Privacy Policy

Effective Date: October 12, 2023

Last Updated: May 31, 2023

This is the Privacy Policy for Play Cent Technologies Private Limited and its affiliates and subsidiaries. In this policy, we call ourselves “Datalayer,” “we,” “us,” or “our.” We call you, the person using our apps or visiting our website, “you.”

Datalayer offers a service that allows you to earn rewards from your everyday purchases, identify financial savings opportunities, and get paid for sharing your data with Datalayer and our Participating Businesses for market research or personalised ads.

If you have opted out of Data Dividends, we will not share your Personal Information with Participating Businesses for market research or personalised advertisements.

This Privacy Policy document outlines the types of information that is collected and recorded by Datalayer, how we use it and why.

This Privacy Policy applies to all the Users whose Personal Information has been processed by Us in the course of our business, mobile applications, forums, blogs, and other online or offline offerings

By visiting the Platform, You (“You” or “Your”), accept and agree to be bound by the terms and conditions of this privacy policy (“Privacy Policy”).

By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms of Service, available here https://datalayer.co/terms.html, which are incorporated as if fully recited herein. Terms defined in the Terms of Service that are not defined herein shall have the same definition as in the Terms of Service. This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Personal Information We Collect

What is Personal Information?

When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

We collect Personal Information in connection with your visits to and use of the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other tracking technologies.

What Personal Information is collected from you?

We collect Personal Information from you that you may provide to us through the Service or otherwise. The categories of information we collect may include

Contact information,For example, your first and last name, email and mailing addresses, and phone number.

Account and profile information, For example, Personal Information you provide to us after you create a user account. The Personal Information we collect could include your contact information, Demographic data, date of birth, gender, interests , credit score, income, Transaction Data, Digital Purchase Data,Online/physical Receipt Data, Banking data, Browsing Data, Survey Responses, Cashback Offer Data and Health Information. We also collect additional information if you provide it.

Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise;

Transaction Data,This includes the data related to your linked bank account(s) or credit or debit card(s) (a “Payment Credential”): account numbers and card transaction data collected and stored by our third-party providers (including credit and/or debit card transaction data collected by our third-party providers, that covers the prior 48 months and all subsequent transactions ), bank fees and refunds, direct deposits, rent and/or mortgage payments, and bill payments (collectively, the “Transaction Data”).

Digital Purchase Data,We also collect purchase information, such as item/SKU-level data, through email accounts or digital consumer accounts that you link to your Datalayer account (collectively, the “Linked Account(s)”). Our Rewards Program allows you to link email accounts or digital consumer accounts to your Datalayer account, as directed by you, through the use of your login credentials to such account(s) so that Datalayer, as your agent, can retrieve purchase information from digital receipts from historical (up to 50 years prior) and future purchases in your digital consumer account or email. In processing your digital receipt data, Datalayer may retrieve Personal Information such as name, payment method, billing address, mailing address, and other information contained in the digital receipt email (collectively, the “Digital Account Data”).

The account credentials that you enter for these accounts are not stored with Datalayer, but are encrypted and stored locally on your device.

While linked, Datalayer will automatically collect digital receipt data from your linked email accounts.

Survey Responses,For example, information you provide when answering survey questions in the App, which may include information about your activities/interests, opinions about products/services, household information, and other demographic information.

Marketing data, such as when you sign up to receive information regarding our products and details about your engagement with them;

Job application data, such as information you submit in connection with an application for a job (including information in a CV, resume or otherwise collected through the job application process);

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public sources, such as government agencies, public records, social media platforms, and other publicly available sources;

Private sources, such as social media platforms, including Instagram, LinkedIn, and Twitter.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer, and your interaction over time with the Service, our communications and other online services, such as: Device data, such as your computer operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area; Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

Data Connections, We may receive your personal and digital data from external accounts, such as Flipkart, Amazon or Google once connected

For Gmail users:
We comply with the Google API Services User Data Policy, including the Limited Use requirements, and use information collected through your use of My Purchases from your Gmail account only to provide you points for your purchases on behalf of our participating partners and to improve user-facing features on the App or Website. We do not share your information that we receive through Google Gmail APIs with third parties other than those service providers as necessary to support functions we need to provide you points for your purchases, for legal or security reasons, or as part of an acquisition or liquidation.

User content, For example, information about how you use the Service and interact with us, including information associated with any content you submit to us, and information you provide when you use any interactive features of the Service.

Other information,
We may collect additional types of information which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

What Personal Information is collected from third-parties?

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. We may receive the same categories of Personal Information as described above from the following third parties:

Information we obtain from social media platforms
We may maintain pages on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your Personal Information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

Information we obtain from health trackers and apps
At your request, we may also collect Health Information gathered or generated by your use of any third-party health application, system, program and/or device that you connect to the Service (the “Connected Health Systems”).

For example, if you choose to connect Apple’s Health app on your iPhone or Apple Watch, we may receive information such as Activity History (i.e., steps taken, workouts, sleep etc.,), Health Vitals (i.e., body temperature, heart rate), Self-Reported Characteristics (i.e., height, weight, body fat percentage, gender), Clinical Records (i.e., protein samples, lab results) and information about the source of such data. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party application, system, program and/or device. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.

