), during negotiations and any other type of acquisition of all or any portion of Company assets, conveyance or transfer of all or a portion of our business to another company.
Your Choices

You have the option to deny any information to us. Choosing not to, might lead to an access limitation to our features and/or services. You have the possibility to unsubscribe or to opt out from receiving marketing communications from us, using the unsubscribe link or by Contacting Us. As an important note, we advise that the information that you supply to us is kept up to date. These Services may allow you to access, review, correct, update, and remove or make inaccessible Personal Information you have provided through your account settings. Through the Personal Information section in your Dashboard, or by contacting us using our Contact Us form, you can change and/or update your personal information at any time. Also, regarding our mobile platforms, you have the option the uninstall the application to further stop the collection of information. We will make sure that the requested changes in the databases will be executed as soon as possible.
Rights Applicable to Certain Users

US Users If you are visiting from the United States (“US”) or other regions with laws governing data collection and use that may differ from the European Union ("EU") law, please note that you may be transferring your Personal Information to the Company in the European Union and in other countries around the world for the purposes described under this Privacy Policy.

In order to keep your Personal Information secure, we will enforce the third party to whom we communicate this data to be processed under the same level of protection as we do with the specified its purpose of its usage. If we are processing your Personal Information based on your consent, you may withdraw that consent at any time.

You have the option to restrict our use of your Personal Information, by contacting us via the Contact Us form, if you have contested the accuracy of that information, or if the utilization of this information is being used unlawfully and/or need to exercise or defend a legal claim. In this case we will secure all your Personal Information and process it only with your consent, or to establish, exercise or defend a legal claim to protect the rights of others. The restriction concerning information claimed to be inaccurate would end if we verify the accuracy of that contested information.

Upon receiving your request and verification of your identity, you will be notified if your Personal Information will be processed, also will supply you with a copy regarding the nature and purpose of processing your Personal Information. In any event this information is inaccurate, you have the option to correct any inconsistencies.

Upon your request, any or all Personal Information that you provided can be deleted if that data is not needed for any purpose it was collected, or used for marketing purposes, or its usage is based on your consent that which you wish to withdraw.

Our Services may be used by children in the EU between the ages of 13 and 16 only with parental consent. However, if the data collected was from a child in the EU under the age 16 without parental consent, we will erase that Personal Information.

In any event when using your Personal information, we change our Privacy Policy in order to permit or disclose the mentioned Personal Information to be used in a different manner than originally collected and authorized by you, we will obtain your consent for any further use of it.

If you have a complaint regarding our compliance with this Policy, you have the right to contact us at privacy@wonderspend.com. Dissatisfaction with our response to this resolution, gives you the right to lodge a complaint with the Supervisory authority in your country of residence in the EU.

If you are not subject to EU law, these rights do not apply to you.

Our services are never meant to be used by children under 13 years of age. We never knowingly collect any kind of Personal Information from children under the age of 13. If you are under the age of 13, do not make any purchases, provide any information or use any interactive or public comment features to our Services. If you believe we might have any information from or about a child under age 13, please contact us at privacy@wonderspend.com.
Data Security and Retention

We take good care about your information to prevent data loss, theft, misuse and unauthorized access, alteration, disclosure and destruction. A secure, encrypted connection is being used on all our pages where you provide and access your Personal Information. WonderSpend uses such measures to keep your data safe, however transmission via the Internet is not fully secure, thus WonderSpend cannot fully guarantee the integrity and security of the information collected. Also, under applicable law, we assume no responsibility or liability for disclosure of your information via transmission errors or unauthorized third-party access since these are beyond our control. All your gathered information will be kept until you choose to close your account. After that time, we may anonymize and aggregate the data and retain it for analytical purposes. Also, we might keep your information on backup media to comply with applicable law, to resolve disputes, to maintain compliance efforts, to support financial audits and for other legitimate business reasons.
Promotional Communications

Push notifications or in-app messages may include both operational messages and promotional messages regarding products, services, and offers that may be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device. As with emails, even if you opt out of receiving promotional communications, we may continue to send you non-promotional push notifications, such as those about your use of the applications or our ongoing business relations.