Information we obtain from service providers
Our service providers that perform services solely on our behalf, such as payment processors, video and audio providers, or survey and certain advertising/marketing providers, collect Personal Information and may share some or all of this information with us.

Referrals
Users of the Service may refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

Information we obtain from other third parties
We may receive Personal Information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your Personal Information from other third parties, such as marketing partners, publicly available sources and data providers. Personal Information obtained from these third parties may include payroll information (e.g., hours worked, wages earned, and tax withholdings etc., ). We also may obtain your information from brand partnerships or through transactions such as mergers and acquisitions.

Deidentified information
Through the provision of our Service, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Datalayer commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Datalayer satisfies the requirements under applicable law.

How we use and protect your Personal Information

Datalayer uses your Personal Information to deliver the Service to you, the goal of which is to help you earn money on everyday purchases and to identify relevant savings opportunities. This includes using your Personal Information to do the following:

Fulfill your requests and provide the Service to you
This includes
  • Making the Service available to you and Participating Businesses;
  • Coordinating access to your account, and establishing and maintaining your user profile on the Service;
  • Enabling the security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • Responding to requests, suggestions, questions, and comments, and providing other types of user support;
  • Sending you service/transaction-related messages, such as changes to your account;
  • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions; and Providing support and maintenance for the Service.
  • Serve You Targeted Advertisements. We may use your PII to serve you advertisements with the Service that are targeted to your interests.

Personalize your experience on our Service
This includes providing you with content or other products or services you might be interested in and de-emphasize content you’ve already read or viewed.

Market our service
We will send you communications about new features, updates, products, and special offers. We may also use your information to serve you ads about our products or other products or services we (or our advertising partners, such as other third-party brands) think you might find interesting. We may also use individual and aggregate information about you to inform our marketing and advertising campaigns.

Communicate with you
For example, we may communicate with you about your account activities, such as by providing you transaction confirmations or alerting you when a subscription is up for renewal. If you register with us, we may enroll you in our email newsletters or other periodic electronic communications and may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. For more information on how to adjust your communications preferences, see “The choices you have regarding our collection, use and sharing practices” section of this Privacy Policy.

Monitor, improve, and develop our products and services We may use your information to understand our visitors and customers and to tailor or optimize our Service. For example, we may analyze statistics and trends to make our Service better and to develop the Site or new services or features.

Prevent fraud
We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law
We may use information to protect Pogo, our users, and our Service. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Use, this Privacy Policy, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets and may use information in connection with or as an asset in such a corporate business transaction. Personal Information may also be used in the event of insolvency, bankruptcy, or receivership.

Create anonymous, aggregated or de-identified data
We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

For any other purposes with your consent, at your direction, or where notice is provided
We may use your Personal Information for any other purposes with your consent, at your direction, or where notice is otherwise provided.

Purchase Data
In addition to the use cases described above, Datalayer and Participating Businesses may use your Transaction Data, Digital Purchase Data, Other Receipts Data, Browsing Data, Location data and Survey Responses (collectively, the “Purchase Data”) in these ways to deliver the Service to you
  • To credit you with automatic cash back when you make qualifying purchases;
  • For market research and providing insights into consumer purchasing behaviors and conducting surveys based on past purchases;
  • To provide targeted offers that may be of interest to you;
  • To confirm a specific transaction occurred or rewards should be provided;
  • To create a record of your Purchase Data to use data in connection with the Service;
  • To respond to a request from government authority or a payment organization involved in a transaction with you or a Participating Business;
  • To analyze bank fees charged on your Payment Credential to: (i) generate an email you can send to your bank to request the bank to provide a refund of such fees, if applicable; and (ii) recommend a low interest loan from a partner to pay off high interest credit card debt;
  • To help identify ways you can save money on insurance, loans, bills, utilities, prescriptions, mortgage payments and other third-party services.
  • To provide you rewards relating to item/SKU-level purchases.
Health Information
With your permission, your Health Information may be used by or shared with Datalayer and Participating Businesses in these ways to deliver the Service to you
  • For market research and providing insights into consumer health behaviors/conditions and conducting surveys based on health attributes;
  • To build and enhance consumer profiles;
  • To provide targeted offers that may be of interest to you;
  • To surface clinical study or other research study opportunities for which you may be eligible to participate in.

Security Practices
We employ a number of organizational, technical and physical safeguards designed to protect the Personal Information we collect.

We do not store your payment card or bank account information, and we do not have control over or responsibility for your payment card or bank account information. When you provide your payment card and/or bank account information through the Site or App, it is stored and/or processed by our third-party service providers.

Please note that security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information.

How we share your personal information

Datalayer may disclose your Personal Information when you share content with others on the Service, when you consent or instruct us to share your information with third parties, or when we have a legitimate business or legal need to share your information.

For example, your information may be shared with

Affiliates
We may share your Personal Information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
  • Making the Service available to you and Participating Businesses;
  • Coordinating access to your account, and establishing and maintaining your user profile on the Service;
  • Enabling the security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • Responding to requests, suggestions, questions, and comments, and providing other types of user support;
  • Sending you service/transaction-related messages, such as changes to your account;
  • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions; and
  • Providing support and maintenance for the Service.