Periodic emails might be sent from WonderSpend to your account by signing up to the platform. If you have accepted to the terms to receive promotional email communications, you can opt out at any time by following the instructions provided in these emails or contacting us through the Contact Us form. Even in the case of opting out, please be advised that we may continue to send you non-promotional emails and other types of communications, as permitted by law. Service email will contain product order confirmations, reward or payment updates and responses to your submitted forms to us. WonderSpend mobile applications, browser extensions, and websites may send you notifications, such as alerts and sounds. Any push in-app messages or push notifications may include promotional messages regarding services, products and offers which might be of interest to you. When using mobile applications, push notifications and other mobile alerts can be configured in the settings of your mobile device.
Cookie Policy

During interaction with our Services we will collect and store information based on our usage of browser cookies. Cookies are small data file identifiers that are transferred to your computer or mobile web browser that allow us and our affiliate partners to recognize your browser or mobile device during information transfers about you by using our Services. The purpose of these cookies include authentication, user tracking by visiting web pages. You have the ability to control the usage of these cookies at the browser level. Disabling cookies will prevent your use of certain functions or features on the Service.
Analytics, Targeting, Tracking

We and also our third-party partners might use these cookies, pixels and other technologies to collect data about you, while using our Services such as web browsers, pages viewed, click-stream data, IP address, time spent on pages, links clicked and even conversion information. Data collected from a particular browser or device may be used with another computer or device by means of cross-linking. The usage of ads will be authorized through third parties we work with, with the intent of customizing campaigns based upon your preferences. These third parties may also collect Personal Information about your online activities over time. Some of these third-party service providers we engage with, may also place their own cookies on your browser. Please note that this Privacy Policy covers only our use of cookies and does not include the use by such third parties.
Third-Party Data

The hyperlinks to websites of retailers and merchants are not controlled by us, but operated by third parties (“Third-Party Websites”). Note that our Privacy Policy does not apply to these third-party websites and that we do not represent these third parties or their policies and business practices.
Social Features

Some of the functionalities on the Services are designed to allow interactions initiated by you, between the Services and third-party services or websites, including third-party social networks. Some examples of Social Features are which allow you to link your account from a third-party website or service to ours to “like or “share” our Services content on other websites or services, to sign in to these Services by using your username and password from a third-party site or service and by connecting our Services with other third-party Services and websites. All the information that you choose to share by using Social Features will or might be used by and/or displayed on our Services. Also, if you post any information on a third-party platform which might reference our Services, for example by using a hashtag associated with WonderSpend in a tweet or status update, your post might be published on our Services with the accordance of the terms of the third-party website or service. When you use our Services with a third-party site or service, both WonderSpend and the third party may have access to certain information about you and your use of our Services and the third-party site or service. We can also have access to your information if any user from a third-party gives us access to their profile and you are linked with them or any information that is accessible through your connections’ profile pages, web pages, any similar pages on social-networking or third-party website services. The information collected and stored by the third parties remains subject to those third parties’ privacy policies, including whether the third parties continue to share information with us, the types of information shared, and your choices with regard to what is visible to others on those third -party websites or services.
Referral Programs

WonderSpend may offer some features which allow you to inform any individual about our Services. Choosing to use our referral features, will mean that we will ask for your referral’s e-mail address in order to send them a message to invite them to join our platform. WonderSpend will store this information in order to track the success rate of such referral program. Accepting participation in such referral programs, you consent to a warrant that you have a personal relationship with your referral and that you are willing to share this information with WonderSpend with the purpose to invite them to join our Services.
Changes to This Privacy Policy

This Privacy Policy is current as of the effective date set forth above. WonderSpend reserves the right to change this privacy policy from time to time consistent with applicable privacy laws and principles. If we make changes to this Privacy Policy we will notify you by revising the date at the top of this Privacy Policy, and in some cases, we may provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).
Contact Us

If you have any questions regarding this Privacy Policy, please feel free to contact us by email at privacy@wonderspend.com or by mail at Vasile Lucaciu 37, Satu-Mare, Satu-Mare, Zip 440038, Romania, Attention: TradeHolding Ltd. Legal.