Participating Businesses through the Rewards Program
If you have opted in to Data Rewards, we may share your Personal Information, including Racial / Ethnic Origin, Precise Geolocation and Health Information, with participating businesses, including our affiliates and subsidiaries, our service providers or advisors, marketing/advertising and strategic partners, analytics providers; social networks; our clients, partnered brands, retailers and agencies (collectively, "Participating Businesses"). These Participating Business partners will use this data in accordance with their own privacy policies. If you have opted out of Data Rewards, we will not share this information with Participating Businesses, in accordance with our market research or personalized advertisements initiatives.

Service providers
We may share your Personal Information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, advertising, marketing, and database management services).

Xoxoday. We use xoxoday.com to process your redemption request, which collects your contact information and cash out method preference to issue payment. You may find out more about how xoxoday provides services by accessing xoxoday’s privacy policy (see https://www.xoxoday.com/privacy-policy).

Information we process to understand how our products are used and make improvements
Firebase, Google analytics, Sentry & more.

Pharmaceutical and healthcare partners
At your direction, we may share your Personal Information, including your Health and Location Data, with our pharmaceutical and healthcare partners.

Lending and insurance partners
We may share your pre-qualification information (i.e., birthdate, credit score, gender, and income) with our loan and insurance partners.

Other users of the Service and the public
We may enable you to disclose Personal Information to other users of the Service or the public at your direction. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We do not control how other users or third parties use any Personal Information that you make available to such users or the public.

Professional advisors
We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety
We may share your Personal Information for compliance, fraud prevention and safety purposes.

Law enforcement, regulators, and other parties for legal reasons
We may share your Personal Information with third parties as required by law or subpoena or if we reasonably believe that such action is necessary: (a) to comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Datalayer, our users, visitors, or others.

Business transfers
We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

With your consent or according to your instructions
We may share information in other ways if you give us consent or direct us to do so, such as sharing your Personal Information for market research or personalized advertisements.

Our third party data collection and online advertising practices

Datalayer may participate in interest-based advertising and use third party advertising partners to collect information from visitors to the Service for the purpose of displaying interest-based advertisements on other websites, apps or services, social networks, or on other devices you may use. Typically, though not always, these third-party ad networks use cookies and tracking technologies to recognize your browser or device and to collect information about your visit to our Service to provide you with customized content, advertising, and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Please see the section below to learn how you can opt out of interest-based advertising.

Are There Other Ways My Personal Data Could Be Shared?
You may elect to share certain personal information with individuals, entities, or with the public via your use of the Service. In this case, you will control such sharing via settings that we provide. For example, the Service may make it possible for you to publicly share information via Platforms such as Facebook, or Instagram. Be aware that when you choose to share information with friends, or with the public at large, you may be disclosing sensitive information, or information from which sensitive information can be inferred. Always use caution when sharing information through the Service. You understand and agree that we are not responsible for any consequences of your sharing of information through and beyond the Service.

Your choices

In this section, we describe the rights and choices available to all users:

Access or Update Your Information
If you have registered for an account with us, you may review certain Personal Information in your account profile by logging into your account and navigating to “Profile” in the App. To update or delete your account, you can contact us at info@datalayer.co

Opt-out of marketing communications. You may opt-out of marketing-related emails by
contacting us at info@datalayer.co. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Opt in for Data Rewards
By default when you sign up on Datalayer, you will be opted in to sharing certain Personal Information for market research or personalized advertisements, you will earn rewards in connection with this opt-in (“Data Rewards”).

You may opt out of this by contacting us at info@datalayer.co

Please note that if you are not opted-in to Data Rewards, certain incentives and Services affiliated with the Datalayer Rewards Program may not be available to you.

Deleting Your Information
you can contact us directly at info@datalayer.co

Cookies & Other Tracking Technologies
To manage cookies, an individual may have the ability to change their browser settings to (for example): (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies (or certain types of cookies, such as cookies set by third parties). Note that similar controls may exist for other tracking technologies, such as pixels, SDKs, and localStorage. Please check your device or browser settings and related documentation for more information.

Further, note that restricting the use of these technologies might negatively impact an individual’s experience using our Service, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Policy. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. An individual may also have options within their email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

Browser settings. Changing your internet web browser settings to block third-party cookies.

Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.

Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Right to Know/Right to Delete. ‍You may submit a request to know, access, correct or delete the information we have collected about you by sending a request to info@datalayer.co. You can also update your account information or delete your account / data by contacting us through the above email.

Our policies on other sites, mobile apps and services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Children

The Service is not directed to, and we do not knowingly collect Personal Information from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us and we will promptly delete such information. We encourage parents with concerns to contact us at info@datalayer.co

Retention

We will usually store the Personal Information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain Personal Information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or deidentify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or deidentification is possible.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you including by updating the “Effective date” at the top of this Privacy Policy. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting).

How to contact us

Please direct any questions or comments about this Privacy Policy or privacy practices to info@datalayer.co.